The 2027 milestone
Review the battery passport milestone alongside your battery category and market activities.
A milestone with a defined scope
Article 77 establishes February 18, 2027 as the battery passport milestone for EV batteries, LMT batteries, and industrial batteries above 2 kWh placed on the market or put into service. The 2 kWh threshold is not a blanket threshold for all three categories.
Useful starting points
- Confirm battery classification using the current definitions.
- Map the activities and dates relevant to your organization.
- Plan information gathering and a representative pilot.
Confirm the categories and activities relevant to your work.
Connect source information, owners, identifiers, and access.
The Article 77 passport milestone for the stated battery categories.
Guides in this topic
What Happens on 18 February 2027 for Battery Passports?
On 18 February 2027 each LMT, industrial above 2 kWh and electric vehicle battery placed on the market or put into service must have a battery passport.
What Is the Readiness Sequence for 2027?
Readiness runs from classification through supplier data, identifier and access design, whole system testing and a placing gate, with evidence at each step.
What Is the Delegated Acts Pipeline for Batteries?
Delegated and implementing acts set detailed Battery Regulation rules, tracked from empowerment through consultation and adoption to entry into force and application.
What Is the Difference Between Expected and Fixed Dates?
Fixed dates are set directly in the Regulation, conditional dates depend on a delegated act, and expected dates come from work programmes without legal duty effect.
What Guidance Publications Should Be Watched?
Guidance, JRC methodology and standards publications should be logged with date, subject and duty map effect, and the duty map reviewed after each publication.
How Should a Dated Timeline Be Prepared for Specific Batteries?
A dated timeline is built from a complete battery register, mapping each duty to each model with basis labelled dates, roles and evidence references.
How Does the Timeline Differ by Battery Category?
Each battery category carries a different duty set on the same date axis, with passport, carbon, performance and collection duties following category, capacity and rechargeability.
How Does the Timeline Differ by Operator Role?
Each operator role carries a different readiness date anchored to its entry point, from manufacturer placing through importer and distributor checks to repair, recycling and second life events.
What Timeline Misconceptions Distort Battery Planning?
Common misconceptions include universal passports, manufacture as placing, QR as passport, expected dates as fixed, and guidance as law, each corrected by returning to the Regulation text.
How Does Transition Work for Batteries Already on the Market?
Batteries placed before 18 February 2027 do not acquire a passport duty by the arrival of the date, while batteries placed from that date do, judged by the placing act.
What Applies Before 2027 Under the Battery Regulation?
Before 2027 the Regulation already applies in part, with conformity, labelling, collection and documentation duties on their own dates, alongside passport preparation.
What Happens If a Delegated Act Slips?
A delegated act slip requires tracking, recalculation of conditional dates, holding open affected fields, and review of interim records when the act is adopted.