EU battery passport for Shopify stores: what changes on 18 February 2027

Last updated: 22 October 2026. This page gives practical pointers and is not legal advice. Deutsche Version · Version française

In short

• From 18 February 2027, each LMT battery (e-bike, pedelec, e-scooter), each industrial battery over 2 kWh (for example a home battery) and each electric car battery placed on the market or put into service needs a battery passport (Regulation (EU) 2023/1542, Article 77(1)).
• One passport per battery, not per model: it combines model data and data on the individual battery.
• The obligation sits with whoever places the battery on the EU market: the manufacturer (including a brand that has it made under its name) or the importer. Resellers check; they do not create passports.
• Access through a QR code on the battery, linking to a unique identifier under ISO/IEC 15459.
• Still open: exactly who may see the restricted data. The implementing act was due by 18 August 2026 and has not been adopted yet.

Which batteries need a passport?

• LMT batteries (light means of transport): sealed batteries of 25 kg or less, specifically designed to power the traction of wheeled vehicles driven by an electric motor alone or by motor and human power, such as e-bikes, e-scooters and type-approved category L vehicles, when they are not electric vehicle batteries (Article 3(11)). There is no capacity threshold: a small e-bike pack needs a passport too.
• Industrial batteries over 2 kWh. An industrial battery is one designed for industrial uses, and also any other battery over 5 kg that is not an electric vehicle, LMT or SLI (starter) battery (Article 3(13)). Stationary energy storage systems are explicitly industrial batteries (Article 3(15)).
• How the 2 kWh is counted. According to the Commission's battery passport FAQ (question 3.3), what counts is the finished battery: units that each work on their own below 2 kWh are assessed one by one; units that form one integrated system with common components are assessed together.
• The QR code concerns every battery. From 18 February 2027 all batteries must carry a QR code; for LMT, industrial over 2 kWh and electric vehicle batteries, it gives access to the passport (Article 13(6)).

Does it concern your store? Brand, importer or reseller

Selling on Shopify changes nothing: what matters is your role. The passport is the duty of the economic operator placing the battery on the market (Article 77(3) and (4)), placing on the market being the first making available on the EU market (Article 3(16)). The Commission's FAQ adds:

• Whoever finishes the battery is responsible. If a finished battery is only installed, it stays with the battery manufacturer; whoever adds, for example, the battery management system (BMS) becomes responsible (questions 2.3 and 2.5).
• Imported products with the battery installed: the battery is normally placed on the market when the product is imported, and the importer is responsible (question 3.5). This is the case of stores that import complete e-bikes or e-scooters from outside the EU.
• Brand-name replacement packs: selling a battery under your own name or trademark makes you its manufacturer (Article 3(33)).
• You can delegate the work, not the responsibility. The operator may authorise another operator in writing to act on its behalf (Article 77(4)), but stays legally responsible (question 2.1).
• Refurbished or second-life batteries: whoever places them back on the market needs a new passport linked to the original one (Article 77(7)). A simple repair does not need a new passport (question 9.2). The passport ceases to exist once the battery is recycled (Article 77(8)).

If you are a reseller (distributor) of batteries another company already placed on the EU market, you do not create passports. Before selling, you must verify that the producer is registered, that the battery bears the CE marking and is marked under Article 13 (so with the QR code from 18 February 2027), and that it comes with its documents, instructions and safety information in the local language (Article 42(2)). If you have reason to believe a battery does not comply, you must not sell it until it does (Article 42(3)).

