Battery passport requirements for PrestaShop merchants
Batteries got a passport before anything else, through their own regulation rather than through ESPR. That makes them the first — and for most merchants the only near-term — hard DPP deadline.
Short answer. From 18 February 2027, every LMT battery, every industrial battery with capacity above 2 kWh and every electric vehicle battery placed on the EU market must carry a battery passport, reachable through a QR code on the battery. Ordinary portable batteries — the AAs and the phone battery inside a phone — are not covered by the passport obligation, though other parts of the Batteries Regulation still apply to them.
What is in scope
The passport obligation in Article 77(1) covers exactly three categories, and the wording matters because it is narrower than most summaries suggest:
- LMT batteries — light means of transport. E-bikes, e-scooters, e-mopeds and similar. This is the category that catches ordinary retailers who do not think of themselves as battery sellers.
- Industrial batteries with a capacity greater than 2 kWh. Home energy storage units sold to consumers frequently sit here.
- Electric vehicle batteries.
Everything else — portable batteries, SLI starter batteries, industrial batteries at or below 2 kWh — falls outside the passport requirement, though not outside the Batteries Regulation generally.
A drafting detail worth knowing. Elsewhere in the Regulation, obligations on industrial batteries carve out those "with exclusively external storage". Article 77(1) contains no such carve-out. Read literally, external-storage industrial batteries above 2 kWh do need a passport from 18 February 2027, even though their carbon-footprint and recycled-content duties do not arrive until 2030–2033. If this affects your product line, it is worth a legal check rather than an assumption.
The trap: batteries inside other products
The obligation attaches to the battery, not to the finished product. If you sell an e-bike, the battery in it is an LMT battery and needs a passport regardless of the fact that you consider yourself a bicycle retailer. The same logic catches portable power stations, e-scooters, and larger cordless garden equipment.
This is the single most common way a merchant discovers they are in scope. Run the check on capacity and category, not on how the product is merchandised.
Timeline for Batteries
- 17 August 2023 Batteries Regulation (EU) 2023/1542 enters into force.
- 18 February 2024 General application of the Regulation begins.
- 18 August 2024 Chapter VI economic operator obligations start to apply.
- 18 August 2025 Old Batteries Directive repealed. Separate-collection and Cd/Pb labelling symbols become mandatory — these are hard dates and are already live.
- 18 August 2026 Three implementing and delegated acts fall due — the definition of “legitimate interest” for restricted passport data, the recycled-content methodology, and the labelling act. None adopted as of 21 July 2026.
- 18 February 2027 Battery passport mandatory for LMT, EV and industrial >2 kWh. Article 11 removability rules and the Article 13(6) QR code requirement on all batteries also apply from this date.
- 18 August 2027 Due diligence obligations apply, after a two-year delay. Exempt below EUR 40 million net turnover.
- 18 August 2031 First recycled-content thresholds bite: 16% cobalt, 85% lead, 6% lithium, 6% nickel.
Data the passport has to carry
Annex XIII splits the passport into four access tiers, not the three that most summaries describe. The distinction matters because only the first tier is public — the rest is visible to specified actors, and one tier is per-individual-battery rather than per-model.
The table below covers the public tier, which is what will appear on your product page. It is long, and every row of it has to come from somewhere upstream.
| Field | What it means in practice | Status |
|---|---|---|
| Unique identifier & QR | A unique identifier reachable from a QR code on the battery, complying with ISO/IEC 15459 parts 1–6 or equivalent. | In force |
| Material composition | Chemistry, hazardous substances other than mercury, cadmium and lead, and critical raw materials present. | In force |
| Carbon footprint | In kg CO₂e per kWh of total energy provided over the expected service life, broken down by life-cycle stage — plus the manufacturing plant's geographic location. See the caution below: the underlying methodology is not yet adopted. | In force |
| Responsible sourcing | Drawn from the due diligence report. Covers cobalt, natural graphite, lithium and nickel. | In force |
| Recycled content | Share of recycled cobalt, lead, lithium and nickel recovered from waste, present in the active materials. | In force |
| Renewable content | Share of renewable material content. | In force |
| Electrical performance | Rated capacity in Ah, minimum/nominal/maximum voltage, original power capability in W, internal cell and pack resistance, initial round-trip efficiency and efficiency at 50% of cycle life. | In force |
| Lifetime & durability | Expected lifetime in cycles with the reference test used, the c-rate of the cycle-life test, temperature range when not in use, and the commercial warranty period for calendar life. | In force |
| Capacity threshold for exhaustion | Electric vehicle batteries only. | In force |
| Conformity & end-of-life | Marking requirements, the EU declaration of conformity, and waste-battery prevention and management information. | In force |
What this means if you sell batteries on PrestaShop
Three things determine how much of this is actually yours.
