The EU's "Battery Passport" initiative is quietly eating into the profits of small and medium-sized lithium battery manufacturers.
Starting from February 18, 2027, three categories of batteries entering the EU market will face a new mandatory requirement: batteries for light means of transport, industrial batteries with a capacity greater than 2 kWh, and electric vehicle batteries will need to be equipped with an electronic "battery passport" (Source: Article 77 of EU Regulation 2023/1542 on Batteries and Waste Batteries, adopted on July 12, 2023).
For China's lithium battery industry, this matter is most easily described as "one more QR code to scan for exports". But the regulation changes far more than just labels. The battery passport needs to record battery model information and cell-level information, associate unique identifiers via QR codes, and the data must adopt open standards, be interoperable, machine-readable, structured and retrievable (Source: Articles 77 and 78 of EU Regulation on Batteries and Waste Batteries).
In other words, what will be delivered to European customers in the future is not only cells, modules or battery packs, but also a set of verifiable, continuously updated data that can be accessed according to permissions. Beyond manufacturing capabilities, data governance is becoming part of the overseas expansion capabilities of Chinese enterprises.
Clarify the Scope of Application First
The first point to correct is the claim that "all lithium batteries are required to be equipped with passports compulsorily on February 18, 2027". Article 77 of the regulation explicitly lists three categories: batteries for light means of transport, namely LMT batteries; industrial batteries with a capacity greater than 2 kWh; and electric vehicle batteries (Source: Article 77 of EU Regulation on Batteries and Waste Batteries).
Key data points: The mandatory implementation node for battery passports is February 18, 2027; the applicable objects include every LMT battery, every industrial battery with a capacity greater than 2 kWh, and every electric vehicle battery. The passport is connected to a unique identifier through a QR code, and requires accurate, complete and timely updated information (Source: Article 77 of EU Regulation on Batteries and Waste Batteries).
This boundary is very important. Small portable batteries in consumer electronics and different types of industrial batteries do not have exactly the same applicable obligations and time nodes. The statement that "lithium battery exports are fully subject to an additional passport threshold" overstates the scope. The accurate statement should be: a batch of batteries directly related to electric mobility and large-capacity industrial applications will take the lead in entering the era of digital passports.
A QR Code Is Not Equal to a Battery Passport
Another concept that is often confused is the QR code. Article 13 of the EU regulation stipulates that from February 18, 2027, all batteries shall be marked with a QR code; but the "battery passport" specified in Article 77 is only mandatorily applicable to LMT batteries, industrial batteries with a capacity greater than 2 kWh, and electric vehicle batteries (Source: Articles 13 and 77 of EU Regulation on Batteries and Waste Batteries).
Therefore, the QR code is the information entry, and the passport is the underlying data system. The presence of a QR code does not mean that all batteries bear exactly the same passport information obligations. For export enterprises, what really needs to be judged first is which category their products belong to, and then check the labels, QR codes, passports and other phased obligations in accordance with the corresponding provisions.
This difference also reminds the industry that February 18, 2027 cannot be simply interpreted as "all EU battery compliance requirements start on the same day". Requirements such as carbon footprint declarations, performance classes, and recycled materials have their own applicable categories and phased schedules in the regulation (Source: Articles 7 and 8 of EU Regulation on Batteries and Waste Batteries). Enterprises need to make a schedule according to product categories, rather than only focusing on one deadline.
What Is Included in a Battery Passport
Annex XIII of the regulation lists a long list of public information. In addition to the manufacturer, manufacturing location, production date, weight, capacity and chemical system, it also includes material composition, critical raw materials, applicable carbon footprint information, responsible sourcing information, recycled material content, rated capacity, service life and waste battery management information (Source: Annex VI and Annex XIII of EU Regulation on Batteries and Waste Batteries).
The carbon footprint requirement in particular is highly illustrative. The regulation requires relevant electric vehicle batteries, rechargeable industrial batteries and LMT batteries to form carbon footprint declarations in accordance with the provisions, and the calculation must trace back to links such as raw material acquisition and preprocessing, production, distribution and end-of-life stages (Source: Article 7 and Annex II of EU Regulation on Batteries and Waste Batteries).
This means that the "data cost" of a battery will be transmitted upstream along the industrial chain. If battery manufacturers want to prove their carbon footprint and material sources, they need verifiable data provided by links such as positive electrodes, negative electrodes, electrolytes, separators, mineral resources and recycling.
