On February 18, 2027, every new drive battery will be assigned a QR code and a digital file. Most guides explain what is included in this battery passport. For manufacturing, however, another question arises: Will you still be able to document how this particular battery was built and tested nine years from now, if the MES system in which the data was generated has been replaced by then?
KEY POINTS AT A GLANCE
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The Battery Regulation (EU) 2023/1542 governs carbon footprint, recycled content, and due diligence obligations in the supply chain. For quality and production managers in battery and module manufacturing, it also includes data and record-keeping requirements that remain in effect long after delivery.
The following section explains how the Battery Passport retention requirement relates to the other deadlines in the regulation, what production data it involves, and what an archive must be capable of to ensure this data remains admissible as evidence even after a system change. The section concludes with a five-step roadmap leading up to February 2027.
IN A NUTSHELL
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What will the Battery Passport require starting February 18, 2027?
The Battery Passport is an electronic record assigned to an individual battery throughout its entire life cycle. The legal basis is Article 77 of the Battery Regulation (EU) 2023/1542. Starting February 18, 2027, every light-duty battery placed on the market or put into service, every industrial battery with a capacity exceeding 2 kWh, and every electric vehicle battery must have such a passport.
| Key Figure | Meaning | Source |
|---|---|---|
| February 18, 2027 | Effective Date for Battery Passport | Art. 77(1) of Regulation (EU) 2023/1542 |
| > 2 kWh | Threshold for industrial batteries | Art. 77(1) of Regulation (EU) 2023/1542 |
| 10 years | Technical documentation and declaration of conformity | Art. 38(4) of Regulation (EU) 2023/1542 |
| 10 years | Supplier and customer data | Art. 46 of Regulation (EU) 2023/1542 |
The passport can be accessed via a QR code on the battery. This QR code is linked to a unique identifier assigned by the economic operator placing the battery on the market (Art. 77(3)). Each individual battery therefore requires a unique identifier.
In terms of content, the Regulation distinguishes between information on the battery model and specific information on the individual battery, including information derived from its use (Annex XIII). This includes, among other things, information on the CO₂ footprint, the origin of raw materials, chemical composition, recyclability, the manufacturer, charge cycles, and disposal.
Paragraph 5 is relevant to the IT architecture. All information in the battery passport must be based on open standards, be interoperable, machine-readable, structured, and searchable, and remain transferable without being tied to a specific provider (Art. 77(5)). For the data model, the Asset Administration Shell (AAS) has established itself as the common foundation, supported by IDTA, Catena X, and the Battery Pass Project. DIN DKE SPEC 99100 describes the requirements for data content.
Regulation (EU) 2025/1561 has postponed the due diligence requirements in the raw materials supply chain to August 18, 2027. The deadline for the Battery Pass in February 2027 is not affected by this.
Who is responsible?
The economic operator who first places the battery on the market in the EU is responsible for its accuracy and completeness. This obligation is tied to the act of placing the product on the market; the place of manufacture is irrelevant. For automotive suppliers who deliver modules or packs to an OEM, this means: They are often not the passport holders themselves, but they provide a significant portion of the data on which the passport and the placing-on-the-market operator’s declaration of conformity are based.
What retention periods does the Battery Regulation specify?
Article 77 does not specify a number of years for the retention requirement regarding the battery passport. The retention periods are set forth in other articles of the regulation. The table summarizes the retention periods under the Battery Regulation and their legal basis.
| Requirement | What Must Be Retained | Duration | Legal Basis |
|---|---|---|---|
| Technical documentation | Documentation pursuant to Annex IX regarding the design, manufacture, and testing of the battery | 10 years from the date of placing on the market | Art. 38(4) |
| EU Declaration of Conformity | Declaration of compliance with the requirements of the Regulation | 10 years from the date of placing on the market | Art. 38, para. 4 |
| Supplier and Customer Data | Suppliers, customers, battery models sold, and quantities | 10 years | Art. 46 |
| Battery Passport | Model and individual battery information in accordance with Annex XIII | until the battery is recycled | Art. 77, para. 8 |
| Availability in the Event of the Actor’s Cessation of Operations | The battery passport remains accessible even if the responsible party no longer exists | indefinitely until recycling | Art. 78 |
Manufacturers must keep the technical documentation specified in Annex IX and the EU Declaration of Conformity available to national authorities for ten years from the date the battery is placed on the market (Art. 38(4)). Separately, Article 46 requires all economic operators to be able to provide information about their suppliers and customers—including the battery models and quantities sold—for a period of ten years.
