Dossier 001 · open end to end, free
EU battery passport, 18 February 2027.
18 February 2027
166 days remaining
On 18 February 2027 it becomes illegal to place an electric vehicle battery, an e-bike or scooter battery, or an industrial battery above 2 kWh on the EU market without a machine-readable electronic record reachable from a QR code on the battery itself.
Nobody is exempt for being small. The importer of a container of scooter packs carries the same obligation as a carmaker, with none of the data and none of the staff.
Source in the same line as the claim, as always: Regulation (EU) 2023/1542, OJ text, Article 77(1).
This dossier is given away in full — the window, the buyers, the build, the screens, the pricing and 50 named customers. Nobody should pay to find out how deep a dossier goes.
The day it lands
18 February 2027
166
days remaining
Regulation (EU) 2023/1542, Article 77(1). The count is arithmetic against the date in the official journal, and you can check both.
The evidence
Five sentences of the regulation decide this entire market. Every row below points at the article it comes from, inside Regulation (EU) 2023/1542.
The obligation
Every LMT battery, every industrial battery above 2 kWh and every electric vehicle battery placed on the EU market from 18 February 2027 must carry an electronic record, the battery passport.
Article 77(1)
The data carrier
The passport must be reachable through a QR code printed on, or engraved into, the battery, and the QR code must give access to the record without a login.
Article 77(2) and Annex VI, Part C
The data set
The record must carry the information listed in Annex XIII: chemistry, materials including critical raw materials, carbon footprint, durability, state of health, dismantling information and the responsible economic operator.
Annex XIII
Who is on the hook
The economic operator placing the battery on the market or putting it into service is responsible for the passport being accurate, complete and current.
Article 77(3)
How long it lives
The passport must remain available until the battery is recycled or repurposed, and must be updated when the battery is repurposed or remanufactured.
Article 77(4) and (5)
The window, and the day it closes
The commercial window is shorter than the compliance window. Compliance software for a fixed date is bought three to six months before it, once the deadline enters the quarterly plan and stops being someone's problem for later.
That puts the selling window between now and roughly the end of 2026, and the building window before that. After 18 February 2027 the firms that were going to panic have already bought something, and the pitch changes from urgency to migration, which is a worse business.
The window does not close because interest fades. It closes because the date passes and the buyers on the other side of it already have a supplier.
Who is forced to spend
Six cohorts, ordered by how badly the date hurts them. The same firms already pay for CE marking files, REACH and RoHS declarations and per-market registrations, typically as consultancy days at four figures per product family.
Pack assemblers and integrators
They place the finished battery on the market, so the passport is legally theirs even though the cell data belongs to a supplier they do not control.
Highest urgency, lowest tooling
Importers
An importer becomes the responsible economic operator for a battery designed and built elsewhere, and inherits a data set nobody upstream has ever assembled.
Highest urgency, no in-house data
Light means of transport brands
E-bike, cargo-bike and scooter brands ship high unit counts of small packs, so per-unit passport cost matters more to them than to a carmaker.
High volume, thin margin
Industrial and storage builders
Every cabinet above 2 kWh is in scope, including forklift traction packs and home storage units, and these firms often have dozens of variants and no product data platform.
Many variants, no platform
Cell manufacturers and gigafactories
They hold most of the Annex XIII data and will be asked for it by every customer downstream, in a different format each time.
Data holder, not the filer
Recyclers and second-life operators
They must read the passport to dismantle safely and write to it when a battery is repurposed, which makes them the only party that needs the record after the sale.
Reader and writer, later
What to build
The passport of record for firms too small to buy a product lifecycle platform.
Not a compliance suite. One narrow job: turn whatever product data a pack assembler already has into an Annex XIII record with a permanent public URL and a QR code, and name the fields that are still missing along with the supplier who holds each one.
The insight worth building on is that the hard part is not hosting the passport, it is assembling the data from suppliers who have never been asked for it. So the product is a chase list wearing a passport as its output, and the chase list is what they will pay for.
Deliberately out of scope: carbon footprint calculation, full material declarations, anything that needs a consultant in the room. The moment this needs services revenue it stops being buildable in a weekend and starts competing with firms that have 400 consultants.
The first screens
Five screens, in the order the buyer meets them. Nothing here needs an account before screen two.
Paste the pack
One field. They drop in the spec sheet, the bill of materials or the existing CE technical file, in whatever shape it already exists. No data model asked of them, no onboarding, no account before this screen.
The gaps table
The Annex XIII fields down the left, what we extracted in the middle, and what is missing on the right, with the supplier who holds each missing field named. This screen is the product. It converts a regulation into a to-do list of fewer than 20 rows.
The supplier ask
One button generates the email to each named supplier requesting exactly the fields that are missing, in the regulation's own words, with the article cited. The reply lands back in the record without the customer retyping anything.
The passport, as a stranger sees it
The public record at a permanent URL, with the QR code beside it and a print sheet sized for a label press. They scan it with their own phone in the room. This is the moment the compliance officer believes the thing exists.
The change log
Every field, who supplied it, when, and what changed. Not a feature for the buyer: a feature for the market surveillance authority that asks in 2028, which is the reason the buyer keeps paying after the date has passed.
The pricing
Priced per product family, because that is the unit these firms already use for a technical file, and because it grows with their catalogue rather than with their seats.
$0
One product family, one passport
The gaps table and one live passport, free forever. The gaps table alone is worth the signup, and it is the only demo that survives a sceptic.
$240 per year
Per product family
Unlimited passports issued inside that family, hosting, the QR sheets and the change log. Priced per family because that is how these firms already think about a technical file.
