Portable worked record: what a record looks like when no battery passport is required

A portable battery is a battery that is sealed, weighs 5 kg or less, is not designed specifically for industrial use, and is neither an EV battery, an LMT battery nor an SLI battery. Portable batteries fall outside the battery passport duty in Article 77 of Regulation (EU) 2023/1542. That boundary is the subject of this guide. A record kept for a portable battery is a voluntary or operational record, not a battery passport, and presenting it as a passport misleads a reader about the legal position.

The outline below shows how such a record can be kept honestly, with the boundary stated at the top.

What decides that a battery is portable?

Category assignment decides the position. The definition in Article 3 turns on weight, sealing, design purpose and exclusion from the other categories. A battery that weighs more than 5 kg, or that is designed specifically for industrial use, is not portable on that test. A battery for an e-bike is LMT, not portable, even when the battery is small and light. A battery for traction in a road vehicle is EV, not portable. The record for a portable battery therefore begins with the category test, stated in full, so that a reader can see why no passport is claimed. Where category is genuinely uncertain, the record should state the uncertainty and the facts relied on, rather than choosing the more convenient category. Category errors at this stage are the most common source of passport errors across all categories.

What information must a portable battery carry instead?

Portable batteries carry labelling and information duties under Article 13, even without a passport. From 18 February 2027, batteries must bear a QR code under Article 13(6), and for batteries other than EV, LMT and industrial batteries above 2 kWh, that QR code gives access to a different information set: label information, the EU declaration of conformity, the due diligence report where applicable, and waste prevention and management information. The portable record should therefore point to the QR code destination and the information set behind it, without calling that destination a passport. Capacity labelling, the separate collection symbol, and chemical symbols where required also belong in the labelling picture. The record keeps labelling facts separate from passport facts, because the two regimes have different dates, different content and different audiences.

How can an operational record still be useful?

An operational record for a portable battery can track model identity, batch or lot identity, manufacturing date, chemistry, capacity, and the supplier chain for the batch. It can also track test results, complaints, returns and recalls where those facts exist. Usefulness comes from discipline: one identifier per batch or unit as appropriate, dated entries, and a stated source for each entry. The record must not borrow passport language for this purpose. Terms such as unique identifier in the Article 77 sense, public tier, authorised tier and Annex XIII point should not be applied to a portable record unless the operator is clear that the terms are being used by analogy for internal tracking. Analogy without a label creates a false impression of legal status. A short boundary note at the top of the record prevents that impression.

What does the portable outline look like?

What mistakes does a portable record commonly make?

One mistake is to copy a passport template and fill it with portable data, producing a document that looks like a passport but has no legal basis. A second mistake is to state a carbon footprint or recycled content figure for a portable battery as if Articles 7 and 8 required it for that category. Those duties apply to EV, LMT and specified industrial batteries, with SLI batteries included for recycled content documentation in defined circumstances, not to portable batteries as a class. A third mistake is to present a batch identifier as a unique battery identifier in the passport sense. Batch identity and unit identity are different levels of granularity, and the record must keep them apart. A fourth mistake is to omit the QR code information set altogether, leaving a reader with a tracking sheet and no route to the information the Regulation does require.

How should the boundary be worded in practice?

The boundary wording should be short, factual and placed before any data. An example in neutral form reads: portable battery, no battery passport required under Article 77, QR code gives access to the Article 13 information set. The wording should name the category, the article and the alternative information route. It should not add marketing language, a sustainability claim or a statement about future law. Where a portable battery is incorporated into a product, the record should also note where the labelling appears, on the battery, on the packaging or in accompanying documentation, following the Article 13 placement rules. This guide gives general educational information only and does not give legal advice for a particular battery, product or sale.