Violations may result in fines. Under German battery law, it is classified as an administrative offense if the aforementioned documents are not kept available for at least ten years or if information required under Article 46 cannot be provided for a period of ten years.
The time limit applies per battery, not per plant
The ten-year period begins when the respective battery is placed on the market. A production line operating from 2027 to 2035 will therefore be subject to reporting requirements until at least 2045. Manufacturers of automotive batteries must also comply with the record-keeping requirements of IATF 16949 (Section 7.5.3.2.1): Records must be retained for as long as the product is active for production and service requirements, plus one calendar year.
In addition, there are the general commercial and tax law retention periods under the German Commercial Code (HGB) and the German Fiscal Code (AO) for business records. An overview of these retention periods and their interaction with the GDPR can be found in the article “Retention Periods under the HGB, GDPR, and GoBD.”
Why does battery data outlast the systems that generate it?
The data on which the battery passport and technical documentation are based is generated in production control systems, test benches, quality assurance databases, and ERP systems. These systems are typically replaced well before the battery is phased out of the market.
| Object | Typical Life Cycle | Impact on Traceability |
|---|---|---|
| Battery in a vehicle | Use, followed by a potential second life until recycling | Certificates and documentation must remain available throughout the entire chain |
| MES and line computers | Replacement during line retrofitting, model changes, or version updates | Historical data is stored in a system that is no longer maintained |
| Quality assurance and inspection database | The database is constantly growing; migrations and version updates | Performance declines; legacy data is offloaded or deleted |
| Database format and licensing | Version changes, licensing model, cloud migration | Without a license and the legacy system, there is no read access to the raw data |
The regulation also governs secondary use. If a battery is prepared for a new use or repurposed, it requires a new battery passport that is linked to the passport of the original battery (Art. 77, para. 7). The passport is deleted only after the battery has been recycled (Art. 77, para. 8). A battery manufactured in 2027 that is later used in a stationary storage system may therefore still raise questions about its origin in the coming decade.
Added to this is product liability. The new Product Liability Directive (EU) 2024/2853 must be transposed into national law by December 9, 2026, and places greater emphasis on software and digital manufacturing records. Anyone seeking to prove in a liability case that a specific battery was manufactured and tested correctly will need the process and test data for that exact battery, not just statistics from the production line.
PRACTICAL MISTAKE: CONFUSING A BACKUP WITH AN ARCHIVEA database backup preserves a state for recovery. It is neither searchable by individual battery nor protected against modification, and after a system change, it can often only be reopened using the old database server. A backup therefore does not constitute evidence for an inspection by market surveillance authorities. The article “Backup vs. Archiving” explains the difference. |
WHITE PAPER: DATA GOVERNANCE FOR STRUCTURED DATABattery data remains verifiable for ten years or longer only if there are clear rules governing who owns it, who is authorized to modify it, and when it is to be deleted. This white paper shows how to establish these rules for production and quality data before a market surveillance audit takes place. |
What production data underlies the battery passport and certificate of conformity?
