The battery passport deadline is 18 February 2027.
From that date every LMT battery, which includes e-bike, e-scooter and e-moped batteries, placed on the EU market or put into service needs a digital battery passport and a QR code on the pack. The date has been in the text since 2023, has never been amended, and is not conditional on any delegated act. This page walks the legal chain, article by article, on the consolidated text.
Written in Art. 77(1), attached to no delegated act, never amended. There is nothing to slip.
Two articles, one date, no conditional clause
Both obligations start on the same day. Neither carries the formula “or X months after the entry into force of the delegated act” that the legislator used elsewhere in the same regulation: there is no act whose delay could move them.
“From 18 February 2027 each LMT battery, each industrial battery with a capacity greater than 2 kWh and each electric vehicle battery placed on the market or put into service shall have an electronic record (‘battery passport’).”
“From 18 February 2027, all batteries shall be marked with a QR code as described in Part C of Annex VI. The QR code shall provide access to the following: (a) for LMT batteries, industrial batteries with a capacity greater than 2kWh and electric vehicles batteries, the battery passport in accordance with Article 77”
Note what Art. 77(1) does not say: there is no capacity threshold for LMT batteries. The 2 kWh floor applies to industrial batteries only. A 250 Wh e-bike pack is in scope exactly like a 100 kWh car pack. What the record has to contain is a separate list, and it is set out data point by data point.
Four acts have amended the regulation. None touches the date.
The consolidated text of 31 July 2025 lists every amending act since 2023. This is the complete list, and Art. 77(1) is not in any of them.
- Reg. (EU) 2024/1781added Art. 77(10), the upload to the EU DPP registry
- Reg. (EU) 2025/1561moved supply-chain due diligence, Art. 48 only, to 18 August 2027
- Delegated Reg. (EU) 2025/606delegated amendment, outside Chapter IX
- Reg. (EU) 2026/1738replaced Annex I, restricted substances
Every 2031 in the regulation is real, and none of it is the passport
The text contains five obligations dated 2031. They live in the collection, carbon and recycling chapters, not in Chapter IX. If someone told you the passport starts in 2031, one of these rows is almost certainly what they were reading.
- Art. 60(3)(b)31 Dec 203161 % collection target for waste LMT batteries, an obligation on producers and their EPR organisationsLMT: yes
- Art. 7(3)(c)18 Aug 2031Maximum carbon-footprint threshold, the last step of the LMT carbon roadmapLMT: yes
- Art. 8(2)18 Aug 2031Minimum recycled content, listing industrial batteries above 2 kWh, EV and SLILMT: excluded
- Annex XII, Part C31 Dec 2031Material-recovery rates, an obligation on recyclersrecyclers
- Art. 9430 Jun 2031Commission review reports, including one on extending the LMT definitionCommission
One article was postponed. It is not this one.
“The battery regulation was delayed” is true of exactly one provision: Regulation (EU) 2025/1561 moved supply-chain due diligence, Art. 48, from August 2025 to August 2027. It amends that single article.
Chapter IX has no size or volume threshold. The 40 million turnover threshold of Art. 47 belongs to the due-diligence chapter, not to the passport.
Art. 96(2) lists the derogations from the general application date. Chapter IX is not among them.
A battery first made available in the EU before 18 February 2027 never acquires the obligation, even if the vehicle sells later. Proving that first-placement date, batch by batch, is on you.
Some Annex XIII fields populate later, such as the LMT carbon footprint from August 2028. The fields change over time. The obligation to issue the passport does not.
A deadline missed by the Commission binds the Commission
The implementing act under Art. 77(9) was due by 18 August 2026 and is expected in Q4 2026. It does not define the passport’s technical requirements, which sit in Art. 78 and are directly applicable. It only settles which parties with a legitimate interest access which data. Nothing in it moves, or could move, the February 2027 date.
Whoever places the battery on the EU market
Placing on the market means the first making available in the Union, Art. 3(1)(16). That is the brand selling packs under its own name, the importer bringing them in from a third country, and the aftermarket too: cells and modules supplied for end use count as batteries placed on the market, Art. 1(4).
An assembler mounting packs a supplier already placed on the EU market is a distributor, not the issuer: the passport is the supplier’s duty. A distributor still may not make a battery available without the Art. 13 marking, which from the same date includes the QR code, Art. 42(2)(b). The full breakdown by role is on the home page, next to three passports you can scan.
February 2027 is a purchase-order question
Any positive lead time moves your real deadline earlier than the legal one: packs ordered late land after the date without a passport. The worked example is on the home page, and the price of closing the gap is published, not quoted.
Sources: Regulation (EU) 2023/1542 (original text), consolidated version of 31 July 2025, CELEX 02023R1542. Quotations are verbatim from the English consolidated text, including its typography. Last checked 18 August 2026.