1. Are you the one placing it on the market?
If you buy e-bikes from an EU distributor and resell them, the passport is the manufacturer's or importer's obligation. If you import them yourself from outside the EU, you are the importer and the obligation is effectively yours. If you sell them under your own brand, you are treated as the manufacturer outright. See who carries the obligation.
2. Even as a pure reseller, you have to surface it
ESPR Article 31 makes the dealer responsible for ensuring the passport is easily accessible to customers and potential customers, including in distance selling. "Potential customers" means before purchase — on the product page, not in the box.
You have a legal hook for getting what you need: under ESPR Article 10(3), the operator placing the product on the market must give dealers a digital copy of the data carrier or the unique product identifier, free of charge, within five working days of your request. If a supplier is stalling, that is the provision to cite.
3. Your listings need the operator details
Article 36 requires distance-selling offers to show the manufacturer's name and postal and electronic address — and where the manufacturer is not established in the EU, the name, postal and electronic address and telephone number of the EU-based responsible person. If you import batteries from outside the EU and no EU responsible person exists, the product cannot lawfully be placed on the market, and you may have to be that person yourself.
How to prepare now
Start with a capacity and category audit
Export your catalogue and flag anything containing a battery. For each, record the chemistry, the capacity in Wh or kWh, and whether it is LMT, industrial, EV, portable or SLI. This is a half-day of work that tells you whether 18 February 2027 is your problem or not.
Then find out who your responsible operator is, per line
For every in-scope battery line, establish in writing who places it on the EU market. Merchants routinely discover that a supplier they assumed was an EU distributor is actually shipping direct from outside the EU, which changes the answer entirely.
Request the passport assets now, in writing
Ask each supplier for their battery passport readiness, the unique identifier scheme they will use, and a digital copy of the data carrier. Cite the five-working-day rule. Suppliers who cannot answer this in mid-2026 are unlikely to be ready by February 2027, and that is information you want now rather than in January.
Plan the product page display
Whatever the supplier provides, you need somewhere to put it. A passport panel and a link on the product page is the deliverable. See showing a passport on a PrestaShop product page.
Do not assume the carbon footprint figure will exist. Every Article 7 carbon footprint obligation is drafted as applying from a fixed date or a set period after the relevant delegated act enters into force, whichever is the latest. Because neither act has been adopted for any battery category, no carbon footprint declaration obligation has yet been triggered — the EV methodology act was due in February 2024 and is around two and a half years overdue. A great deal of commentary states that industrial battery carbon footprint declarations became mandatory in February 2026. They did not.
Questions
I sell e-bikes. Do I need a battery passport?
What about ordinary AA batteries or phone batteries?
Is the 2 kWh threshold on the cell or the pack?
Where does the passport data have to be hosted?
Can the same passport cover a whole model, or does each battery need its own?
Sources
Other product groups
Textiles & apparel
First named priority under ESPR, and already subject to the unsold-goods destruction ban that took effect in July 2026.
Tyres
A priority group with an indicative 2027 act, and one that already carries mandatory EU labelling.
Electronics & appliances
Not one group but many. Electronics come in through energy-related products and horizontal rules, on a schedule running from 2026 to 2030.
Get the data before you need the passport
Whatever your product group, the bottleneck is the same: supplier data you do not have yet. The readiness checklist tells you what to start asking for.