Not all manufacturing information belongs in the Battery Passport. Much of the content specified in Annex XIII consists of model data, supply chain information, or sustainability details. However, the ability to provide evidence in the event of an audit depends on a second, internal level of data: the manufacturing and testing data that prove that the individual battery was built exactly as described in the technical documentation.
| Data Class | Examples | Reference | Recommended Granularity |
|---|---|---|---|
| 1. Identification | Battery identification, serial numbers of cells, modules, and packs, date of manufacture, plant | Art. 77(3), Annex XIII | per battery |
| 2. Material and Batch | Cell batch, supplier, material certificates | Art. 46, Annex XIII | Per batch, linked to serial number |
| 3. Process data | Screw and fastening data for module assembly, welding parameters, adhesive processes | Technical documentation in accordance with Annex IX, product liability | Per battery and process step |
| 4. Test data | EOL (End of Line) testing, leak testing, insulation testing, capacity testing | Technical documentation, conformity assessment | per battery, including limit values and results |
| 5. Changes and Deviations | Rework, special approvals, test plan versions | IATF 16949, product liability | Per event, with timestamp and approval |
Everything depends on the link established through the unique identifier. If a pass refers to a serial number for which no one can find the inspection result anymore, it still exists but does not serve as evidence in the event of an inspection. The article “Data Model for Traceability: Required Fields” describes how to define the required fields for a reliable link. “Traceability in Production” summarizes the basics of seamless traceability across the production line.
An example from battery manufacturing illustrates the project for fail-safe process data storage in battery production. “Quality Assurance in Battery Manufacturing” addresses the quality requirements in this environment.
What are the four errors that jeopardize the traceability of battery data?
From archiving projects in the manufacturing industry, we have identified four patterns that formally comply with retention requirements but still fail when audited.
- The data remains in the production system. The QA database grows year after year, eventually slows down, and then someone deletes old records—often without checking against the retention periods specified in the Battery Regulation.
- The legacy system is shut down. During a production line overhaul or MES migration, only part of the historical data is transferred to the new system. The rest remains in a database for which there is no server, no license, and no point of contact.
- The data is exported as a file without context. A CSV or PDF export contains the measured values, but not which test plan version and which limit values applied, nor who approved them.
- There is no data retention policy. Storing everything indefinitely conflicts with the GDPR’s storage limits as soon as personal data—such as worker IDs—is included, and results in ongoing costs for storage and licenses.
The article “Costs of Non-Archiving and Liability ” calculates the costs of not having an archive in the event of an emergency.
What requirements must a battery data archive meet?
Six requirements for a battery data archive can be derived from Articles 38, 46, 77, and 78 of the Battery Regulation. These requirements apply regardless of which software provides the battery passport itself and translate the battery passport retention requirement into verifiable technical requirements.
| Requirement | What it means | Derivation |
|---|---|---|
| 1. Immutability | Archived data records cannot be modified retroactively; every action is logged | Evidential value for authorities; GoBD principles |
| 2. Query per battery | All data associated with a serial number can be retrieved in a single query without accessing the source system | Art. 38, para. 4; Art. 77, para. 3 |
| 3. Independence from the source system | Data remains readable after the MES, database server, and license have been shut down | Art. 78, System Lifecycle |
| 4. Open, structured formats | Machine-readable and exportable without vendor lock-in | Art. 77, para. 5 |
| 5. Time-controlled deletion | Deletion upon expiration of the retention period, documented and rule-based | Art. 5(1)(e) GDPR |
| 6. Role-Based Access | Quality, Compliance, and Service teams have access without an IT ticket and without write permissions | Art. 78, access rights pursuant to Annex XIII |
If the inspection data for a serial number can no longer be located, even a fully completed battery passport will be of no help in the event of an audit.
You can find selection criteria for a solution in the article “How to Choose Audit-Traceable Archiving Software Correctly.” “Archive Access Without an IT Ticket” shows how departments can access data directly without going through IT.
How does CHRONOS ensure that battery data is available in an audit-compliant manner?
CHRONOS does not create a battery passport and does not replace a battery passport platform. CHRONOS is the archiving module of the Manufacturing OS. It ensures that the production, testing, and documentation data on which the battery passport and technical documentation are based remain available and admissible as evidence throughout the entire retention period. In this way, CHRONOS covers the portion of the battery passport retention requirement that arises during manufacturing.
CHRONOS archives closed data records from MES, QA, and test databases in an audit-proof manner. This keeps the production database lean and fast. The archived data remains retrievable even long after the source system has been shut down. This allows for the planning of legacy system archiving prior to a system migration, rather than having to recover data from a decommissioned server afterward.
