Battery Passport Readiness Checklist: 12 Steps to 18 February 2027

Questo articolo non è ancora disponibile nella sua lingua, quindi è mostrato in inglese.

The battery passport deadline is fixed: from 18 February 2027, EV batteries, light means of transport (LMT) batteries and industrial batteries above 2 kWh cannot be placed on the EU market without one, under Article 77 of Regulation (EU) 2023/1542. What is not fixed is how prepared you will be when it arrives.

This is a working checklist — twelve steps, in the order that experience with product compliance projects says they should happen, working back from the deadline. The consistent lesson from early movers is that the passport web page is the easy part; the data behind it is the project.

Step 1: Confirm which of your batteries are in scope

Start with an honest scoping exercise. The passport applies to EV batteries, LMT batteries and industrial batteries with a capacity above 2 kWh — not portable consumer batteries. List every model you place on the EU market, its category and capacity, and mark which need passports. Borderline industrial products near the 2 kWh line deserve particular care. This list is your project scope; everything else keys off it.

Step 2: Audit your data against Annex XIII

Annex XIII of the regulation defines the passport's content: general battery and manufacturer information, compliance and certification data, carbon footprint, supply-chain due diligence, materials and composition, circularity and resource efficiency information, and performance and durability data. Build a spreadsheet with those categories as rows and your models as columns, and mark each cell: have it, have it but unverified, don't have it. Our battery passport requirements guide details what sits in each category. The gaps you find here dictate the length of the rest of the project.

Step 3: Start supplier data collection now

Most of the gaps will be data you do not own: cell chemistry detail, upstream emissions, raw material origins, recycled content evidence. Supplier data collection is the slowest workstream in every passport project, because it depends on other organisations' willingness and ability to respond. Send structured data requests early, chase them systematically, and where suppliers are unresponsive, escalate to commercial leverage — 2027-onwards purchase orders are the leverage.

Make the requests easy to answer: a fixed template per supplier, one named contact on each side, and a stated deadline tied to your production planning. Record what arrives against your Step 2 audit as it comes in, so you always know which models are passport-ready and which are blocked, and by whom. Suppliers serving several EU customers will be receiving similar requests from everyone; the ones who answer yours first are telling you something useful about who to build 2027 volumes around.

Step 4: Calculate the carbon footprint

The carbon footprint has its own timeline: the Regulation set 18 February 2025 as the target for EV battery declarations and 18 February 2026 for rechargeable industrial batteries, but each starts 12 months after the Commission adopts the calculation delegated act, which was still outstanding in September 2026. Maximum thresholds follow under a further delegated act, applying from 18 February 2028 for EV batteries or 18 months after that act, whichever is later. If you have not yet produced a compliant carbon footprint for an in-scope model, treat this as the critical path: lifecycle assessment work takes months and depends on the supplier data from Step 3.

Step 5: Put your due diligence policy in place

The regulation requires supply-chain due diligence aligned with the OECD Due Diligence Guidance for cobalt, natural graphite, lithium and nickel. Check your position under the due diligence chapter's thresholds, then build a policy that actually produces output: mapped supply chains for the four materials, identified risks, mitigation, and reporting that can feed the passport. An unimplemented PDF policy fails both the audit and the passport.

Step 6: Assemble materials, composition and recycled content evidence

Document what each battery contains — including critical raw materials and hazardous substances — and gather chain-of-custody evidence for recycled content. Recycled content minimums arrive from 18 August 2031 (cobalt 16%, lead 85%, lithium 6%, nickel 6%, rising by 2036 to cobalt 26%, lithium 12% and nickel 15%), so the evidence trail you establish now is infrastructure you will rely on for a decade.

Step 7: Compile circularity and dismantling information

The passport must serve repairers, second-life operators and recyclers, so gather dismantling information and spare parts details from engineering. This content rarely exists in customer-ready form; allow time for technical writing, not just data export.

Step 8: Assign an internal owner

Passports cut across engineering, procurement, sustainability, quality and IT. Projects without a single accountable owner stall in the gaps between departments. Appoint one person to own the passport programme, with a standing route into each contributing team — and make maintaining the passport part of a defined role after launch, because state-of-health and other dynamic data mean the record lives as long as the battery does.

Step 9: Choose your passport platform

Only now — with scope, data and ownership understood — choose the software. The core questions: Does it structure data along Annex XIII's categories? Does it handle the public versus restricted access tiers? Can records be updated after publication? Will the hosted passport remain accessible for the battery's lifetime? Can you afford it at your volumes? Options run from enterprise implementations to self-serve platforms; MyProductPassport is the self-serve end, with a free tier that lets you build a real passport before committing budget.

Step 10: Integrate the QR code into labelling

The passport is reached via a QR code on the battery. That QR has to enter your artwork and production process: label design, marking method, placement, durability, and the link between each physical unit and its passport record. Loop in packaging and production engineering early — label tooling changes have lead times, and this step is where a software project becomes a factory project.

Step 11: Test end-to-end

Before the deadline, run a full dress rehearsal on at least one real model: scan the printed QR on a production-representative battery, check it resolves to the right passport, review every data field against your Step 2 audit, verify the access tiers show the right data to the right audiences, and have someone outside the project try to break it. Fix what fails and re-run. A passport that has never been tested from the physical battery inwards is not ready.

Step 12: Go live, then maintain

Go-live is not the finish line. Set a review cycle for passport content, a process for updating dynamic data, and a watch on the implementing acts as the Commission specifies technical formats. The wider regulation keeps evolving around you — recycling efficiency targets for lithium-based batteries step from 65% (end 2025) to 70% (end 2030), lithium recovery reaches 80% by end 2031, and collection targets ramp for portable (63% by end 2027, 73% by end 2030) and LMT batteries (51% by 2028, 61% by 2031). Our guide to the 2027 Battery Regulation changes is a good ongoing reference.

How long does this take?

Working backwards from 18 February 2027: testing and labelling integration want a quarter; platform setup is quick but depends on data; and the data workstreams — supplier collection, carbon footprint, due diligence — are commonly six months or more end to end. If you are starting from a blank sheet, you should be starting now; if you are partway, the audit in Step 2 tells you your true position.

Frequently Asked Questions

What is the battery passport deadline?

18 February 2027. From that date, EV batteries, LMT batteries and industrial batteries above 2 kWh must not be placed on the EU market without a battery passport under Regulation (EU) 2023/1542.

What is the slowest part of battery passport preparation?

Supplier data collection and the carbon footprint calculation. Both depend on organisations outside your control, and the carbon footprint declaration deadlines for EV and rechargeable industrial batteries have already passed, so this workstream should lead the project.

Can a small manufacturer do this without consultants?

Largely, yes. The data gathering is internal work whoever does it, and self-serve passport platforms remove the software build. Where external help earns its fee is typically the lifecycle assessment behind the carbon footprint.

A note on sources: dates and targets cited follow Regulation (EU) 2023/1542; the exact passport data formats will be set by implementing acts, and your specific obligations should be checked against the consolidated text. This article is general guidance, not legal advice.

Start Step 9 early for free: create a battery passport on MyProductPassport and use the template as your data checklist.