The battery passport from 2027: what will really change in TSL operations

From 18 February 2027, the digital battery passport will become mandatory for certain batteries placed on the market or put into service in the European Union. The latest European Commission guidance, published on 21 August 2026, organises 71 data points and explains how they apply to different battery categories.

For carriers and logistics operators, one of the most important aspects will be distinguishing between three separate areas: legal responsibility for the passport, access to data during operations and transport safety documentation. Connecting them within a well-designed process can improve traceability. Treating them as one and the same document, however, may lead to incorrect operational decisions.

Which batteries will be covered?

Under Article 77 of Regulation (EU) 2023/1542, from 18 February 2027 a battery passport will be required for every light means of transport battery, every industrial battery with a capacity greater than 2 kWh and every electric vehicle battery when it is placed on the market or put into service.

The passport relates to an individual battery and is linked to its unique identifier. It will be accessible via a QR code, while the scope of information available will depend on the type of data and the user's access rights. Some information will be publicly available, some will be accessible to specific parties with a legitimate interest, and some will be restricted to authorities and bodies specified in the regulation.

Who is responsible and who provides the data?

As a general rule, the economic operator placing the battery on the market is responsible for ensuring that the information in the passport is accurate, complete and up to date. The regulation also provides specific rules for transferring this responsibility, including after a battery has been prepared for reuse, repurposed or remanufactured, as well as when it becomes waste.

This does not mean that all the data originates in one place. In practice, the information needed for the passport may come from different stages of the value chain, including manufacturers, importers, battery service providers, users, businesses involved in reuse and recyclers.

A TSL operator may therefore not be responsible for maintaining the passport, but depending on its role, it may become part of the data flow. For example, it may scan the identifier upon receipt, link a specific battery to a warehouse or transport operation and use the available data in subsequent stages of the process.

Which data matter to logistics?

The European Commission stresses that its current guidance does not create new legal requirements. Instead, it organises 71 data points together with their legal basis and scope of applicability.

For TSL operators, particularly useful information may include identification data, model and manufacturer information, composition, capacity, carbon footprint, parameters relating to state of health and expected lifetime, as well as information relevant to repair, reuse and recycling.

Not every employee or system should have access to the full set of information. Article 78 provides for access based on permissions, requirements concerning data integrity, a high level of security and privacy, and protection against fraud.

An integration project should therefore begin by defining roles and actual operational needs rather than copying the full set of passport data into a TMS or WMS.

The battery passport does not replace ADR

This is one of the most important operational distinctions.

The battery passport is a digital source of information about the product and its lifecycle. ADR, on the other hand, governs the international carriage of dangerous goods by road and sets out requirements covering, among other things, classification, packaging, marking, documentation, training and the responsibilities of participants in the transport chain.

Scanning a QR code therefore does not release the consignor, carrier or consignee from their obligations under ADR.

The requirements applicable to a particular shipment depend on factors including the battery's classification, configuration, condition, quantity and packaging. A damaged, defective or waste battery may require different handling from a new battery of the same model.

The passport can help correctly identify a specific battery and provide useful information, but transport decisions must still be based on the current ADR requirements and information relating to the specific shipment.

How to prepare for February 2027

The first step is to establish whether the company handles batteries covered by the regulation and in what role - for example, as a carrier, warehouse operator, importer, distributor, service provider or returns operator.

The next step is to identify where the battery identifier may be used within existing processes and determine which data will actually be needed for operational purposes.

It will also be important to establish who should have access to particular information and how passport data will function alongside transport and ADR documentation.

For companies handling larger volumes of batteries, it may be useful to test the process on a limited number of operations before the requirements take effect. This can help identify potential issues involving battery identification, access to data or discrepancies between passport information and shipment documentation.

The main takeaway

The battery passport can connect information that is currently scattered across manufacturers, logistics providers, users and recyclers.

For TSL, one of its greatest benefits may be the ability to reliably link an event to a specific battery. This will require a clear separation between product data and ADR documentation, as well as access appropriate to the user's role.

Companies that organise their processes and approach to using battery passport data before 18 February 2027 will be better prepared for the new requirements.