From 18 February 2027, each e-bike, e-scooter and home-storage battery placed on the EU market must carry an electronic record reachable from a QR code on the pack. One record per physical unit, with its own unique identifier.
“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.”
Regulation (EU) 2023/1542, Art. 77(1)If you have packs made to your design and sell them under your own name, you are the manufacturer. You must ensure the passport data is “accurate, complete and up to date”. You can authorise someone to act for you — you cannot hand off the responsibility.
Art. 3(1)(33), Art. 77(4)Chemistry, detailed composition of cathode, anode and electrolyte, exploded dismantling diagrams, cell layout, safety measures, test reports. All of it lives in your battery supplier’s engineering department, not in your product catalogue.
Annex XIII, points 1(b), 2(a)–(d), 3The record must stay reachable “after the economic operator … ceases to exist or ceases its activity in the Union”, must be free to consumers, and must be exportable in open formats without vendor lock-in.
Art. 78(e), Art. 78(b), Art. 77(5)The threshold catches less than most compliance blogs claim, and more than most merchants expect.
| What you sell | Passport from 18 Feb 2027 | Why |
|---|---|---|
| E-bike / e-scooter battery | Yes | LMT battery — sealed, ≤25 kg, traction for a wheeled vehicle. No capacity threshold, so every pack counts. |
| Home storage above 2 kWh | Yes | Industrial battery over the 2 kWh threshold. |
| Portable power station | Only above 2 kWh | Must be over 5 kg and over 2 kWh. A 1 kWh unit is out. |
| Power bank | No | Portable battery, 5 kg or less — outside passport scope entirely. |
There are already several digital-product-passport apps on the Shopify App Store. Every one of them generates a page per product, built from your product metafields, with a QR pointing at it.
| Per-product QR page apps | This | |
|---|---|---|
| Record granularity | One page per SKU | One record per physical pack, with its own identifier |
| Identifier standard | Store URL | ISO/IEC 15459 unique identifier, per Art. 77(3) |
| Supplier evidence | You retype a datasheet | Requested, versioned, timestamped, expiry-tracked |
| Access tiers | Public page only | Public / legitimate-interest / authorities, per Annex XIII |
| Survives your business | Page dies with the subscription | Passport archive with continuity commitment |
If you ship 4,000 packs a year, the regulation expects 4,000 records. A page per SKU is not a battery passport, whatever the listing says.
A record per pack, created when you receive stock, keyed to a unique identifier and the QR you print. Bulk import from your existing serial list.
A structured request to your battery supplier for exactly the Annex XIII fields, with a chase schedule, version history, and warnings when a declaration goes stale.
Free to consumers, as required. Shows only the Annex XIII point 1 fields. Restricted tiers gated behind access control.
Full export in open, machine-readable formats at any time. A written continuity arrangement so passports remain reachable if you stop trading.
Monthly, billed through Shopify. Early-access pricing is held for 12 months from launch.
Support is documentation and an issue tracker. We do not contact your suppliers on your behalf — the regulation puts that relationship with you, and a tool that pretends otherwise would be selling you a service it cannot deliver at this price.
We are talking to a small number of EU-selling brands before building. If the shape is right for you, say so — and tell us the one thing that decides whether this is usable: whether your battery supplier will hand over the data.