EU Battery Passport for Energy Storage Systems (BESS)

On 27 October 2026, Jinko ESS, the energy storage business of the JinkoSolar group, announced on ESS News that it had taken part in the latest Battery Passport pilots of the Global Battery Alliance (GBA). The company says it used a real 5 MWh storage product and traced information from the system to the cells, the materials and the upstream mineral sources, with third party verification of its ESG data.

That is serious supply chain work. It also raises a practical question for storage makers and integrators: if you join a GBA pilot, have you prepared your EU battery passport? Only in part. The two share a name, but they are different things with different rules.

Two different battery passports

The GBA Battery Passport is a sustainability certification run by an industry alliance. In the 2026 operational trials, manufacturers and their suppliers report against GBA rulebooks on responsible production and sourcing, calculate product carbon footprints with the GBA Greenhouse Gas Rulebook, and are checked by third party verifiers using a GBA handbook. The GBA plans to launch a full certification scheme in 2027. It also warns that no conclusions should be drawn on the sustainability performance of the companies in the trials, because the methods are still drafts.

The EU battery passport is a legal obligation. Article 77(1) of Regulation (EU) 2023/1542 reads: "From 18 February 2027 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 shall have an electronic record ('battery passport')." Its content is fixed by Annex XIII, and the passport is reached through a QR code that links to a unique identifier for each battery (Article 77(3)).

Taking part in a GBA pilot can help you collect sourcing and carbon data. It does not give your batteries the identifier, the QR code or the Annex XIII data the EU passport needs.

Does a battery energy storage system need an EU battery passport?

Yes, if it is above 2 kWh. The regulation defines a stationary battery energy storage system as "an industrial battery with internal storage that is specifically designed to store from and deliver electric energy to the grid or store for and deliver electric energy to end-users, regardless of where and by whom the battery is being used" (Article 3(1), point 15). Industrial batteries above 2 kWh are in the scope of Article 77, so a 5 MWh system is in scope from 18 February 2027, and so is a home storage battery above 2 kWh.

Battery passport data points by category: the 31 are a floor

The European Commission's guidance document Digital Batteries Passport: data points by category (version 3.2, 19 October 2026) lists 71 data points and marks each one per battery category. From February 2027, 45 are mandatory for EV batteries, 48 for LMT batteries and 31 for industrial batteries.

For a storage system, 31 is the starting point. Many points are marked conditional for industrial batteries, and the conditions fit a storage system well:

Data points (guidance v3.2)	What they cover	Condition for industrial batteries
31 points, from 1 (unique identifier) to 67 (status of the battery)	Identity, manufacturer, chemistry, hazardous substances, critical raw materials, voltage, power capability, composition, dismantling, safety, test reports, status	Mandatory for every industrial battery
52 to 56	Capacity fade, power, power fade, internal resistance and its increase	Only for rechargeable batteries
62 to 66	State of health under Article 14	Only for stationary battery energy storage systems with a battery management system
68 to 71	Charge and discharge cycles, negative events such as accidents, operating conditions, state of charge	As soon as the battery starts to be used

So a rechargeable storage system with a BMS that is in use carries at least 14 data points on top of the 31, which brings it to 45 or more. Other points can apply too: round trip efficiency (57 and 58) where applicable, expected lifetime under reference conditions (59 and 60) for rechargeable batteries, and cycle life and efficiency values (31, 32, 36, 37 and 39), which the guidance applies to some industrial batteries.

Not everything is public. Under the same guidance, points 1 to 45 are public, points 46 to 49 and 51 to 71 are for persons with a legitimate interest, and point 50 (test reports) is for notified bodies, market surveillance authorities and the Commission.

Some of the data is already required today

The state of health points do not start from zero in 2027. Article 14(1) has required since 18 August 2024 that up to date data for the parameters that determine state of health and expected lifetime, as set out in Annex VII, is contained in the battery management system of stationary battery energy storage systems, LMT batteries and EV batteries. The passport adds a second step: the battery's own record, reachable through its QR code, where those values are shown to the people who have a right to see them.

For an integrator, this means the BMS is the data source to check first. If its export does not give you state of health, cycles, negative events, temperature and state of charge in a usable form, the passport will be hard to keep up to date. We wrote about the update rules for this data in one passport per battery, and where cell data goes.

What storage integrators can do before 18 February 2027

Confirm the category. A storage system is an industrial battery; if it is above 2 kWh, it needs a passport.
Plan one unique identifier and one QR code per battery, as Article 77(3) requires.
Map your product against the 71 data points of guidance version 3.2. Start from the 31 mandatory ones, then add the conditional ones that apply to your system. Our guide to how many battery passport data points are mandatory walks through the list.
Ask your cell and module suppliers for the model data you cannot produce yourself. See what to ask battery suppliers.
Check what your BMS exports and how often it can be read.
Keep any GBA or other ESG work separate in your plan. It can feed sourcing and carbon data later, but it does not replace the EU passport.

Hoken Pass is digital product passport software for SMEs with a battery template for EV, LMT and industrial batteries. Each published passport gets a public page with a QR code and a qualified eIDAS timestamp from InfoCert, and you can start on the free plan with 3 passports. For the full picture of the battery rules, see our EU battery passport page.

Frequently asked questions

Does a battery energy storage system need an EU battery passport?

Yes, if its capacity is above 2 kWh. A stationary battery energy storage system is an industrial battery under Article 3(1), point 15 of Regulation (EU) 2023/1542, and Article 77(1) requires a passport for each industrial battery above 2 kWh placed on the market or put into service from 18 February 2027.

Is the GBA Battery Passport the same as the EU battery passport?

No. The GBA Battery Passport is an industry sustainability certification with its own rulebooks and third party verification, and its full scheme is planned for 2027. The EU battery passport is a legal requirement under Article 77 of Regulation (EU) 2023/1542, with content set by Annex XIII.

How many data points does the EU battery passport require for an industrial battery?

The Commission's guidance (version 3.2, 19 October 2026) marks 31 of the 71 data points as mandatory for industrial batteries from February 2027. A rechargeable stationary storage system with a battery management system that is in use carries at least 14 more conditional points: capacity and power fade, state of health, cycles, negative events, operating conditions and state of charge.

Does a home storage battery need a battery passport?

If it is an industrial battery with a capacity above 2 kWh, yes. The definition of a stationary battery energy storage system applies regardless of where and by whom the battery is used.

Is state of health data public in the battery passport?

No. Under guidance version 3.2, the data points about the individual battery, including state of health, are for persons with a legitimate interest. Data points 1 to 45 are public.

Sources

Start free with 3 passports: hokenpass.com.