Second life: a new passport after repurposing

Many batteries still have enough capacity after their first use for a second life, for example a vehicle battery as home storage. The Batteries Regulation sets out when such a battery needs a new passport and who is then responsible for it (Art. 77(7)).

The terms

• Preparation for re-use: checking, cleaning or repairing a waste battery so that it can be used again without any other pre-processing (Art. 3(1), point 29, referring to the Waste Framework Directive).
• Preparation for repurposing: a waste battery or parts of it are prepared for a purpose other than the original one (point 30).
• Repurposing: a battery that is not waste, or parts of it, are used for a purpose other than the original one (point 31).
• Remanufacturing: all cells and modules are disassembled and evaluated, cells or components are replaced, capacity is restored to at least 90 % of the original rated capacity, the state of health of the cells differs by no more than 3 %, and the battery serves the same purpose as before (point 32).

When a new passport is needed

After any of these four operations, the battery needs a new passport linked to the passport of the original battery. If one battery is made from several old ones, the new passport is linked to all original passports (Art. 77(7)). The old passport does not disappear; it gets a new status.

According to the Commission, a simple repair where the battery keeps its purpose and none of the four operations applies does not require a new passport. The same goes for simply reselling a used battery.

The category can change: an electric vehicle battery that serves as stationary storage after repurposing is then an industrial battery (Art. 3(1), point 13).

Who is responsible

• Whoever prepares a battery for re-use or repurposing, repurposes or remanufactures it and then places it on the market or puts it into service is considered a manufacturer (Art. 38(11)). They bear all manufacturer obligations, from conformity assessment to CE marking.
• Responsibility for the new passport passes to this economic operator (Art. 77(7)).
• If the battery becomes a waste battery, responsibility passes to the producer, the appointed producer responsibility organisation or the waste management operator (Art. 77(7), second subparagraph).
• The new operator placing the battery on the market registers the new passport in the EU registry with its own verification.

The status values in the passport

Every passport shows the status of the battery (Annex XIII, point 4(c)). This information is mandatory for all passport categories from February 2027:

• Original: the battery in its first life
• Re-used: after preparation for re-use, in the same purpose
• Repurposed: in a purpose other than originally intended
• Remanufactured: after remanufacturing, in the same purpose
• Waste: the battery is waste

Batteries that have undergone one of these operations also get a new label, and their change of status must be accessible through the QR code (Art. 13(9)).

Evidence for waste batteries

If the battery had already become waste, the holder must show the authority on request that it no longer is (Art. 73(1)):

• an evaluation or test of the state of health, carried out in a Member State
• an invoice or contract for the further use
• appropriate protection against damage during transport, loading and unloading

The state of health information is also made available to end-users (Art. 73(2)). The battery management system data (Art. 14) help here, as do the dismantling details from the original passport, which second-life operators can access as persons with a legitimate interest (Art. 77(2)).

End of the passport

The passport only ceases to exist once the battery has been recycled (Art. 77(8)). Until then, every stage remains traceable. In Batterypass Online, after repurposing or remanufacturing you create the new passport directly from the old one, also for a pack made from several waste batteries. The predecessor is withdrawn but remains verifiable.