On 18 February 2027 a transition period ends that many operations have filed under "sometime later". From that date, industrial batteries with a capacity above 2 kWh must have a digital battery passport, reachable via a QR code on the battery. The legal basis is the EU Battery Regulation (EU) 2023/1542, Chapter IX, Articles 77 and 78.

According to the publicly available guidance, three groups are covered: electric vehicle traction batteries, traction batteries for light means of transport — and industrial batteries above 2 kWh, which explicitly include stationary storage.

Why this belongs on the table now

Procurement cycles run longer than four months. Anyone building a fleet today will still be operating it after the deadline. And the deadline applies at the point of placing on the market, not only to brand-new models.

There is a second point that is often missed. The general labelling obligations have applied since 18 August 2026, and CE marking since 18 August 2024. The battery passport is therefore not a single date but the last link in a chain that is already running.

Responsibility sits with the name on the housing

This is the sentence that settles most procurement conversations: legal responsibility lies entirely with the economic operator whose brand appears on the product — regardless of whether third-party software is used for the passport.

If you buy under your own brand, the obligation is yours. If you buy under the manufacturer's brand, you still have to check — see below. The content must be complete, correct and current; software alone is not evidence.

What dealers and rental companies must check

The IHK guidance lists three checks for dealers (Articles 42 and 62):

  • Is the manufacturer registered in the Stiftung EAR producer register?
  • Are the batteries correctly labelled — manufacturer or importer details, CE mark, the further required symbols?
  • Are all required documents and safety information enclosed?

If these three are not checked at delivery, they will not be checked later — by then the unit is already with the customer.

Four questions for the supplier

1. Does this model have a battery passport, and does the QR code on the housing actually resolve there? What counts is the code on the product, not the existence of a software platform.

2. Who is the economic operator for this product — manufacturer, importer, or us as the brand owner?

3. Is the manufacturer registered in the EAR register, and can we see the registration number?

4. Which documents ship with the unit — declaration of conformity, safety information, data on performance and durability?

What happens if it is missing

National authorities monitor compliance through document checks, audits and spot checks. Violations can lead to warnings, fines and sales bans. For a rental business that means, in the worst case, the unit sits in the depot and may no longer be placed on the market.

What this article does not say

This text describes the obligations as set out in publicly available sources. It is not a statement about the conformity or certification status of any specific product — including our own. If you need a reliable answer for your fleet, ask your supplier the four questions above and get the answer in writing.

Sources: IHK guide to the EU Battery Regulation and the digital battery passport · TÜV SÜD: EU Battery Passport · Regulation (EU) 2023/1542 (EUR-Lex)

*Dates and obligations are taken from the public guidance linked above (as of 19 October 2026). Only the text of the regulation is legally binding.*