Pixel QR frame linked to one battery registry record, with public, operator and authority reading lanes.
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EU battery passport QR code explained

Most people meet the EU battery passport as a sticker. A square on the pack. A phone camera. A page that opens.

That square is doing more work than it looks. Under Regulation (EU) 2023/1542, the QR code is the door to an electronic record for each in-scope battery. The record is the passport. The QR is how you find it.

Here is how that door is supposed to work, and what BPN (Battery Passport Network) does with it.

The QR is mandatory from 18 February 2027

Article 13(6) says that from 18 February 2027, all batteries must carry a QR code built to Annex VI Part C. What that code opens depends on the battery:

  • For LMT batteries, industrial batteries above 2 kWh, and electric vehicle batteries, the QR must open the battery passport under Article 77.
  • For other batteries, it opens labelling, conformity, due-diligence and waste information set out in Article 13, not a full Article 77 passport.
  • SLI batteries also expose recovered cobalt, lead, lithium or nickel amounts where Article 8 applies.

So "battery QR" is not one product. Passport batteries get a passport link. Everything else still gets a machine-readable mark, with a narrower payload.

Article 13(7) is practical: print or engrave the QR visibly, legibly and indelibly on the battery. Only if size or nature make that impossible do you fall back to packaging and accompanying documents. Annex VI Part C adds the boring-but-vital bit: high contrast, and readable by a common QR reader.

Unique identifier ≠ pretty URL slug

Article 3 defines a unique identifier as a unique string of characters that identifies the battery and enables a web link to the battery passport. Article 77(3) ties that identifier to the passport and expects it to follow the ISO/IEC 15459 series or an equivalent.

That split is easy to get wrong in a product roadmap:

  1. Identifier — stable identity for that physical battery.
  2. QR — data carrier that points at the passport for that identifier.
  3. Passport — the electronic record (model data + unit data) with access rules.

The European Commission's Battery Passport FAQ is blunt on who creates the identifiers: economic operators can mint them locally using the standards options, or use a commercial service. The identifiers live with the passport and get registered in the EU DPP Registry.

Important nuance from the same FAQ: the DPP Registry does not host your full passport. It stores registration and metadata (and helps authorities where the law says so). The passport itself is hosted by the economic operator who places the battery on the market, or by someone with written authorisation under Article 77(4). Responsibility stays with the operator who places the battery on the EU market.

Scanning is not a free-for-all

A public scan should not dump dismantling sheets, conformity test results and lifetime use data onto one open page.

Article 77(2) and Annex XIII still apply after the camera fires:

  • Public (Annex XIII point 1) — model facts anyone can read.
  • Legitimate interest (points 2 and 4) — detailed composition, spare parts, dismantling, safety, and individual-battery use / state-of-health data, for actors the Commission still has to pin down in the Article 77(9) implementing act.
  • Authorities / notified bodies (point 3, and restricted model data as written) — compliance evidence, not a marketing sheet.

The Commission's FAQ (section 6.3) confirms that the implementing act on restricted access was still being developed as of the September 2026 FAQ edition, with a draft expected for public feedback around October or November 2026. The February 2027 passport date does not wait for that act to finish your architecture.

In BPN, those audiences map onto entity types on the network. Each field on the battery registry record can be visible to some entity types and hidden from others. Same QR. Same record. Different view after you prove who you are.

What changes when the battery's life changes

Article 13 also says batteries that go through preparation for re-use, preparation for repurposing, repurposing or remanufacturing need new labels or markings, including the status change from Annex XIII point 4, still reachable through the QR.

Article 77(7) goes further for the passport itself: after repurposing or remanufacturing, you need a new battery passport linked to the previous one. A simple repair does not. The Commission's FAQ (section 9) lines that up with industry practice: new operator, new passport, lineage preserved.

If your QR only ever pointed at a static marketing page, you will rebuild this twice. If the QR points at a registry record that can grow fields, change status and open a linked second-life passport, you are closer to the regulation's shape.

How BPN treats the scan

BPN is a battery registry: one record per battery that manufacturers, installers, repairers, second-life operators, recyclers and auditors write to over time. It runs on a permissioned shared ledger (Hyperledger Fabric) and is still a pilot. Documents can attach when you need proof; they are not the passport.

For operators, the QR flow is then boring in a good way:

  1. Mint a unique identifier that fits ISO/IEC 15459 (or equivalent).
  2. Create the battery record in the registry (often from a model template).
  3. Mark the physical unit with a QR that resolves to that record.
  4. Register the passport metadata in the EU DPP Registry when your onboarding path requires it.
  5. Let entity-type access decide what a public scan, a recycler login or an authority credential can see.

That is the opposite of "keep files private and share a hash." The regulation wants a live record. The QR is how the physical world finds it.

FAQ

Does every battery get an Article 77 passport behind the QR?

No. From 18 February 2027 every battery gets a QR under Article 13(6), but only LMT batteries, industrial batteries above 2 kWh and EV batteries must open an Article 77 passport. Other categories open the Article 13 information set instead.

Who invents the unique identifier?

The economic operator (or a service they use). The Commission FAQ says you can create identifiers locally from the relevant standards options, or buy the service. Store them with the passport and register them in the DPP Registry.

If I scan a public QR, do I see state of health?

Not by default. State of health and use data sit in Annex XIII point 4 for persons with a legitimate interest, once the implementing act and your access checks say so. Public scans stay on the public layer.

Where does BPN fit next to the EU DPP Registry?

BPN holds the working battery record and enforces per-field access by entity type. The DPP Registry is the EU registration layer for passport metadata. They solve different jobs. If you make or import in-scope batteries for the EU market, see how BPN works or ask for a demo.

Sources

The deadline puts a square on every pack. The work is making sure that square opens one honest registry record, with the right fields for the right eyes.