What goes in the passport

Annex XIII of the regulation sets four groups of information with different access rights:

1. Public, per model: the information in Annex VI Part A (manufacturer, category, identification, place and date of manufacture, weight, capacity, chemistry…), material composition with hazardous substances and critical raw materials, rated capacity (Ah), minimal, nominal and maximum voltage, power capability, expected lifetime in cycles with the reference test, temperature range when not in use, period of the commercial warranty, energy efficiency, internal resistance, C-rate, markings, the EU declaration of conformity, and information on the prevention and management of waste batteries.
2. Persons with a legitimate interest and the Commission, per model: detailed composition (cathode, anode, electrolyte), part numbers and contacts for spare parts, dismantling information (exploded diagrams, disassembly sequence, fasteners, tools, warnings, number and layout of cells) and safety measures.
3. Notified bodies, market surveillance authorities and the Commission only: results of the test reports proving compliance.
4. Per individual battery, for persons with a legitimate interest: performance and durability values at placing on the market and at each change of status, state of health, status (original, repurposed, re-used, remanufactured, waste), and use data such as charge cycles, accidents, temperature and state of charge.

Not everything is required in February 2027. According to the Commission's FAQ (question 7.2), carbon footprint, recycled content and due diligence information will not be required yet; they have their own application dates. Due diligence was postponed to 18 August 2027 by Regulation (EU) 2025/1561. Which of the 71 data points are mandatory, optional, conditional or not yet required for each battery category is set out in the Commission's guidance “Digital Batteries Passport – data points by category” (updated 21 August 2026).

• Use data may be empty when a new battery is first placed on the market (question 8.6). For an offline e-bike battery, the Commission considers updating it when the battery is brought in for servicing appropriate (question 8.7). State of health is only required where the battery has a BMS (question 8.5).
• Language: information that is not language-neutral must be in the language set by the Member State where the battery is sold (question 7.4).
• Format: open standards, interoperable, machine-readable, structured, searchable, and transferable without vendor lock-in (Article 77(5)).

QR code, unique identifier, and why the passport outlives your store

• The passport is reached through the QR code, which links to a unique identifier the operator attributes to the battery. Both must comply with ISO/IEC 15459-1 to -6 or equivalent standards (Article 77(3)).
• Identifiers can be created in-house using one of the options in those standards, or obtained from a commercial service (FAQ, question 5.2).
• The QR code is printed or engraved visibly, legibly and indelibly on the battery. Only where the nature or size of the battery does not allow it does it go on the packaging and accompanying documents (Article 13(7)).
• Because the code stays on the battery for years, the address behind it must keep working: the passport must remain available even after the responsible operator ceases to exist or stops its activity in the EU (Article 78(e)). A page that disappears when a store closes, changes platform or removes an app does not meet that.

Access levels: what is fixed and what is not

• Fixed: access is free of charge for everyone, according to their access rights (Article 78(b)). A provider storing the data on the operator's behalf may not sell, re-use or process it beyond the service (Article 78(c) and (d)). Authentication, reliability and integrity of the data must be ensured (Article 78(g)).
• Fixed: persons with a legitimate interest are those who need the data to dismantle, repair, remanufacture, repurpose or recycle the battery, and the purchaser of an individual battery (or someone acting on their behalf) to make it available to independent energy aggregators or energy market participants (Article 77(2)).
• Not fixed yet: exactly who counts as a person with a legitimate interest, and to what extent they may download, share and re-use the data. An implementing act was due by 18 August 2026 (Article 77(9)). According to the Commission's FAQ (question 1.4), it is still being developed, with a draft expected for public feedback in October or November 2026. It will not define how repairers or recyclers authenticate either (question 6.4).

The EU registry

• The operator placing the battery on the market must upload the unique identifier to the EU digital product passport registry (Article 77(10), added by Article 78 of the Ecodesign Regulation (EU) 2024/1781).
• The registry rules are in Implementing Regulation (EU) 2026/1778 of 16 July 2026, which explicitly covers batteries under Article 77.
• The registry has been live since 20 July 2026, with a testing environment and a helpdesk (FAQ, question 1.2). To register, the operator must verify its identity, for example with a qualified electronic seal under eIDAS (question 6.1).
• The registry mainly records registrations and metadata. The passport itself is hosted by the operator or by a provider authorised in writing (question 6.5).

