EU Battery Passport 2027: SKU Data Preparation for LMT, Industrial and Electric-Vehicle Batteries

Start with the scope correction: “The EU Battery Passport will become mandatory for every portable battery in 2027” is not what Article 77 of Regulation (EU) 2023/1542 says. From 18 February 2027, an electronic battery passport is required for each light means of transport (LMT) battery, industrial battery with a capacity greater than 2 kWh, and electric-vehicle battery placed on the EU market or put into service. A portable battery does not enter Article 77 merely because it reaches a universal “10 Wh threshold”. Portable batteries can still be subject to QR, labelling, removability, producer-responsibility and product-specific requirements, but those duties must be assessed separately.

This reference is for cross-border sellers, manufacturers, importers, EU economic operators, supply-chain teams and data owners selling products containing batteries. Its purpose is to connect the finished product, battery model, production information, responsible economic operator, technical file and QR entry point into an auditable evidence trail. It was prepared by Greenark Certification (Shenzhen) Co., Ltd. for internal preparation; it is not a legal opinion and does not promise a platform, customs or certification outcome.

1. Classify the battery before deciding whether Article 77 applies

Article 77 uses battery categories rather than an Amazon ASIN count or a universal watt-hour trigger. Start with one row for each finished SKU and link it to the battery model, intended use and placing-on-the-market scenario.

Category	Article 77 boundary	Evidence to collect first
LMT battery	From 18 February 2027, an electronic record is required for an LMT battery placed on the market or put into service. Confirm the legal definition and any product-specific boundary.	Vehicle or equipment use, rated parameters, battery model, manufacturer, placing entity and applicable date.
Industrial battery	Article 77 lists industrial batteries with a capacity greater than 2 kWh. Do not treat every storage product or every battery sold for business use as the same legal category.	Use classification, rated capacity, external-storage status, model, manufacturing site and technical file.
Electric-vehicle battery	Expressly listed in Article 77. The vehicle, battery and economic-operator records must describe the same configuration.	Battery model, vehicle/system link, manufacturer and economic operator, technical file and performance data.
Ordinary portable battery	Do not claim Article 77 coverage merely from “≥10 Wh”. Article 13(6) separately provides that all batteries carry a QR code from 18 February 2027; for other batteries, the QR leads to applicable labelling, declaration-of-conformity, waste-management and related information.	Battery category, capacity label, incorporation in a product, instructions, QR location and applicable product, chemical and transport rules.

A battery built into a vacuum cleaner, tool or appliance is not automatically outside compliance work. Incorporation affects product responsibility, labelling, instructions, removability and technical documentation. It does not automatically turn an ordinary portable battery into an LMT, industrial or electric-vehicle battery listed in Article 77. Record the product category, battery category and placing scenario separately.

2. What the Battery Passport is expected to contain

Article 77 requires information about the battery model and information relating to the individual battery, including information resulting from its use. The regulation separates public information, information for notified bodies, market-surveillance authorities and the Commission, and information available to persons with a legitimate interest. A public web page should not expose every BOM, test result or commercially sensitive field.

• Identity: battery model, unique identifier, manufacturer and relevant economic operators, linked back to the actual product or battery model.
• Technical data: category, rated parameters, chemistry, performance and durability data where the battery category and applicable provision require them.
• Lifecycle data: information needed for repair, reuse, repurposing, remanufacturing and recycling, with status or use data where applicable.
• Access control: roles for reading, updating, downloading or sharing data, with a record of permissions and version changes.

Article 77 also requires the information to be accurate, complete and up to date, using open standards and an interoperable, machine-readable, structured and searchable format. The passport is linked to a unique identifier through the QR code in Article 13(6). Article 77 does not create a universal “first 15 official providers” list, nor does it make one commercial platform, blockchain or seller-backend workflow mandatory for every company. Select technical providers against the applicable rules, access rights, security controls and contractual accountability.

3. Build a SKU evidence matrix linking product, pack and battery model

For cross-border teams, the common failure is not the absence of a polished page. It is inconsistent battery information across the BOM, label, manual, technical file and online offer. A practical internal matrix can use one row per finished SKU or ASIN. That matrix is a control tool, not a legally prescribed “six-layer system”.

