An industrial battery passport entry is required from 18 February 2027 for each industrial battery with a capacity greater than 2 kWh placed on the market or put into service. The entry is an electronic record for one individual battery, reached through a data carrier on the battery. Industrial batteries cover a wide range of settings, from factory equipment to stationary energy storage, and the record must make the setting visible. The worked outline below is illustrative in form only. Placeholder entries mark positions in a record, not values from a real battery or a real installation.
Why does the 2 kWh threshold decide the record?
The threshold in Article 77 is a capacity test, not a size test or a weight test. An industrial battery at or below 2 kWh falls outside the passport duty in Article 77, even when the battery is large, heavy or permanently installed. A battery above 2 kWh falls inside the duty. Capacity must therefore be recorded in a way that allows the threshold test to be repeated: rated capacity, the conditions under which capacity was determined, and the unit of measurement. A record that states a capacity without conditions leaves the threshold question open. A record that rounds capacity across the threshold, or that states capacity only in a marketing summary, creates the same problem. The threshold check is a first check, made before any other field is read, because it decides whether a passport entry is required at all.
How does stationary storage change the entry?
Stationary storage changes the operating context recorded in the entry, not the basic identity structure. A stationary battery energy storage system may be installed as a single battery or as an assembly, and the record must show whether the identifier refers to the battery unit, the system, or both, and how the two relate. Operating conditions for stationary use differ from mobile use: duty cycles, temperature exposure, charge and discharge patterns, and maintenance access all shape the history that accumulates. Safety information and dismantling information gain weight in a stationary setting, because access for inspection, repair and eventual removal is planned around the installation. The entry should record the installation type in neutral terms, without presenting site specific safety assessments that belong in installation documentation rather than in the passport.
Which fields describe the industrial model?
Model fields for an industrial battery include manufacturer identity, model identifier, category, chemistry, rated capacity and voltage, weight, and the EU declaration of conformity reference. For rechargeable industrial batteries, performance and durability values from Annex IV documentation sit alongside the model description, with the test conditions stated. The model layer also carries carbon footprint and recycled content information where those duties apply to the category. A model with exclusively external storage follows a different timetable for carbon footprint duties, and the record must not collapse that distinction. The model layer is shared across units of the same model, and changes to it require a new model version rather than a silent edit to existing unit records.
Which fields belong only to the single unit?
Unit fields include the unique identifier, the serial or unit number, the manufacturing date or batch reference, and the history that follows the battery. For an industrial battery, history includes commissioning information where recorded, operating condition entries, maintenance and repair events, and state of health measurements taken at stated dates. A unit that has been moved between sites accumulates a location history only where the passport system records location changes; absence of a location entry must not be read as proof that the battery never moved. The discipline is the same as for other categories: dated entries, stated sources, and visible gaps. An industrial unit record without dated operating entries is a model record with an identifier attached, not a life record.
What does the worked industrial entry look like in outline?
The table below sets out the shape of the entry. Placeholder text marks positions, not real values.
| Record section | Illustrative entry | Note for the reader |
|---|---|---|
| Threshold check | Rated capacity above 2 kWh, conditions stated | Decides whether Article 77 applies |
| Model identity | Manufacturer, model identifier, industrial category, chemistry | Stable across units of the model |
| Performance | Electrochemical performance and durability values, test conditions | Read with Annex IV documentation |
| Unit identity | Unique identifier, serial number, manufacturing date | Never reused for another battery |
| Operating history | Dated entries for commissioning, maintenance, state of health | Gaps shown as gaps |
| End of life preparation | Dismantling information, safety measures, waste prevention information | Authorised tier where Annex XIII so provides |
How is safety and dismantling information handled?
Safety measures and dismantling information are model level items in Annex XIII point 2, accessible to persons with a legitimate interest and to the Commission. The entry therefore points an authorised reader to dismantling sequences, fastening techniques, tools required, warnings and cell layout, without publishing the full detail in the public tier. For an industrial battery, dismantling detail must reflect the actual pack construction, not a generic diagram for the chemistry family. A reader in the authorised tier checks that the dismantling information matches the model identifier and the revision in front of the reader. Where a pack has been modified, the dismantling information for the original model may no longer describe the battery as it stands, and that mismatch must be visible in the status record rather than hidden by an unchanged model entry.
What limits apply to reading an industrial entry?
An industrial entry describes one battery and one model. It does not describe the performance of an installation, the safety of a site, or the suitability of a battery for a new application. A capacity figure does not prove that a battery will deliver that capacity under different operating conditions. A state of health figure does not prove remaining life without the measurement conditions and the date. A carbon figure does not prove a lower impact than another battery without the same scope and method. This guide gives general educational information only and does not give legal advice for a particular battery, installation or transaction.
Sources & further reading
- Regulation (EU) 2023/1542, consolidated text, Article 77 and Annex XIII ↗
- European Commission, Batteries ↗
- EU Battery Regulation: labelling and QR code requirements ↗
Source links point to primary materials and further reading, including commercial implementation resources where cited. This introductory guide does not replace the legislation.