Battery passport. What changes on 18 February 2027, and what we decide now.
01 The obligation
From 18 February 2027, Regulation (EU) 2023/1542 requires a digital passport for every industrial battery above 2 kWh, light means of transport battery or electric vehicle battery placed on the EU market, reachable through a QR code on the battery. A battery in scope without a passport cannot be placed on the market. The obligation falls on the operator who places it on the market, not on its cell supplier.
02 What it changes for us
The pressure will come from our customers first, who prepare their own passport and will ask for our data, from tenders, where carbon footprint and recycled content already sit in the scoring grids, and from the first competitor ready. Volvo delivered the first battery passport in June 2024, Decathlon is preparing its suppliers and Fnac Darty has launched the product passport on appliances. The first to publish take the lead.
03 What must be gathered
For an industrial battery above 2 kWh, the Commission guidance lists 32 mandatory data points and 26 that apply in certain cases. Most already exist here, scattered across BOMs, certificates, test reports and spreadsheets. Part sits with our cell supplier. Its answer takes weeks, and the request must go out now.
04 The options
- In-house. A compliance profile to hire or reassign, months to reach the required level, engineering and quality pulled onto a subject they are discovering.
- A platform built for large groups. An integration project on top of the licence, with our IT inside.
- Seqo. An infrastructure where we create, manage and share the data of each battery. Nothing to install, no one to hire. Our first models are set up with their team, and when the text changes, our passports follow.
05 The countdown
To publish before 18 February 2027, the supplier request must leave before the end of November 2026, clear of the year-end holidays and Chinese New Year, and the decision before that. Count one to three months between launch and publication.
06 What we decide
- Confirm which references are in scope and who carries the obligation here.
- Send the document request to our cell supplier now.
- Name an internal owner and put the decision on the 2027 budget.