Three Layers of Data for One Battery
There is another often overlooked design in the battery passport: not all data is open to everyone. The regulation divides information into different layers according to access permissions. Part of the model information is publicly accessible; detailed composition and disassembly information are only open to entities with legitimate interests and the European Commission; information such as test reports is mainly for certification bodies, market supervision authorities and the European Commission (Source: Article 77 and Annex XIII of EU Regulation on Batteries and Waste Batteries).
Individual cells will also record performance and durability parameters, health status, original or reused status, as well as usage data such as charge-discharge cycles and accidents, and set access permissions based on legitimate interests (Source: Annex XIII of EU Regulation on Batteries and Waste Batteries).
Therefore, the "battery passport" is not only a data identity card, but also a set of permission systems. Enterprises not only need to ensure that they have the required data, but also need to clarify which data can be made public, which data can only be opened to designated parties, who has the right to modify the data, and how to ensure data authenticity and security.
A takeaway framework: the new threshold for batteries to enter overseas markets can be broken down into four components. First, whether product parameters can be traced; second, whether the carbon footprint can be calculated; third, whether raw material and supply chain information can be verified; fourth, whether recycling and life cycle data can be continuously updated. Qualified manufacturing is only the first hurdle, and verifiable data is the second.
Pressure Has Been Transmitted to the Upstream
According to a report by China Securities Journal on August 10, 2026, the compliance requirements for exports to the EU have been transmitted from downstream battery manufacturers to the upstream of China's lithium battery industrial chain, involving work such as ESG data collection and supply chain due diligence; some enterprises are building data collection systems and requiring suppliers to upgrade synchronously (Source: China Securities Journal, August 10, 2026).
This change is consistent with the logic of the EU regulation. Because a lot of key data is not generated in the final assembly process of battery factories, but in the upstream material, energy and production links. The later you start to supplement the data, the more likely you will face the problem that "the product has been manufactured, but the supporting proof materials cannot be traced back".
China Securities Journal also reminds that enterprises need to balance compliance standards, supply chain resilience, data governance and data security at the same time (Source: China Securities Journal, August 10, 2026). This also shows that the battery passport is not the work of a single environmental protection department, but will simultaneously involve procurement, production, quality, supply chain, information technology and legal compliance departments.
Competition Shifts From Manufacturing to Verification
The following is a reasoning for readers' reference. One of the strongest advantages of China's lithium battery industry in the past is integrating complex materials and manufacturing processes into a high-efficiency supply chain. The new problem raised by the battery passport is that this supply chain must not only "be able to produce the products", but also "be able to explain clearly and prove the products".
This change does not mean that the manufacturing advantage is invalid. On the contrary, it may create a new outlet for the organizational capabilities of the mature supply chain. Large-scale enterprises are more likely to establish unified data standards, while small and medium-sized suppliers hold a lot of first-hand original data. If leading enterprises can synchronize data templates, traceability standards and audit mechanisms to the upstream, compliance capabilities may evolve from the capability of a single enterprise to the capability of the entire supply chain.
The real threshold has thus changed from a single QR code to "data continuity". From raw material to production, from factory delivery to use, and then to recycling, the passport requires connecting multiple stages. Any party whose data chain is broken will need to provide additional supporting proofs.
What Does This Have to Do With You
The first group of people are practitioners in the lithium battery, material, recycling, testing and certification industries. February 18, 2027 is not a deadline that only belongs to battery manufacturers. Whether upstream data can enter the customer system in a timely and accurate manner will directly affect the compliance efficiency of the entire supply chain.
The second group of people are those engaged in the overseas expansion of the manufacturing industry. The battery passport sends a clear signal: global trade rules are evolving from "products meeting standards" to "the full life cycle information of products can also be verified". Similar data passport ideas may continue to expand to more product fields.
The third group is ordinary consumers. In the future, scanning a battery QR code will not only connect to model parameters, but also information such as materials, carbon footprint, service life and recycling. More and more products are entering the market with a digital file.
This article is for information sharing and industry analysis only, and does not constitute any investment advice, investment analysis opinion or transaction solicitation. The applicable scope, implementation date, information fields and access permissions of the EU battery passport in this article are from EU Regulation 2023/1542 on Batteries and Waste Batteries and its annexes (adopted on July 12, 2023, the regulation is a continuously revised text); the compliance practice of China's lithium battery industrial chain is from China Securities Journal (August 10, 2026). The specific obligations and phased timelines for different categories of batteries vary, and the actual compliance of enterprises shall be subject to the latest official EU regulations, delegated acts and implementing acts. The market is risky and decisions should be made with caution. The content explicitly marked as reasoning in this article is a logical deduction based on public information and does not represent an official position.
This article is from the WeChat Official Account "BT Business Tech", author: Yi Ning, published with authorization from 36Kr.