EU Batteries Regulation 2023/1542 · Article 77

Every battery you sell needs its own passport. Not every product — every battery.

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.

days until 18 February 2027

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What the regulation actually says

One record per battery

“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)

The duty is yours

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)

Most of the data isn’t yours

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), 3

Passports outlive the business

The 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)

Does this apply to what you sell?

The threshold catches less than most compliance blogs claim, and more than most merchants expect.

What you sellPassport from 18 Feb 2027Why
E-bike / e-scooter batteryYesLMT battery — sealed, ≤25 kg, traction for a wheeled vehicle. No capacity threshold, so every pack counts.
Home storage above 2 kWhYesIndustrial battery over the 2 kWh threshold.
Portable power stationOnly above 2 kWhMust be over 5 kg and over 2 kWh. A 1 kWh unit is out.
Power bankNoPortable battery, 5 kg or less — outside passport scope entirely.
What you will not hear from us: that you need carbon-footprint or recycled-content declarations for e-bike batteries by 2027. You don’t. For LMT batteries those obligations start on 18 August 2028 and 18 August 2033 respectively, and battery due diligence does not apply at all below €40m turnover. Anyone selling you a 2027 deadline for those is guessing. Art. 7(1), Art. 8(1), Art. 47

Why the €10 “passport” apps don’t solve this

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 appsThis
Record granularityOne page per SKUOne record per physical pack, with its own identifier
Identifier standardStore URLISO/IEC 15459 unique identifier, per Art. 77(3)
Supplier evidenceYou retype a datasheetRequested, versioned, timestamped, expiry-tracked
Access tiersPublic page onlyPublic / legitimate-interest / authorities, per Annex XIII
Survives your businessPage dies with the subscriptionPassport 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.

What you’d actually get

Serial registry

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.

Supplier evidence workflow

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.

The public page

Free to consumers, as required. Shows only the Annex XIII point 1 fields. Restricted tiers gated behind access control.

Export and continuity

Full export in open, machine-readable formats at any time. A written continuity arrangement so passports remain reachable if you stop trading.

The honest boundary. Annex XIII point 4 requires per-unit state of health, cycle counts and operating conditions. That data comes from the battery management system, not from a Shopify app. We hold the model-level and evidence-custody layer and give your supplier a defined way to deliver telemetry fields. We will not pretend to produce data we cannot see.

Pricing

Monthly, billed through Shopify. Early-access pricing is held for 12 months from launch.

Starter
$299
per month
  • Up to 2,000 passports a year
  • One battery model family
  • Supplier evidence requests
  • Public QR page
  • Docs and issue tracker support
Growth
$799
per month
  • Up to 15,000 passports a year
  • Unlimited battery models
  • Evidence expiry tracking and chase
  • Restricted-tier access control
  • Bulk serial import
Scale
$1,499
per month
  • Unlimited passports
  • Repurposing and status transfer
  • Continuity escrow arrangement
  • API access and full export
  • Market-surveillance response pack

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.

Early access

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.

This is the question that decides whether the product is buildable. A straight “no” is genuinely useful to us.