Data check date: 6 July 2026. This article is based on Regulation (EU) 2023/1542 concerning batteries and waste batteries. It does not promise registration, certification, platform review, customs clearance or commercial outcomes.
Correct the scope first
18 February 2027 is an important date for the EU battery passport, but it should not be simplified into “every battery-powered product needs a digital passport or cannot enter the EU.”
Article 77 of Regulation (EU) 2023/1542 requires, from 18 February 2027, a battery passport for each LMT battery, each industrial battery with a capacity greater than 2 kWh, and each electric vehicle battery placed on the market or put into service. Ordinary portable batteries in many consumer electronics may have labeling, QR code, performance, safety and supply-chain obligations, but they should not automatically be treated as Article 77 battery-passport products.
Classify the battery before preparing fields
| Battery type | Preparation focus |
|---|---|
| LMT battery | Light means of transport batteries, such as batteries for e-bikes or e-scooters, should be checked for battery-passport fields and data-carrier preparation. |
| Industrial battery > 2 kWh | Energy storage and industrial equipment batteries should prepare model, capacity, chemistry, manufacturer, carbon-footprint and supply-chain fields. |
| Electric vehicle battery | Review battery passport, carbon footprint, performance and durability, recycled-content and due-diligence evidence. |
| Portable battery | Do not automatically apply the passport conclusion. Check labeling, QR code, substance restrictions, removability and recycling responsibilities separately. |
Prepare data fields before the system question arrives
A practical battery data table should include battery category, model, batch, manufacturer, capacity, chemistry, product link, importer or economic operator, carbon-footprint documents, recycled-content information, due-diligence files, test reports, labels and data-carrier status.
For finished-product sellers, the key is to map each SKU to the actual battery model. A product name alone is not enough if the seller cannot identify the battery supplier, specification sheet, test file and responsible operator.
Three actions to take first
Cross-border sellers should review EU-listed battery-powered SKUs and separate LMT, electric-vehicle and industrial batteries above 2 kWh from ordinary portable-battery products.
Factories and battery suppliers should organize specifications, test reports, batch records, labeling information, carbon-footprint files and supply-chain due-diligence evidence.
Brand and compliance teams should manage Battery Regulation, ESPR/DPP, WEEE, RoHS, REACH and transport-safety requirements separately, then connect them through one SKU-to-evidence table.
How Greenark can support
Greenark (Shenzhen) Certification Co., Ltd. can support EU battery passport scope checks, battery data-field lists, supply-chain evidence organization and customer questionnaire pre-checks.
Greenark (Shenzhen) Certification Co., Ltd. provides preparation, organization and consulting support. It does not replace final decisions by regulators, platforms, customs authorities or certification bodies, and does not promise registration, certification, platform approval or commercial results.
