QR and Registry Implementation Plan for the Battery Passport

A QR and registry implementation plan for the battery passport works from identifier to data carrier to registry, with each link designed, built and tested in order, so that a scan of the carrier resolves to the correct individual record, and the record identifier is registered where the Regulation requires registration. The identifier is the foundation, because a carrier that resolves to the wrong record, or a registry entry that names the wrong identifier, breaks the link that the passport is designed to provide. The plan should therefore start with the identifier scheme, then the carrier, then the registry, and should test each link separately before testing the whole chain, because a whole chain test that fails does not show which link failed.

The scope is the identifier, data carrier and registry arrangements for Article 77 passports, as described in the Regulation and the Commission guidance, as checked on 28 October 2026. The guide states no registry platform, no carrier technology recommendation and no claim about the final registry design, which depends on further acts.

How is the identifier scheme designed?

The identifier scheme is designed to distinguish model from individual battery, to remain unique for the life of the battery, and to survive changes of holder, status and record system. The scheme should state the format for the model identifier and for the unique battery identifier, the authority that issues each identifier, the check that prevents duplication, and the record that links the two identifiers. A scheme that reuses identifiers, that allows the same identifier for two batteries, or that changes the identifier when the battery changes holder, breaks the continuity that the passport requires. The scheme should be documented, controlled and tested on a pilot set of identifiers before it is used for production batteries, with the duplication check tested by attempting to create a duplicate.

How is the data carrier designed and tested?

The data carrier is designed to resolve to the individual record, to remain legible and durable for the life of the battery, and to be reachable where the battery is installed, with the carrier type, placement and durability stated in the design. The carrier should be tested by scanning at manufacture, at handover and at collection, with the date, the scanner and the result recorded for each test, and with a failure at any test triggering a remedy that preserves the identifier rather than creating a new record. A carrier that scans in the factory but fails after installation has failed the placement test, and a carrier that scans but resolves to the wrong record has failed the resolution test. Both failures need different remedies, and the test record should distinguish them.

What registry arrangements are expected?

Registry arrangements are expected to include an EU registry that stores battery identifiers, as the Regulation and the summaries describe, with the Commission required to set up the registry by a date stated in the Regulation, and with the economic operator uploading unique identifiers to the registry. The precise registry design, the upload format and the access arrangements depend on further acts and guidance, and this guide does not state them as settled, because stating them as settled would invent detail that the sources consulted do not provide. An operator should therefore design the identifier and carrier links to be registry ready, with the identifier format and the upload data prepared, while monitoring the registry arrangements and updating the plan when they are published. Registry readiness is a preparation state, not a completed registration.

What does a QR and registry plan table look like?

A QR and registry plan table shows the link, the design decision and the test that proves the link works. The table below uses general links, without stating a technology.

How are carrier failures handled?

Carrier failures are handled by recovering the identifier from other sources, restoring the carrier without creating a duplicate record, and recording the failure, the recovery and the remedy with dates. A damaged carrier does not erase the passport, and a new carrier that resolves to a new record creates a duplication problem. The remedy should preserve the existing identifier, restore the carrier to resolve to the existing record, and test the restored carrier by scanning. Where the identifier cannot be recovered from the battery or the documents, the failure should be escalated to the record holder, with the battery held from making available until identity is resolved. The failure file should be kept with the battery file, linked by identifier once identity is restored.

How is the whole chain tested?

The whole chain is tested by a pilot that follows one battery from identifier creation, through carrier application, through record creation, through handover, to a scan by a reader who did not create the record, with each link checked and recorded. The pilot should include a tier access check, a carrier scan in the installed position, and a registry readiness check where the registry arrangements allow it. A pilot that passes every link proves the chain, while a pilot that fails one link shows the link to fix. The pilot should be repeated after any design change, because a change to one link can break another link, and a chain test that is not repeated after a change is an outdated test.

What limits apply to a QR and registry plan?

The limits are that registry arrangements depend on further acts, and this plan states them only as expected. This guide gives general educational information only and is not individual legal advice. An operator with a specific battery should check the Regulation text and the registry guidance as checked on 28 October 2026 before acting.