Battery Passports and the EU Registry: The Qualified Electronic Seal You Need First

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From 18 February 2027 every light means of transport (LMT) battery, every industrial battery above 2 kWh and every electric vehicle battery placed on the EU market needs a battery passport. The passport is half the job. Its unique identifier also has to be uploaded to the EU digital product passport registry, and the registry only lets in operators who have proved who they are. For a company, that proof is a qualified electronic seal. This guide sets out who needs one, why a UK seal does not count, and what to arrange before February.

Two duties, not one

Article 77(1) of the Batteries Regulation (EU) 2023/1542 requires the passport itself. Article 77(10) adds a second duty: the economic operator placing the battery on the market or putting it into service "shall upload the unique identifier in the registry" set up under Article 13(1) of the Ecodesign Regulation (EU) 2024/1781.

How that registry works is set by Commission Implementing Regulation (EU) 2026/1778, adopted on 16 July 2026 and in force since 6 August 2026. Its Article 1(1)(b) names batteries covered by Article 77 of the Batteries Regulation as one of the product groups it applies to. Our explainer of Implementing Regulation 2026/1778 covers the registry as a whole; this guide is about getting in.

Only verified operators can register

Article 4(3) of Regulation 2026/1778 grants access to the registry for registering passports to verified economic operators only. Article 4(2) sets how a company (a legal person) becomes one:

• A company required to be established in the Union submits evidence of its identity and establishment with a qualified electronic seal, supported by a qualified certificate for electronic seal issued by a qualified trust service provider under Regulation (EU) No 910/2014 (eIDAS), or with a qualified electronic attestation of attributes issued under Union law.
• A company not required to be established in the Union submits evidence of its identity with the same kind of qualified electronic seal, or with an electronic attestation of attributes issued under Union law.

Sole traders verify in a similar way with a qualified electronic signature, or with the other means listed in Article 4(1).

So whichever side of the border you are on, a company that registers needs a qualified electronic seal, unless it has an electronic attestation of attributes issued under Union law. Ask your trust service provider whether such an attestation is available to you; if it is not, the seal is the route.

Why a UK seal does not count

The seal has to come from a qualified trust service provider "pursuant to Regulation (EU) No 910/2014". UK providers are now qualified under the UK's own version of the eIDAS rules, not under the EU Regulation, so their seals do not meet Article 4(2). A UK company needs a provider on an EU Member State's trusted list. Some of those providers issue qualified seals to companies outside the EU.

Verified status runs out

Verification is not permanent. Under Article 4(4), an operator keeps verified status until its electronic identification means expire, and for no longer than three years from verification. After that it cannot register new passports or change registration data until it has verified again. Qualified seal certificates are typically issued for one to three years, so the renewal of the seal and the renewal of your registry status go together.

Who registers your batteries

The duty in Article 77(10) sits with the economic operator placing the battery on the EU market or putting it into service. If you sell to an EU importer, the importer usually places the battery on the market, and the importer registers with its own verified status. If you sell into the EU yourself, the duty is yours.

Can someone else do it for you? Article 8(2) of Regulation 2026/1778 allows a third party to register on an operator's behalf only "where Union law provides" for it, and Article 19(4) requires that third party to be verified itself while the operator stays fully responsible. In September 2026 the Commission's registry helpdesk confirmed that battery passports cannot currently be registered by a service provider on the operator's behalf. Plan on registering with your own verified status.

What to arrange before 18 February 2027

1. Decide who registers. Map which entity places each battery on the EU market: you, your importer, or an EU subsidiary.
2. Order the qualified electronic seal early. Identity checks take time. Some providers ask a company outside the EU for notarised and apostilled documents, so allow weeks, not days.
3. Assign the unique identifiers. Article 77(3) requires each battery's identifier and QR code to follow the ISO/IEC 15459 series. A GS1 Digital Link with a serial number per battery meets that.
4. Build the passports. Collect the Annex XIII data from your cell and pack suppliers, and publish one passport per battery.
5. Keep the proof. After each registration, the registry can produce a proof of registration sealed by the Commission (Article 9). It stays available to download for 90 days from when it is generated, so store a copy with each passport's record.

Frequently Asked Questions

Do UK battery manufacturers need a qualified electronic seal?

A UK company that registers battery passports in the EU registry needs a qualified electronic seal from a trust service provider qualified under Regulation (EU) No 910/2014, or an electronic attestation of attributes issued under Union law (Article 4(2)(b) of Regulation 2026/1778). A seal from a UK-qualified provider does not meet that test.

Does an EU company need a seal too?

Yes, unless it has a qualified electronic attestation of attributes issued under Union law. A company required to be established in the Union verifies with one or the other (Article 4(2)(a)).

Can my passport software provider register for me?

Only where Union law provides for it, and the provider must then be verified itself (Articles 8(2) and 19(4)). The Commission's helpdesk has said battery passports cannot currently be registered by a service provider on the operator's behalf.

How long does verified status last?

Until your electronic identification means expire, and no longer than three years. Then you must verify again before registering new passports or changing registration data (Article 4(4)).

When does the battery passport apply?

From 18 February 2027, for every LMT battery, every industrial battery above 2 kWh and every electric vehicle battery placed on the market or put into service (Article 77(1) of Regulation (EU) 2023/1542).

MyProductPassport builds the battery passports themselves: every Annex XIII field, one passport per battery under GS1 Digital Link, the access tiers Article 77(2) requires, and a record on each passport of what was submitted to the registry and the registration identifier returned. Start free, or see a complete example battery passport.