What Happens on 18 February 2027 for Battery Passports?

The 18 February 2027 milestone is the fixed date in Article 77 of Regulation (EU) 2023/1542 from which each LMT battery, each industrial battery with a capacity greater than 2 kWh and each electric vehicle battery placed on the market or put into service must have a battery passport. The date is fixed in the Regulation text, it is not an expected date dependent on a delegated act, and it applies to batteries placed on the market or put into service from that date, not to batteries already placed before it. The milestone is therefore a placing date threshold, and the planning question is always whether a specific battery is placed from that date in a passport category.

The same date also brings the QR code marking duty for batteries within scope under Article 13 and the removability and replaceability duties for portable and LMT batteries under Article 11. The three duties share a date but remain separate, with separate evidence and separate checks. A battery that meets one duty on the date but misses another fails the combined requirement for the date, and a milestone checklist that lists only the passport will hide the other two duties. The milestone should be planned as a combined date, with separate lines for each duty.

What exactly happens on 18 February 2027?

On 18 February 2027, the passport duty in Article 77 applies to the three categories named, the QR code duty in Article 13 applies to batteries within scope, and the removability and replaceability duties in Article 11 apply to portable and LMT batteries. Each duty is checked separately: the passport is checked for existence, identifier resolution and Annex XIII content; the QR code is checked for presence, legibility and resolution; removability is checked for design, instructions and replacement availability. A battery placed on the market from that date must pass all three checks where all three apply, and the evidence file should show each check separately.

A milestone checklist should list the passport, the QR code and removability as separate lines, each with a status, an evidence reference and a checker. A checklist with a single ready line for 2027 cannot show which duty is ready and which is not, and a gap in one duty will be hidden by readiness in another. The checklist should be dated as checked on 28 October 2026 for the framework, with a review trigger for each delegated act that remains open and that affects passport detail.

Which batteries are covered on that date?

Batteries covered on that date are LMT batteries, industrial batteries above 2 kWh and electric vehicle batteries placed on the market or put into service from 18 February 2027. Portable batteries and SLI batteries are not covered by the passport duty, although they are covered by the QR code duty and by other labelling, collection and removability duties. Industrial batteries at or below 2 kWh are not covered by the passport duty, although they remain inside other Regulation duties. The coverage test is category plus capacity where applicable, plus placing date, and all three elements must be checked.

Worked check: an LMT pack, an industrial pack above 2 kWh and an electric vehicle pack, all placed on the market in March 2027, each need a passport. A portable pack placed on the market on the same day needs a QR code but no passport. An industrial pack at 2 kWh exactly, placed on the same day, needs a QR code but no passport, because the passport threshold is greater than 2 kWh. The placing date is the same for all four; the category and capacity results produce different passport outcomes.

What does placed on the market mean for the milestone?

Placed on the market means the first making available of a battery on the Union market, and put into service means the first use of a battery in the Union where the battery has not previously been placed on the market. The milestone attaches to that first making available or first use from 18 February 2027, not to manufacture, import shipment, warehousing or later resale in the ordinary chain. A battery manufactured in 2026, warehoused, and first made available in March 2027 is placed on the market in March 2027 and needs a passport. A battery first made available in January 2027 does not acquire a passport duty by the arrival of February, although later duties on repair, life stage change or resale may create a new placing question.

Placing evidence should record the placing date, the first making available act, the operator who carried it out and the battery identifiers placed. A record that lists only a manufacture date, or only a sale date in a later distribution step, cannot prove the placing date. The placing record is the anchor for the milestone, and it should be filed with the passport evidence, so that an authority can check the milestone without reconstructing the distribution chain from invoices.

What does not happen on 18 February 2027?

What does not happen on 18 February 2027 is a general passport duty for all batteries, a retroactive passport duty for batteries already placed, or a complete settlement of all passport detail. Portable and SLI batteries do not acquire a passport duty, batteries already placed do not acquire a passport duty by the arrival of the date, and passport detail that depends on delegated or implementing acts remains open until those acts are adopted. A milestone plan that assumes a universal passport, a retroactive duty or a settled detail set will overbuild in one area and underbuild in another.

A milestone scope note should state the three non events explicitly: no universal passport, no retroactive duty, no settled detail where acts remain open. A note that states only what happens on the date leaves the non events to be inferred, and inference is where planning errors arise. The note should be shared with the teams that plan labelling, data and software, so that each team plans to the same scope.

How should the milestone be evidenced?

The milestone should be evidenced by a placing register, a passport and carrier check per battery, a labelling check per model, and a removability file per incorporated product, each dated and linked to the battery identifiers placed from the milestone date. A register that lists models without identifiers cannot show that each individual battery placed from the date carries a passport. A register with identifiers, carrier resolution results and passport checks shows the milestone at individual battery level, which is the level at which Article 77 applies.

Evidence should be retained with the conformity file, with the milestone register as the first entry in the post milestone evidence set. A register started after the milestone, from memory or from sales data, will be incomplete, because identifier and carrier checks cannot be reconstructed reliably after placing. The register should be started before the milestone, in preparation, and used live from the first placing on or after the date.

What misconceptions surround the milestone date?

Misconceptions include treating the date as a grace period end for all duties, treating manufacture before the date as an exemption regardless of placing date, treating a QR code as a passport, and treating the date as the settlement of carbon footprint and other delegated act duties. Each misconception is corrected by returning to Article 77, Article 13 and Article 11, and to the placing date. As checked on 28 October 2026, the milestone date is fixed, and the surrounding detail should be checked against the current act status before planning relies on it. This guide gives general educational information only and is not individual legal advice. A reader with a specific battery or market decision should check the current Regulation text and any applicable delegated act, as checked on 28 October 2026, before acting.

This guide gives general educational information only and is not individual legal advice. A reader with a specific battery or market decision should check the current Regulation text and any applicable delegated act, as checked on 28 October 2026, before acting. The milestone is a placing date threshold for three categories, and the checklist should show passport, QR and removability as separate lines.