When does the EU battery passport apply to industrial and LMT batteries?

Direct answer: Regulation (EU) 2023/1542 requires an electronic battery passport from 18 February 2027 for each light means of transport (LMT) battery, each industrial battery with capacity greater than 2 kWh, and each electric-vehicle battery placed on the market or put into service in the EU. The passport is accessed via a QR code linked to a unique identifier. Buyers should plan data exchange with suppliers well before that date because implementing acts and data-point guidance continue to evolve.

Legal hook. Article 77 of Regulation (EU) 2023/1542 sets the passport duty and points to Annex XIII for the information set. Always read the Official Journal text rather than secondary summaries alone. Commission digital product passport pages give indicative implementation milestones for registries and standards work ahead of the mandatory date.

What is in scope for industrial and LMT. Industrial batteries above 2 kWh—such as many server-rack modules like the 51.2V 200Ah 5U (10.24 kWh) or traction packs such as the 48V 420Ah-class forklift battery—and LMT batteries fall under the passport timeline. Compact packs still need category checks: a 48V 100Ah (5.12 kWh) general pack is typically well above 2 kWh if classed as industrial. EV batteries are also covered by the same Article 77 start date.

Who carries the duty. The economic operator placing the finished battery on the EU market maintains the passport. Component suppliers may need to feed data upstream; clarify roles in contracts so factory, importer and distributor duties are explicit and auditable.

What buyers should request. Unique identifiers, QR process, data fields for chemistry, capacity, manufacturing and due-diligence information as applicable, and a timeline for readiness. Prefer documents available on request over marketing claims that a pack is already passport-complete.

Related compliance. Shipping and test documentation remain separate topics; see UN3480 Class 9 shipping and UN38.3 documents. EU form-factor notes for other products appear in EU thin-size 12V fitment.

Practical timeline. Treat 18 February 2027 as the mandatory passport date for the categories named in Article 77, and track Commission implementing acts for registry operation and data formats ahead of that date. Other Batteries Regulation obligations (for example carbon footprint or due diligence) follow their own schedules and should not be confused with the passport start date.

Stay current. Category definitions and Annex XIII content can be amended by delegated acts; re-check EUR-Lex and Commission DPP pages before locking supplier KPIs for EU SKUs, and keep a change log in the quality system.