Does Every Battery Need a Battery Passport

Not every battery needs a battery passport, and the answer to the question in the title is no, with the qualification that follows from Article 77. The passport duty applies from 18 February 2027 to each electric vehicle battery, each light means of transport battery and each industrial battery with a capacity greater than 2 kWh placed on the market or put into service. Portable batteries and starting lighting and ignition batteries fall outside that duty, as do industrial batteries at or below 2 kWh, and batteries placed on the market before the duty date. A battery outside the duty may still carry other Regulation duties, including labelling, information and producer responsibility, and may carry a voluntary record, but it does not carry a passport duty under Article 77.

The scope is the Article 77 duty test, as checked on 28 October 2026. The guide states no conclusion about any particular battery, and the test should be applied battery by battery, with category, capacity and placing date recorded.

Which categories need a passport?

The categories that need a passport are electric vehicle batteries, light means of transport batteries and industrial batteries over 2 kWh, as Article 77 states, with no capacity threshold for electric vehicle and light means of transport batteries, and a greater than 2 kWh threshold for industrial batteries. The category test is decided by the Article 3 definitions, based on design purpose, not by marketing label or by purchaser identity. A battery that is designed as a portable battery, even where it is used in an industrial setting, should be classified as portable, and a battery designed for industrial use, even where it is small, should be classified by its design purpose and then tested against the capacity threshold. Category first, capacity second, is the order that prevents a small industrial battery from being treated as a portable battery.

Which categories do not need a passport?

Portable batteries and starting lighting and ignition batteries do not need a passport under Article 77, as the Regulation summaries consistently record, even though those batteries carry labelling, information and other Regulation duties. Portable batteries include sealed, hand carried batteries for everyday and professional uses, and starting lighting and ignition batteries include the batteries used for starting, lighting and ignition in vehicles and machinery, as the definitions describe them in general terms. A reader should check the Article 3 definitions for the precise wording, because the boundary between portable and industrial, and between starting lighting and ignition and electric vehicle, turns on design purpose, and a battery near a boundary needs a recorded classification decision with reasons.

How does the placing date decide the duty?

The placing date decides the duty because Article 77 applies to batteries placed on the market or put into service from 18 February 2027, and a battery placed before that date falls outside the fixed duty, even where it falls in a passport category. The placing date is the date of first making available on the EU market, or of first putting into service, and it should be recorded for each battery, because a file without placing dates cannot answer the duty question. A battery manufactured before the date but placed from the date falls inside the duty, while a battery manufactured after the date but placed before it, where that sequence is possible in a particular supply chain, needs a careful placing analysis. The test is placing, not manufacture, and the file should state the placing evidence.

What does a duty test table look like?

A duty test table shows the category, capacity and date tests in order, with the outcome for each combination. The table below uses general combinations, without deciding any particular battery.

What about batteries in products?

Batteries in products are covered by the Regulation where the battery falls within its scope, whether the battery is sold alone or incorporated in a product, and the passport duty follows the battery category, capacity and placing date, not the product category. A product containing a passport battery needs the battery passport for that battery, and the operator placing the product on the market carries the duties for the battery, as the Regulation provides for products incorporating batteries. A product containing only a portable battery needs no passport for that battery, but still carries the labelling and information duties for the battery. The product reading should therefore start from the battery, not from the product, and should list every battery in the product with its category and placing date.

What about voluntary records for batteries outside the duty?

Voluntary records for batteries outside the duty are lawful and useful, and a manufacturer or holder may create a record that follows the Annex XIII structure for a portable battery, a starting lighting and ignition battery, or an industrial battery at or below 2 kWh, without claiming that the record is required by Article 77. A voluntary record should be labelled as voluntary, with the date and the structure stated, so that a later reader does not mistake it for a required passport or treat its absence in another case as a failure. A voluntary record that is well kept can support resale, repair and recycling, and it can be converted to a required record where the battery later falls within a duty, provided that continuity is preserved and the conversion is recorded.

What limits apply to the duty test?

The limits are that the duty test needs the Regulation definitions and the placing facts for the particular battery. This guide gives general educational information only and is not individual legal advice. A reader with a specific battery should check Article 77 and Article 3 as checked on 28 October 2026 before acting.