No, a battery passport is not mandatorily required for the delivery of sample batteries, provided that the batteries are not intended to be placed on the market or put into service. According to the battery regulation, Member States shall not prevent the display or delivery of non-compliant batteries (e.g., for trade fairs, exhibitions, or demonstrations), as long as it is clearly and visibly indicated that these batteries do not comply with the regulation and are not available for market placement or use. In such cases, the battery must carry a visible sign clearly stating its non-compliance with the regulation and its prohibition from market use until brought into conformity. Consequently, the requirement for a battery passport does not apply to these non-compliant sample batteries. However, the economic operator remains fully responsible for:

• Ensuring adequate safety measures during transport and handling of the sample battery,
• Preventing the market placement or use of the battery until it complies with all regulatory requirements.

Regulatory Reference:
“At trade fairs, exhibitions, demonstrations or similar events, Member States shall not prevent the showing of batteries which do not comply with this Regulation, provided that a visible sign clearly indicates that those batteries do not comply with this Regulation and that they cannot be made available on the market or put into service until they have been brought into conformity with this Regulation. During demonstrations of such batteries, the relevant economic operator shall take adequate measures to ensure the safety of persons.”

No, a Battery Passport is not required for the supply of battery cells alone. According to the Battery Regulation, the Battery Passport obligation applies to batteries, specifically to rechargeable industrial batteries, light means of transport (LMT) batteries, and electric vehicle (EV) batteries with a capacity above 2 kWh. The passport is required at the level of the battery pack, not at the level of individual cells.

When a cell manufacturer supplies battery cells to an OEM, the cells are not yet placed on the market as standalone batteries. Instead, they are intended to be integrated into battery packs or systems within the OEM’s final product (e.g., vehicles or devices). Therefore, the responsibility to create and provide the Battery Passport lies with the OEM, who is the entity placing the final battery on the market or putting it into service.

The regulation also states that the Battery Passport must be provided at the highest level of granularity, meaning that all relevant data — including data on the cells — must be traceable and integrated into the battery-level passport. However, this does not translate into a requirement for cell manufacturers to create or supply the passport themselves. They are, however, expected to provide necessary technical data to the OEM to support the OEM’s obligation to generate a compliant Battery Passport.

Failure to provide a Battery Passport for applicable batteries after 18 February 2027 constitutes a breach of the EU Battery Regulation. As per the regulation, each Member State is required to establish rules on penalties for such infringements by 18 August 2025. These penalties must be effective, proportionate, and dissuasive, and Member States must also take all necessary measures to ensure enforcement.

This means that companies failing to comply with the Battery Passport requirements after the specified date may face legal and financial penalties, the nature and severity of which will be determined by the specific rules implemented in each Member State. These penalties are designed to ensure compliance and encourage responsible battery management in the EU market.

Regulatory Reference:
“By 18 August 2025 Member States shall lay down the rules on penalties applicable to infringements of this Regulation and shall take all measures necessary to ensure that they are implemented. The penalties provided for shall be effective, proportionate and dissuasive. Member States shall, without delay, notify the Commission of those rules and of those measures and shall notify it, without delay, of any subsequent amendment affecting them.”

The Battery Passport is required at the battery pack level, not at the cell or module level. According to the EU Battery Regulation, the Battery Passport must be provided for rechargeable industrial batteries, electric vehicle (EV) batteries, and light means of transport (LMT) batteries with a capacity greater than 2 kWh. These batteries are considered in their composite form, meaning as assembled battery packs that are placed on the market or put into service.

The regulation further states that the Battery Passport must contain information at the highest level of granularity, which includes data on the cell and module components within the battery. However, this does not mean a separate passport is required at the cell or module level. Rather, all relevant data from those components must be aggregated into a single passport associated with the final battery pack.

Yes, the Battery Regulation requires that labels and the QR code be printed or engraved visibly, legibly, and indelibly on the battery. This means they must remain durable and readable for the entire lifespan of the battery, including over long periods of use (e.g., 5–10 years). This requirement ensures that essential information, including access to the Battery Passport, remains available throughout the battery's operational life.

