Who Is Responsible for the EU Battery Passport? The Commission's FAQ, Case by Case

From 18 February 2027, electric vehicle batteries, LMT batteries (e-bikes, e-scooters) and industrial batteries above 2 kWh placed on the EU market need a battery passport under Article 77 of Regulation (EU) 2023/1542. The date is fixed. For many companies the harder question is a different one: whose job is it?

A battery passes through several hands before it reaches the market. Cells are often made outside the EU, modules and packs are assembled somewhere else, a battery management system (BMS) is added, and the finished battery may end up inside a vehicle, a machine or a storage cabinet. The European Commission's EU Digital Product Passport FAQ for Batteries (1st edition, September 2026) answers this case by case. The short version: the passport sits with whoever completes the battery and places it on the EU market.

The FAQ is guidance, not a legally binding act, and it says it reflects the views of its authors. It is still the clearest reading the Commission has published, and it is the document your customers and market surveillance authorities will look at first.

Who is responsible for the EU battery passport?

The responsible party is the economic operator that places the finished battery on the EU market. That operator registers the passport in the EU Digital Product Passport Registry. A manufacturer based outside the EU cannot shift this: according to the FAQ, registration has to be done by the operator that places the battery on the EU market. A non-EU company can open an account and register only after its own verification.

What counts as "finished" decides most cases. For a traction battery, the FAQ says the finished battery would normally include the BMS and any other components needed for safe operation. Battery-Tech Network summed up the logic in its analysis of the FAQ: "The obligation lands where the battery is finished, not where its cells are made."

Five common cases

1. You import cells or modules and assemble the battery in the EU. Separately imported cells and modules are not subject to the passport requirement on their own. The EU entity that completes the battery becomes its manufacturer and carries the passport. The FAQ adds that unfinished packs, modules and components can be imported without a passport for further assembly: the obligation starts when the completed battery is placed on the market. The FAQ notes a limited exception for "do it yourself" kits placed on the market ready for end users.

2. You supply a finished battery to a vehicle maker. If an EU battery manufacturer supplies a finished battery that the vehicle manufacturer only installs, the battery manufacturer is responsible for the passport. If the vehicle manufacturer is the one that completes the battery, the responsibility moves to the vehicle manufacturer.

3. You import a product with a battery already inside. For machinery, vehicles or other products imported with a finished battery installed, the FAQ says the battery is normally placed on the EU market when the product is imported. The importer is responsible.

4. Your system has several packs. If several packs share a common BMS or other common systems, the whole system is one battery and needs one passport. If each pack is a complete, independently working battery, each one is a separate battery. The same logic applies to the 2 kWh threshold for industrial batteries: units that are complete batteries below 2 kWh are assessed one by one, while for an integrated system the combined capacity counts.

5. You repurpose or remanufacture a battery. A repurposed or remanufactured battery needs a new passport, normally under a new economic operator, and the new passport must be linked to the previous one. A battery placed on the market before February 2027 and remanufactured after the rules apply will also need one. We covered this in more detail in our article on second life batteries.

Can a supplier or software provider do it for you?

It can do the work, but the responsibility stays with you. The responsible verified economic operator can give another operator written authorisation to create and update the passport on its behalf, and the same applies to dynamic data such as state of health. Authorising a non-EU manufacturer to create or update the passport does not make it the EU manufacturer or importer. In every case the operator placing the battery on the market stays legally responsible.

So the supplier contract matters. If your cell or module supplier holds the data you need, the contract should say which data they provide, in what format and by when. We explained how to structure that request in our guide to battery passport supplier data.

What to do before 18 February 2027

Map your role for each battery model. Use the five cases above: are you the company that completes the battery, the importer of a product with a battery inside, or a supplier of components?
Check the BMS question. For traction batteries, find out who fits the BMS. That usually answers who completes the battery.
List the data you need from suppliers. Cell chemistry, materials and manufacturing data often sit with the cell or module maker. Ask for them now and put the obligation in the contract.
Decide who does the work. You can run the passport yourself or authorise another operator in writing. Either way, keep the authorisation and the data responsibilities on file.
Get verified in the Registry. Operator verification in the EU DPP Registry lasts up to three years. Registering battery passports in the Registry is not yet available, but verification and data collection do not need to wait.

Digital product passport software for SMEs

For a company that assembles packs from imported cells, the passport is now its own task, often for the first time. Hoken Pass is digital product passport software for SMEs, self service, with a battery template. Every published passport gets a qualified eIDAS timestamp from InfoCert, a qualified trust service provider, and the public page exports EU Registry batch files in JSON and XML. The free plan covers 3 passports. More on the battery use case on our battery passport page.

Frequently asked questions

Who is responsible for the EU battery passport?

The economic operator that places the finished battery on the EU market. In most cases that is the company that completes the battery, for a traction battery usually where the BMS is fitted. For a product imported with a battery already installed, it is the importer.

Do imported battery cells need a battery passport?

Not on their own. According to the Commission's battery FAQ, separately imported cells and modules are not subject to the passport requirement. The EU company that completes the battery becomes its manufacturer and is responsible for the passport.

Can a non-EU manufacturer register the battery passport?

Registration has to be done by the economic operator that places the battery on the EU market. A non-EU manufacturer can create and update the passport if that operator authorises it in writing, but this does not make it the EU manufacturer or importer, and the responsibility does not move.

Does a system with several battery packs need one passport or several?

If the packs share a common BMS or other common systems, the whole system is one battery with one passport. If each pack is a complete, independently functioning battery, each needs its own passport.

Is the Commission's battery FAQ legally binding?

No. It is guidance prepared for the Commission and reflects the views of its authors. The binding text is Regulation (EU) 2023/1542, in particular Article 77.

Sources

Start free with 3 passports: hokenpass.com.