A battery passport must stay up to date after the sale

European Union (EU) battery law requires a battery passport to stay correct after the sale. The duty runs for the full life of the battery, and it ends at recycling.

The battery passport is the first digital product passport that EU law makes mandatory. Your EU importer carries the legal duty for that passport. The data in it comes from your factory in New Zealand. So the importer will ask you to report every change you make. A passport that nobody updates becomes wrong at the first change in your factory.

Only three kinds of battery carry this duty

The duty comes from Regulation (EU) 2023/1542, the EU battery regulation. That regulation is in force. Its passport duty starts on 18 February 2027 and covers three categories:

• each light means of transport (LMT) battery, such as an e-bike battery
• each industrial battery with a capacity greater than 2 kilowatt hours
• each electric vehicle battery

Warning: an LMT battery carries no size threshold. A Commission news item of 20 July 2026 uses the phrase "large batteries" for this rule. You can read that phrase as an exemption for an e-bike battery. No such exemption exists.

The Commission web page on digital product passports writes "certain types of batteries, including". An open list reads like an exemption too. Name the three categories instead. See batteries for the scope.

The duty to keep the data up to date never ends

Article 77(4) of the battery regulation reads:

The economic operator placing the battery on the market shall ensure that the information in the battery passport is accurate, complete and up to date. It may give written authorisation to any other operator to act on its behalf.

Read the three words in that sentence. Accurate and complete describe a job that ends. Up to date describes a job that does not end.

The page on manufacturer obligations separates the three words field by field. This page covers what the third word costs you after the sale.

Some passport values change after the sale

A battery passport carries values that describe one battery at one moment. Annex XIII point 4 holds the item-level performance and durability values. Examples are the state of health, the capacity fade, the power fade and the round trip efficiency.

A record that repeats the factory figure for years does not describe the battery that the customer uses. See who can see what for the readers of point 4.

Three ordinary events make a passport wrong

Take an e-bike battery built in Christchurch and sold by an importer in Rotterdam. Each event below is usual manufacturing work, and each one makes a passport field wrong.

• You change the cell supplier. The detailed composition no longer matches.
• You correct a capacity figure after a retest. The published number is wrong.
• A test house issues a corrected certificate. The passport cites the old one.

Every one of those events starts in New Zealand. Every one of them must reach the passport in Europe.

The update must cross a company boundary

The responsible operator holds the battery passport. For a New Zealand exporter with no EU establishment, that operator is the EU importer. Your importer can also pay a passport service provider to hold the record. See what a service provider does.

OwlQR, a New Zealand company that publishes this site, builds this type of service. Put the three questions on that page to any provider before you sign.

Your specification data sits in your own system in New Zealand. So an update is a handover between two companies. Four steps have to occur in order:

1. Somebody in your company notices the change.
2. Somebody in your company sends it.
3. Somebody in the importer's company enters it.
4. Somebody confirms that the change reached the passport.

This is a process problem that software does not fix. Give each of the four steps a named person.

Written authorisation moves the work, and it does not move the duty

The second sentence of Article 77(4) lets the responsible operator authorise another operator in writing. Your importer can authorise you to enter the passport data, because you hold that data.

That authorisation is not a transfer of responsibility. The operator that placed the battery on the market stays responsible for the passport.

One route does transfer the duty. Article 77(7) moves it when a battery is re-used, repurposed, remanufactured, or becomes waste. The new operator then issues a new passport. See lifecycle events.

You can agree to pay for your own mistake. You cannot agree to become the party that EU law holds responsible. See who is the economic operator.

The duty ends when the battery is recycled

Article 77(8) says the passport "shall cease to exist after the battery has been recycled". So the update work runs from the first sale to the recycler.

Article 78(e) keeps the passport available in the meantime. The passport must remain available after the responsible operator ceases to exist, or ceases its activity in the Union. Article 78(g) requires data authentication, reliability and integrity.

Plan staff time for that full period. Do not plan only for the cost of the first system. See how long a passport lasts.

The ecodesign regulation sets the same test, and it binds no product today

The Ecodesign for Sustainable Products Regulation (ESPR) is the framework law for digital product passports. It has been in force since 18 July 2024. Article 9(1) applies the same test, and asks for passport data that is accurate, complete and up to date.

That duty starts for a product group only when the European Commission adopts a rule for that group, called a delegated act. As at 14 August 2026 the Commission has adopted no such rule. Read how to read the timeline before you accept a date.

ESPR also decides where the passport data sits. Article 10(c) requires the operator responsible for creating the passport to store it, or a passport service provider to store it. Recital 41 of the same regulation requires a decentralised data system. The handover described above is thus part of the design.

The rules this page uses, and their status

Both regulations are in force. The dates above are the dates on which each rule starts to bind a product.

What to write down before your first shipment

1. Name the person in your company who reports a change.
2. Name the person in the importer's company who enters that change.
3. Give the update time as a number of working days, not as "promptly".
4. Name the person who confirms that the update reached the passport.
5. Ask the importer for a dated record of every change it makes.
6. Keep your own copy of every version, in a format you can export.

Steps 1 to 4 name people. They need no software, and they keep their value whatever rule reaches your sector later. See agreeing data duties for the contract and versioning and archives for the record.