Penalties

Each Member State sets its own penalties, which must be “effective, proportionate and dissuasive” (Article 93). Check the rules of each country where you place batteries on the market. Example, Germany: section 60 of the Batteries Act (BattDG) sets fines of up to €10,000 for an operator that does not ensure the passport information is accurate, complete and up to date, the same for a manufacturer that does not ensure the Article 13 marking (QR code included) and for a distributor that does not check it, and up to €100,000 for not complying with an enforceable order of the authority.

What a Shopify store can prepare now

1. Settle your role for each product: do you place the battery on the EU market (your brand, your import), or buy from an EU supplier that already did?
2. List the products concerned: every LMT battery and every industrial battery over 2 kWh, including batteries inside e-bikes and e-scooters, and spare packs.
3. Collect the model data, usually from your cell or pack supplier: Annex VI Part A, composition, performance values, declaration of conformity, dismantling and safety information, test reports.
4. Track serial numbers per unit. One passport per battery means knowing which serial each shipped battery carries. Shopify's inventory features work on quantities per variant and location, not on individual units; our guide Serial number and lot tracking in Shopify covers the ways to record them.
5. Get the QR code on the battery, not only on the box where possible. That is decided at production, so talk to your supplier early.
6. Choose hosting that will outlive your store setup, in an open, exportable format.
7. Prepare the EU registry verification (qualified electronic seal or another accepted means) and try the testing environment.
8. If you are a reseller: ask your suppliers how their batteries will carry the QR code, and plan the Article 42 check before you list new stock.

What Merchant Tools offers

For Shopify stores. Our app MT: Serial & Lot Tracking already records which serial number shipped in which order (import, phone or USB scanner, assignment from the order page and at the till with Shopify POS). A “Battery passport” module for this app is in development: it is meant to turn the serial numbers you already track into one passport per battery. It is planned to be available before February 2027. Until then, we promise neither detailed features nor prices.

View MT: Serial & Lot Tracking on the Shopify App Store

Not on Shopify? If you sell through WooCommerce, Shopware or a custom website and need battery passports, write to support@merchanttools.eu with what you sell and roughly how many batteries per year. We want to measure that demand; we have no offer outside Shopify yet.

Frequently asked questions

When does the EU battery passport become mandatory?
From 18 February 2027, for each LMT battery, each industrial battery over 2 kWh and each electric vehicle battery placed on the market or put into service (Article 77(1)). From the same date, all batteries must carry a QR code (Article 13(6)).

I sell e-bikes on Shopify. Do I need to create battery passports?
It depends on your role, not on the platform. If you are the brand (including a brand that has batteries made under its name) or the importer, yes. If you resell batteries another company already placed on the EU market, no: you check before selling that the battery carries, among other things, the CE marking and the QR code (Article 42(2)).

I import complete e-bikes or e-scooters from outside the EU. Am I responsible?
Normally, yes. According to the Commission's FAQ, when a product is imported with a finished battery installed, the battery is normally placed on the market at import, and responsibility lies with the importer.

Is it one passport per battery or per model?
Per battery. The passport holds model information and information specific to each battery (Annex XIII), and the QR code links to a unique identifier per battery (Article 77(3)). In practice: one passport per serial number.

Can the battery passport be a page on my Shopify store?
The regulation does not say where it must be hosted, but a store page meets its conditions poorly: the QR code stays on the battery for its whole life, and the passport must remain available even after the responsible operator ceases to exist or stops its activity in the EU (Article 78(e)). The data must also be machine-readable and transferable without vendor lock-in (Article 77(5)).

Will the battery passport be postponed?
As of 22 October 2026, no postponement of the passport has been adopted and the Commission still states 18 February 2027. Only due diligence was postponed, to 18 August 2027 (Regulation (EU) 2025/1561). The industry association EUROBAT asked in September 2025 for a postponement to 2030: a request, not a decision. Check again before February.

Shopify is a trademark of Shopify Inc. Merchant Tools is an independent developer, not affiliated with Shopify.