Where printing or engraving directly on the battery is not possible — due to the battery's nature or size — the regulation allows for the label and QR code to be affixed to the battery packaging and accompanying documentation instead.

Additionally, if a battery undergoes preparation for re-use, repurposing, or remanufacturing, it must bear new labels or markings, including updated information about its changed status, which must be accessible through the QR code. This ensures that the label and associated digital information remain current and accessible, even after significant changes in the battery's lifecycle.

Regulatory Reference:
“The labels and the QR code referred to in paragraphs 1 to 6 shall be printed or engraved visibly, legibly and indelibly on the battery. Where this is not possible or not warranted on account of the nature and size of the battery, the labels and the QR code shall be affixed to the packaging and to the documents accompanying the battery.”
“Batteries that have been subject to preparation for re-use, preparation for repurposing, repurposing or remanufacturing shall bear new labels or shall be marked with markings in accordance with this Article, and containing information on their change of status in accordance with point 4 of Annex XIII, which shall be accessible through the QR code.”

Access to Data:
Access to the Battery Passport is granted free of charge to consumers, economic operators, and other relevant actors, but based on clearly defined access rights as outlined in Annex XIII of the Battery Regulation and further specified through an implementing act to be adopted by the European Commission by 18 August 2026.

These access rights will be determined based on whether a person or entity is considered to have a "legitimate interest", and will define:

• Which actors can access specific categories of data;
• What actions they may take with that data (e.g., download, share, publish, or reuse it);
• The scope of access, particularly with regard to protecting commercially sensitive information.

The Commission will consider the following criteria when defining legitimate interest and access levels:

• The need for data to evaluate the status or residual value of a battery;
• The need for data to support preparation for re-use, repurposing, remanufacturing, or recycling;
• The obligation to limit access to sensitive commercial information to the minimum necessary, in accordance with EU law.

Right to Alter or Change Data:
Only specific parties are authorized to alter or update data within the Battery Passport. These include:

• The economic operator responsible for fulfilling the Battery Passport obligations under Article 77(4) or (7);
• Or operators authorized to act on their behalf (e.g., third-party data managers or digital service providers).

These responsible parties must ensure that the data stored in the Battery Passport is accurate, secure, and compliant with regulatory requirements.

Regulatory References:
“Consumers, economic operators and other relevant actors shall have access to the battery passport free of charge and based on their respective access rights set out in Annex XIII and the implementing act adopted pursuant to Article 77(9).”

“The data included in the battery passport shall be stored by the economic operator responsible for the fulfilment of the obligations under Article 77(4) or (7), or by operators authorised to act on their behalf.”

“By 18 August 2026, the Commission shall adopt implementing acts specifying which persons are to be considered persons with a legitimate interest as referred to in points 2 and 4 respectively of Annex XIII... and to what extent they can download, share, publish and re-use that information.”

If a battery is disassembled and some of its modules are used to construct a new battery, this constitutes a case of preparation for re-use or repurposing, depending on whether the original battery was classified as waste. In such cases, a new Battery Passport must be issued for the newly formed battery

According to the Battery Passport Consortium's guidance, operations such as repurposing, remanufacturing, or preparation for re-use trigger the need for a new passport. This new Battery Passport must:

• Include updated data on the reassembled battery configuration.
• Provide a link or reference to the original battery passport, to ensure traceability across the battery’s lifecycle.
• Clearly indicate the changed status of the battery (e.g., repurposed or remanufactured), in accordance with regulatory requirements (including Annex XIII of the EU Battery Regulation).

The distinction between re-use and preparation for re-use is essential:

• Re-use (involving non-waste batteries) typically does not require a new passport—only updates to the existing one, if necessary.
• Preparation for re-use (involving waste batteries) does require the issuance of a new Battery Passport.

In the case described — where modules from a disassembled battery are used to create a new battery — the activity clearly falls under preparation for re-use or repurposing, thus mandating a new passport.

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