Quality and compliance teams can access all data associated with a serial number via departmental access, without needing to submit an IT ticket. Retention rules can be defined for each data class, and once the retention period expires, CHRONOS deletes the data in a controlled and documented manner.
When switching MES systems or migrating to the cloud, you only transfer what is needed for operations. The rest remains in the archive and can still be used as supporting documentation. The article on selective archiving during cloud migration explains how this works.
The KLS Martin Group’s user story describes how a medical technology company uses CHRONOS to secure application data.
Roadmap: Five steps to achieve verifiable compliance by February 2027
There are just over four months left until the deadline. The five steps relate to data management and will proceed in parallel with the selection of a battery passport platform.
- Clarify your role. Are you a distributor, manufacturer, or data provider for an OEM? This determines which obligations under Articles 38, 46, and 77 apply directly to you and which are passed on contractually.
- Take inventory of your data sources. For each of the five data classes, identify which system currently stores the data, how long it is retained there, and when the system will be replaced.
- Ensure a unique identifier is consistently applied. Verify that every process and test record can be traced using the battery identifier, even across cells, modules, and packs.
- Set retention periods for each data class: at least ten years from the date of market release; in the automotive sector, additionally in accordance with IATF 16949, with a clear deletion rule for the end of each retention period.
- Set up the archive before the next system change. The easiest way to archive legacy data is while the source system is still running—that is, before the next MES release or migration.
The principles of proper data retention are explained in the article “GoBD-Compliant Archiving: Requirements and Implementation.”
Frequently Asked Questions About the Battery Passport
When does the Battery Passport become mandatory?
The Battery Passport will be mandatory starting February 18, 2027. As of that date, every affected battery placed on the market or put into service must have a digital Battery Passport that can be accessed via a QR code (Art. 77 of Regulation (EU) 2023/1542).
Which batteries require a battery passport?
Electric vehicle batteries, batteries for light-duty vehicles such as e-bikes and e-scooters, and industrial batteries with a capacity of more than 2 kWh require a battery passport. Device batteries such as coin cells or AA cells are not affected.
How long must battery manufacturers retain technical documentation?
Manufacturers must make the technical documentation specified in Annex IX and the EU Declaration of Conformity available to national authorities for ten years from the date the respective battery was placed on the market (Art. 38, para. 4). Information about suppliers and customers must also be retained for ten years, in accordance with Art. 46.
What happens to the battery passport after recycling?
The battery passport is deleted as soon as the battery has been recycled (Art. 77(8)). Until then, it must remain available, even if the responsible economic operator no longer exists or ceases its activities in the EU (Art. 78).
Does a “second-life” battery need a new battery passport?
Yes. If a battery is prepared for a new use, repurposed, or remanufactured, it requires a new battery passport that is linked to the battery passport of the original battery (Art. 77, para. 7). The history thus remains part of the chain of custody.
Does CHRONOS create the battery passport?
No. CHRONOS is a solution for audit-proof database archiving. It keeps the production, testing, and documentation data—on which the battery passport and technical documentation are based—accessible throughout the entire retention period, even after the source system has been shut down.
Is a backup sufficient as proof of compliance with the Battery Regulation?
Generally not. A backup preserves a system state for recovery purposes, but it is neither searchable by individual battery nor protected against modification, and is often readable only on the original database server. To meet the retention requirements of the Battery Regulation, an audit-proof, searchable archive is required.
Conclusion: Implementing the Battery Passport Retention Requirement in Manufacturing
The battery passport retention requirement takes effect on February 18, 2027, and extends well beyond the date of delivery. Technical documentation and the declaration of conformity must be retained for ten years, as must supplier and customer data, and the passport itself remains valid until the battery is recycled. During this period, an MES or QA database is typically replaced at least once.
Those who take stock of their data sources now, consistently link the battery identifier, and set up the archive before the next system change will be able to use the same data for product liability cases, recalls, and audits in accordance with IATF 16949.
