The Digital Battery Passport requirement is taking effect on 18 February 2027. For companies importing batteries into the European Union, compliance responsibilities extend beyond customs clearance. Importers must verify that batteries meet applicable requirements before placing them on the EU market, maintain supporting documentation, cooperate with authorities and, for relevant battery categories, prepare for the
Under Regulation (EU) 2023/1542, importers have specific responsibilities for checking conformity, labelling, documentation and the manufacturer's obligations.
For EU importers and other economic operators, the practical question is: what needs to be in place before 2027?
We’ve already discussed what EU Customs will check regarding Battery Passports. Today we’ll go through everything importers can do to prepare for 2027 regulations.
Who is Responsible for Imported Batteries’ Compliance?
An importer bringing batteries from outside the EU onto the Union market has its own obligations under Article 41 of the Batteries Regulation. It cannot simply rely on a manufacturer's declaration that a battery is compliant.
Before placing a battery on the market, importers must verify that the manufacturer has completed the appropriate conformity assessment, prepared the EU declaration of conformity and technical documentation, and fulfilled the relevant requirements.
They must also check that the battery carries the required CE marking and labelling, and that it is accompanied by the necessary documentation, instructions and safety information. If an importer has reason to believe that a battery is not compliant, it must not place it on the market until the issue has been addressed.
This makes compliance verification part of the import process, rather than something to address after products arrive.
Check Labelling, Documentation and Product Information
Importers should establish a repeatable process for checking each relevant battery model or shipment.
This should cover conformity documentation, technical documentation, CE marking, required labelling, instructions and safety information. Importers must also provide their own identification details, including their name, registered trade name or trade mark and postal address, subject to the requirements of Article 41.
Storage and transport also matter. While batteries remain under an importer's responsibility, their storage and transport conditions must not compromise compliance.
For organisations working with multiple overseas suppliers, documenting these checks can make it considerably easier to demonstrate compliance if an authority requests evidence.
What Does the Digital Battery Passport Mean for Importers?
The Digital Battery Passport introduces another important information requirement.
From 18 February 2027, every electric vehicle battery, LMT battery and industrial battery above 2 kWh placed on the EU market or put into service must have a Battery Passport. The Passport contains information relating to the battery model and individual battery, including information generated during its use.
The European Commission's latest Battery Passport guidance, published on 21 August 2026, identifies 71 data points and provides information on their applicability to EV, LMT and industrial batteries. The guidance is intended to help economic operators understand the information required for battery passport implementation.
For importers, an important question follows:
Where will this information come from?
For batteries manufactured outside the EU, much of the relevant information will originate with the overseas manufacturer or other supply chain actors. Importers therefore need reliable processes for obtaining, validating and maintaining the information associated with the batteries they place on the EU market.
Establish a Reliable Supplier Data Chain
Battery Passport preparation should begin with suppliers.
Importers should identify which information they need for each battery category and agree how that information will be provided, validated and updated.
This may include technical characteristics, performance and durability information, sustainability and circularity data, and information supporting repair, reuse and recycling.
A useful starting point is to map:
Required data → source → responsible organisation → update frequency → supporting evidence
BASE's article about Battery Passport Data Attribute Longlist v1.3 can support this exercise by helping organisations understand the range of data attributes that need to be considered.
Importers should also assess whether supplier information can be integrated with their own ERP, product information or compliance systems. Relying on spreadsheets and manually exchanged documents may become increasingly difficult as Battery Passport information grows in volume and complexity.
Keep Compliance Evidence Audit-Ready
Importers should be able to demonstrate not only that information exists, but where it came from and how it was verified.
Article 41 requires importers to provide national authorities, following a reasoned request, with information and documentation necessary to demonstrate conformity. Importers must also cooperate with authorities when measures are required to address risks associated with batteries they have placed on the market.
This makes data provenance, version control and evidence management important parts of Battery Passport preparation.
A practical system should allow an importer to connect a battery or battery model with its conformity documentation, supplier information, supporting evidence and relevant Battery Passport data.
For a deeper look at this issue, see our Battery Passport Audit Trail and Evidence Management article.
Keep Battery Passport and Due Diligence Requirements Separate
Importers should also distinguish the Digital Battery Passport from the Batteries Regulation's separate due diligence obligations.
Regulation (EU) 2025/1561 postponed the application of Article 48 battery due diligence obligations from 18 August 2025 to 18 August 2027. These requirements concern policies covering the sourcing, processing and trading of certain raw materials used in batteries, including cobalt, natural graphite, lithium and nickel.
The postponement does not change the 18 February 2027 Battery Passport deadline.
Importers should therefore manage these as separate regulatory workstreams while looking for opportunities to use common supplier and data-management processes.
How BASE Can Help
The BASE project is developing and validating a trusted and interoperable Digital Battery Passport framework for the European battery value chain.
For importers, BASE's work is particularly relevant to the challenge of connecting information from manufacturers and suppliers with the systems and processes used by economic operators in the EU. The project addresses areas including digital identity, secure data exchange, interoperability, data management and lifecycle traceability.
BASE is also developing practical resources around Battery Passport data and standards. Its Battery Passport Data Attribute Longlist v1.3, DIN DKE SPEC 99100 Explained: The Technical Standard Behind Battery Passport Data Fields and JTC 24 Standards Explained For Battery Passport Teams: What They Mean In Practice can help organisations understand the data structures and interoperability considerations behind implementation.
For importers, this means looking beyond the Passport itself and considering how reliable information can move between suppliers, internal systems and the wider battery value chain.
Preparing for 2027
For EU importers, Battery Passport preparation can start with a straightforward exercise: map your batteries, suppliers, data and evidence.
Identify which imported batteries fall within scope, determine what information is required, establish responsibilities with overseas manufacturers and suppliers, and make sure supporting documentation can be retrieved when needed.
The goal is to ensure that when the Battery Passport requirement takes effect in February 2027, the importer can demonstrate not only that the required digital record exists, but that the information behind it is complete, reliable, traceable and supported by appropriate evidence.
The BASE project has received funding from the Horizon Europe Framework Programme (HORIZON) Research and Innovation Actions under grant agreement No. 101157200.
References & Resources
European Union - Regulation (EU) 2023/1542, Batteries and Waste Batteries Regulation: https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1710708373207&uri=CELEX:32023R1542
European Union - Regulation (EU) 2023/1542, Article 41: Obligations of Importers: https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1710708373207&uri=CELEX:32023R1542#:~:text=surveillance%20authorities%20thereof.-,Article%2041,-Obligations%20of%20importers
European Commission - Digital Product Passport For Batteries: https://single-market-economy.ec.europa.eu/single-market/digital-product-passport/batteries_en
European Commission - Guidance To Support Preparations For The Digital Batteries Passport, 21 August 2026: https://single-market-economy.ec.europa.eu/news/guidance-support-preparations-digital-batteries-passport-2026-08-21_en
European Union - Regulation (EU) 2025/1561, Battery Due Diligence Amendment: https://eur-lex.europa.eu/eli/reg/2025/1561
European Commission - The Digital Product Passport Registry Is Now Live: https://single-market-economy.ec.europa.eu/news/digital-product-passport-registry-now-live-2026-07-20_en