Matrix field	Manual review question	Evidence examples
Finished product identity	Do brand, model, variant, SKU/ASIN and physical label describe the same product?	Model rules, photographs, BOM version, packaging and listing snapshot.
Battery identity	Do cell/pack model, series-parallel configuration, voltage, capacity and energy come from one controlled version?	Datasheet, BOM, nameplate, test report and production-batch record.
Responsible operator	Are manufacturer, importer, authorised representative and other economic-operator roles distinguished?	Contracts, EU Declaration of Conformity, EU address and appointment documents.
Regulatory file	Have battery, radio/EMC, transport, chemical and product-specific obligations been kept distinct?	Applicability note, technical-file index, test reports, declarations and revision log.
Passport entry	Does the QR link to the correct battery/model, remain reachable, and expose only the appropriate version and access level?	QR sample, unique identifier, access log, version record and change approval.

Change control: a cell substitution, BMS change, rated-parameter change, packaging or manual revision, operator change or QR migration should trigger an impact assessment. Record before/after values, affected SKUs, owner, approval date and files that must be synchronized. The regulation does not set one general “14-day synchronization across six systems” deadline, so do not present an internal SOP as a statutory deadline.

4. Keep QR, labelling, carbon footprint and removability separate

The original article combined several dates into a four-stage “passport rollout” and applied industrial/electric-vehicle battery requirements to ordinary portable batteries. A safer implementation calendar is clause-based:

1. QR code: Article 13(6) requires a QR code on all batteries from 18 February 2027. For LMT, industrial batteries above 2 kWh and electric-vehicle batteries, the QR provides access to the Battery Passport. For other batteries, it provides applicable Article 13 information, the declaration of conformity, the relevant report and waste-battery information.
2. Labelling: capacity, general battery information, separate-collection symbols and heavy-metal symbols have their own provisions and application conditions. Where the battery’s size or nature makes marking impracticable, the regulation allows the label or QR to be placed on packaging and accompanying documents. Do not turn “cell, pack, carton and manual” into a universal four-location rule.
3. Carbon footprint: Article 7 focuses on electric-vehicle batteries, rechargeable industrial batteries above 2 kWh and LMT batteries. Do not apply the original article’s PCF, A/B/C/D or corporate Scope 1+2 rules to every portable battery; check the category, provision and relevant delegated or implementing act.
4. Recycled content: Article 8 addresses industrial, electric-vehicle, LMT and SLI batteries and phases in information and targets for recovered materials. Fixed cobalt, lithium and nickel percentages should not be presented as a universal 2026 threshold for every battery.
5. Removability: Article 11 sets requirements for products incorporating portable or LMT batteries, including instructions and spare-parts considerations, with product-specific exceptions. It is a separate question from the Battery Passport and must be reviewed with the applicable derogations.

5. A practical preparation sequence for cross-border teams

Order	Action	Completion evidence
1	Inventory EU sales SKUs and identify batteries that are built in, supplied with or sold separately. Record category, use and key parameters.	SKU-to-battery list with boundary cases assigned for review.
2	Assess whether the battery is an LMT, industrial >2 kWh or electric-vehicle battery under Article 77. Do not use “≥10 Wh” as a substitute for classification.	Applicability card with clause reference and accountable reviewer.
3	Request traceable model, BOM, parameter, manufacturing-site, technical-file and change information from suppliers, while separating manufacturer and economic-operator roles.	Supplier dossier, version number, gap list and follow-up record.
4	Define model-level and individual-battery data layers and access roles for the passport information that applies.	Data dictionary, field sources, access roles and retention rules.
5	Design the physical, packaging, document and digital QR entry points. Manually sample model, version, language and permission alignment.	Samples, scan records, page-field review and closed exceptions.
6	Create a change and end-of-life process. For cell changes, redesign, reuse, remanufacturing, recycling or operator changes, assign who updates which data.	Change ticket, approvals, archived version and linked new/old passport record.

6. Manual review checklist and claim boundaries

• Do the title, H1 and summary state 18 February 2027 and the three Article 77 categories without claiming universal portable-battery coverage?
• Can each SKU be traced to a battery model, rated parameters, manufacturer/economic operator, technical file and QR entry?
• Does the QR distinguish the Battery Passport from Article 13 information for other batteries, with version and access evidence?
• Have carbon footprint, recycled content, removability, CE/transport/chemical and EPR questions been assessed separately rather than replaced by one “certificate”?
• Have unsupported pilot statistics, official-provider lists, automatic platform actions, detention/removal/fine amounts and pass-rate claims been removed?