EU Battery Regulation · Industrial & stationary storage

The battery passport for energy storage.

Reg. (EU) 2023/1542 · industrial batteries >2 kWh in Article 77 scope · from 18 February 2027 · second-life linkage under Art 77(7).

Grid-scale and commercial energy storage runs on exactly the batteries Article 77 covers: industrial batteries above 2 kWh. From 18 February 2027 they need passports — and because storage is where retired EV packs go for a second life, storage integrators inherit the Article 77(7) linked-passport problem more than anyone else in the chain.

Reg. (EU) 2023/1542>2 kWh industrial18 Feb 2027Art 77(7) linkageAnnex XIII telemetry
What the rule requires

A passport that lives as long as the asset does.

Passports for >2 kWh industrial batteries

Composition, capacity, expected lifetime and performance data, QR-accessible — for each battery placed on the EU market from the date.

Longitudinal telemetry

Annex XIII expects state-of-health and operating data over time. A 15-year storage asset needs a passport platform, not a shipping label.

Second-life genealogy

Racks built from repurposed EV modules need new passports linked to every donor pack's passport — Article 77(7)'s many-to-one requirement lands hardest on storage.

Module-level identity inside the rack

Modules get replaced across a storage system's life. Identity at module level is what keeps the passport truthful after year three's first swap-outs.

The dates

The timeline, as it stands.

Storage projects commissioning after February 2027 will procure passported batteries; projects using second-life modules need genealogy from donors that retire before then. Procurement teams feel this before compliance teams do.

Battery passport18 Feb 2027
Second-life linkage (77(7))with Art 77
Storage build-outthrough 2030
What to do now

Three moves that de-risk the deadline.

01 · Step

Put passports into procurement specs

BESS integrators buying cells and modules for 2027 delivery should require passport data readiness in supplier contracts today.

02 · Step

Solve module identity before rack assembly

Tag modules at intake — new or harvested — so the system passport assembles from evidence, not spreadsheets.

03 · Step

Design the telemetry hand-off

Decide how BMS data reaches the passport record. Annex XIII's operating-data expectations assume that pipe exists.

How Aeroz fits

From donor pack to grid rack, one chain of custody.

Aeroz gives packs and modules chip-bound identities with custody written as EPCIS 2.0 events — harvest, test, rebuild, commission, swap. The storage system's passport links to its donors because the log proves it, and every module in the rack can be verified with a tap for the life of the asset.

FAQ

Battery passport for energy storage, answered.

Which storage batteries need passports?

Industrial batteries with capacity above 2 kWh placed on the EU market from 18 February 2027 — which covers essentially all commercial and grid-scale storage units.

How does this interact with second-life modules?

Directly: a repurposed battery needs a new passport linked to the original passports under Article 77(7). Storage is the main destination for retired EV packs, so integrators own this problem.

Does the BMS satisfy the passport requirement?

No — the BMS is a data source, not the passport. The passport is a regulated, QR-accessible record with defined content; a well-designed system feeds it from the BMS.

What happens when modules are replaced in service?

The passport should reflect the battery as it exists. Module-level identity makes replacements an append to the record rather than a divergence from it.

Readiness audit

Know exactly where you stand — in 14 days.

A fixed-fee Aeroz audit maps your products against battery passport for energy storage requirements and returns a written readiness assessment, a data-mapping review, and a scoped pilot plan with cost and timeline.

Fixed fee 14-day written report No commitment to proceed