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Registering battery passports in the EU registry

Who registers, what you need, what the registry stores and when it becomes possible.

As of October 2026

Besides the passport itself, the Batteries Regulation requires a registration: the economic operator placing the battery on the market uploads its unique identifier to the EU registry for Digital Product Passports (Art. 77(10)). The registry is based on Art. 13 of the Ecodesign Regulation (EU) 2024/1781, and the details are set by Implementing Regulation (EU) 2026/1778. It has been online since 20 Jul 2026.

What the registry stores and what it does not

  • It stores the battery's identifier as the HTTPS address of the passport, optionally the model and batch identifier, plus the registrant, a timestamp and a checksum (hash) of the passport version.
  • In return you receive a unique registration identifier.
  • The passport itself stays with the economic operator or its service provider (Art. 78(c)). The registry expressly does not store it.
  • Later changes such as state of health or charging cycles are not reported to the registry.
  • For batteries, according to the Commission, the registration identifier does not go into the customs declaration.

Who may register

Registration must be done by the economic operator placing the battery on the EU market. Creating and maintaining the passport can be delegated to third parties in writing (Art. 77(4)). For registration, the Commission draws an explicit distinction: it names the operator placing the battery on the market. The implementing regulation only lets third parties register where Union law provides for it and they are verified themselves. Whether this applies to batteries was not settled as of October 2026. Manufacturers outside the EU can get verified, but the battery is registered by the operator placing it on the EU market.

What you need

  1. An EU Login for your company.
  2. Verification of your organisation in the registry: you enrol, the Commission issues a sealed PDF declaration, you sign it with a qualified electronic seal and upload it. Natural persons use a qualified electronic signature or an eID instead.
  3. An identifier for your company: trade register number (preferred), LEI, VAT number or eID. The EORI number is not used for this.
  4. You get the seal from a qualified trust service provider. It costs money; the registration itself is free.

The verification is valid for at most three years and must then be renewed.

How registration works

  • Individually in the online form or by file upload in JSON or XML format following the Commission's template.
  • At most 100 passports per file. A single error rejects the whole file.
  • The registry retrieves the passport address once automatically and checks the content against its data catalogue. The address must be reachable via HTTPS and must not go through redirect chains.
  • Processing runs in the background. You see the result in your account.
  • As proof you can generate a PDF with a qualified seal. It is available for 90 days.

When it becomes possible

Legally, registration is tied to the passport obligation from 18 Feb 2027. There is no separate deadline or transitional rule. The Commission states that a product must be registered before it is placed on the market. As of October 2026, however, battery passports cannot yet be registered because the data catalogue for batteries is missing. The Commission has not given a date for it. Verifying your company, on the other hand, is already possible today. Do it early, so that once the catalogue is released you only need to upload.

What we do and what you do

  • We create the upload file, check it in advance, including whether every passport address is reachable, and split it into batches of at most 100 passports.
  • We enter the returned registration identifier in your passport.
  • You set up EU Login and verification, obtain the seal and upload the file under your own account.
  • You keep the registration data up to date if the address, model identifier or registrant changes.

After repurposing or remanufacturing, the new operator placing the battery on the market registers the new passport with its own verification.

Do you need a battery passport? Two or three questions and you know.

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Sources

This article summarises the legal situation in plain language and is not legal advice. The text of the regulation is authoritative.