EU battery passport 2027 checklist for economic operators

Why this checklist exists

Regulation (EU) 2023/1542 requires a digital battery passport for relevant batteries placed on the EU market. The operational passport date widely used in industry planning is 18 February 2027. This checklist is for economic operators who need a shared worklist across engineering, supply chain, and compliance before that date.

It covers industrial batteries above 2 kWh, EV traction batteries, and LMT batteries. It does not replace product-specific legal advice.

1. Confirm which batteries are in scope

• Inventory every model you place or intend to place on the EU market by category
• Record nominal energy, chemistry family, and intended application
• Flag repower and second-life derivatives that create a new placing-on-market event
• Name the legal entity that will appear as economic operator on the passport

2. Build the Annex XIII field map

Map each model to the public and restricted field set. Operators typically work with on the order of 90 fields per model once identification, composition, carbon, performance, supply chain, and circularity blocks are included.

• Assign an owner for every field block (engineering, PEF, purchasing, legal)
• Separate public disclosure fields from restricted access fields
• Record which values are already attested versus still draft

3. Collect evidence before you chase polish

• Cell and module datasheets under document control
• Supplier declarations for cobalt, lithium, nickel, and natural graphite where required
• Carbon footprint study inputs aligned to your PEF path
• Performance and durability test reports with clear model linkage
• Retention rules so the audit trail survives staff turnover

4. Configure identifiers and the Digital Link

5. Run publication gates, not informal sign-off

• Critical fields approved against evidence, not chat messages
• Carbon and PEF blockers cleared or formally escalated
• Multi-stage approval complete where your governance requires it
• Publish creates a versioned record with actor and timestamp
• Audit export pack archived for customs and market surveillance requests

6. Keep Article 48 on a parallel track

Passport publication and due diligence are related but not the same workstream. Due diligence obligations under Article 48 (as amended) have a later industry planning date of 18 August 2027. Start the management system and risk register now so supplier evidence collected for passports also serves DD.

90-day operating rhythm

1. Week 1 to 2: scope inventory and economic operator identity
2. Week 3 to 6: field map and evidence gap list per model
3. Week 7 to 10: supplier requests and PEF path confirmed
4. Week 11 to 12: dry-run publish on one industrial model; fix gate failures

If you need a structured gap view before committing a programme, use the readiness assessment.