Reg. (EU) 2023/1542 · Article 77(7) · a repurposed battery needs a new passport linked to the passport(s) of the original batteries.
Second-life battery projects harvest modules from many retired EV packs and rebuild them into storage systems. Article 77(7) requires the rebuilt battery's passport to link back to every original passport. That is a genealogy requirement — and it cannot be met at scale if identity only exists at pack level, because the pack identity dies when the pack is opened.
Article 77(7): a battery put to a new use gets a new passport linked to the original battery passports — many-to-one genealogy when modules from several packs are combined.
Annex XIII expects exploded diagrams, disassembly sequences, and cell count and layout — information that presumes the parts inside are identifiable.
Cycle counts, incident history and operating conditions determine a module's second-life value. Without identity, that history is lost the day the pack is opened.
Second-life economics run on state-of-health confidence. A module that can prove its history commands a price; an anonymous module is scrap with ambitions.
The obligation lands with the passport itself: batteries and their repurposed descendants placed on the market from 18 February 2027. Projects being engineered now decide whether compliance is possible later.
Genealogy must exist before disassembly. Module-level identity applied at manufacture — or at collection — is what makes the 77(7) linkage possible at all.
Each harvest, test and rebuild step should append to the custody log, so the new passport's link to its ancestors is evidence, not assertion.
Before rebuilding, define what the storage system's passport must carry and where each field comes from. Retrofitting genealogy after assembly is guesswork.
Aeroz gives packs and modules chip-bound identities with custody written as EPCIS 2.0 events — so when a pack is opened, each module carries its own provable history into the rebuilt system, and the new passport's Article 77(7) linkage assembles itself from the log. This is the gap in the mandate: the law requires the outcome and specifies no means. We build the means.
That a battery prepared for re-use, repurposing or remanufacturing carries a new battery passport linked to the passport or passports of the original battery or batteries. The plural matters: rebuilt systems combine modules from many source packs.
Because the pack's QR marks the pack. Once opened, its modules carry no mandated identity of their own — and a storage rack built from thirty packs' modules has no honest way to link back to thirty passports.
No — that is the gap. The regulation requires the linked-passport outcome without specifying the means. Module-level identity is how the outcome becomes achievable at industrial scale.
The economic operator placing the repurposed battery on the EU market. Second-life integrators, remanufacturers and the OEMs supplying them all inherit a piece of the answer.
A fixed-fee Aeroz audit maps your products against battery passport for second life requirements and returns a written readiness assessment, a data-mapping review, and a scoped pilot plan with cost and timeline.