$4,800 per year
Importer and assembler plan
Up to 25 families, the supplier chase workflow, and a single export their notified body will accept. This is the tier the money comes from, and it is still an order of magnitude under a consultancy engagement.
Thirty firms on the middle tier and four on the top one is $26,400 a year, from a product whose whole surface is a table and a QR code.
The first 50 customers, by name
Named because a list of segments is not a list of customers. Each one places batteries in scope of Article 77 on the EU market, which is why the date reaches them whether or not they have noticed it.
Light means of transport brands and their pack suppliers
Every one of these places LMT batteries on the EU market in volume, so each unit needs a passport and per-unit cost decides who they buy from.
Bosch eBike Systems
Drive-unit and pack supplier to most European e-bike brands
Brose Antriebstechnik
E-bike drive and battery systems built and sold in Germany
Fazua
Lightweight e-bike drive packs supplied to EU frame builders
Mahle SmartBike Systems
E-bike systems including in-frame packs, sold EU-wide
Pon.Bike
Gazelle, Kalkhoff and Focus e-bikes placed on the EU market
Accell Group
Batavus, Haibike and Koga e-bikes, high unit counts per year
Riese und Müller
Premium e-bikes and cargo bikes, dual-battery configurations
Canyon Bicycles
Direct-to-consumer e-bikes shipped across the EU
Cube Bikes
One of the largest e-bike volumes in the German market
Orbea
Spanish e-bike manufacturer placing packs on the EU market
Cowboy
Belgian e-bike brand, own battery pack design
VanMoof
Dutch e-bike brand with proprietary integrated packs
Decathlon
Importer and own-brand seller of e-bikes at retail scale
Shimano Europe
Importer of record for STEPS drive batteries into the EU
Yamaha Motor Europe
Importer of e-bike drive systems and packs
Stromer
Speed pedelecs with large-capacity integrated packs
Piaggio
Electric scooters and swappable packs sold across the EU
Silence
Swappable scooter packs, an explicit second-life story to document
Pack assemblers, integrators and importers
These are the responsible economic operator on the label while the Annex XIII data sits with a supplier they do not own. They are the sharpest version of the problem.
BMZ Group
Independent pack assembler across LMT, industrial and medical
Customcells
Custom cell and pack builder for regulated applications
Webasto Battery Systems
Standard packs sold into third-party vehicle builders
BorgWarner Battery Systems
Commercial-vehicle packs formerly Akasol, EU-built
Leclanché
Packs for marine, rail and stationary use, all above 2 kWh
Alelion Energy Systems
Lithium packs for forklifts and industrial vehicles
Intilion
Industrial storage cabinets, many variants, small team
Tesvolt
Commercial storage systems assembled in Germany
Fenecon
Storage integrator including second-life EV packs
VARTA
Consumer and storage batteries placed on the EU market
Industrial, traction and storage builders
Everything they sell is above 2 kWh, so their whole catalogue is in scope, and a catalogue of variants is exactly what a per-family price fits.
Jungheinrich
Lithium traction batteries built into its own forklifts
Linde Material Handling
Industrial traction packs across a wide model range
Toyota Material Handling Europe
Forklift lithium packs sold EU-wide
EnerSys EMEA
Motive power and storage batteries above the threshold
Exide Technologies
Industrial batteries across EU markets
Hoppecke
Traction and stationary industrial batteries
Sunlight Group
Motive power and storage, Greek manufacture, EU sales
Midac
Italian industrial battery manufacturer
FIAMM Energy Technology
Industrial batteries placed on the EU market
Sonnen
Home storage units, every one above 2 kWh
SENEC
Home storage at volume in the German market
E3/DC
Storage systems with a large installed base to document
Cell manufacturers and gigafactories
They hold most of the Annex XIII data. They will be asked for it by every downstream customer in a different format, which is a product in itself.
PowerCo
Volkswagen cell operation supplying EU vehicle programmes
Automotive Cells Company
Franco-German cell manufacture for EU carmakers
Verkor
French cell manufacturer with EU customers
Northvolt
Swedish cell operation supplying EU pack builders
Morrow Batteries
Norwegian cells for stationary and industrial use
InoBat
Slovak cell manufacturer supplying EU programmes
LG Energy Solution Wrocław
Largest EU cell plant, supplies many pack builders
Samsung SDI Göd
Hungarian cell plant supplying EU vehicle makers
SK On Iváncsa
Hungarian cell plant with EU-bound output
CATL Erfurt
EU cell manufacture, and the data source for many importers
Compiled on 5 September 2026 from what each firm publicly sells. Scope is our reading of Article 77 against their product lines, not legal advice, and we expect you to check a name before you write to it.
What would falsify this
Five ways this thesis dies. Printed here, in the free dossier, because a research product that hides its own counter-arguments is marketing.
The date moves. There is precedent inside this very calendar: the deforestation regulation was postponed twice. Watch the Commission's amending proposals, not the trade press.
A delegated act or an implementing act fixes the passport's data format and a free reference implementation ships with it. This would turn hosting into a commodity and leave only the gaps table as a business.
A standards body publishes the interoperability standard early and a consortium of cell makers runs the registry themselves, at zero cost to their customers, to keep the data out of a third party's hands.
The large product lifecycle management vendors bundle passport issuance into contracts these firms already hold. This closes the top of the market and leaves the small assemblers and importers, which is why the plan starts there.
Enforcement is weak in the first 18 months. Market surveillance capacity is finite, and a regulation nobody checks is a regulation nobody buys software for. The counter-signal to watch is the first published enforcement action.
Every dossier is built this way. The calendar holds six more dates.
This window closes 18 February 2027. You have 166 days.