(EU) 2023/1542
18 February 2027: what exactly happens, and what about stock in the warehouse
A great deal of approximation circulates around this date. The regulation itself is precise, and the precision matters here for one consequence: whatever sits in your warehouse on 18 February 2027 and has not yet been supplied cannot go to market after that date without a passport — regardless of when it was manufactured.
What Article 77(1) says verbatim
From 18 February 2027, each LMT battery, each industrial battery with a capacity greater than 2 kWh and each electric vehicle battery placed on the market or put into service shall have an electronic record. The operative phrases are “placed on the market” and “put into service” — not “manufactured”.
Why the definition decides the fate of your stock
The regulation defines placing on the market as the first making available of a battery on the Union market, and making available as any supply for distribution or use in the course of a commercial activity, whether for payment or free of charge. The trigger is therefore the first supply. A battery manufactured in 2026 and supplied in March 2027 is placed on the market in March 2027 — and needs a passport.
What about batteries supplied earlier
If a battery was first placed on the market before 18 February 2027, Article 77(1) does not apply to it. Two cautions, though: anyone who modifies a battery already on the market in a way that could affect compliance, or changes its purpose, takes on the manufacturer's role — and with it the obligations for that modified battery.
The QR code arrives on the same day
From 18 February 2027, Article 13(6) requires all batteries to be marked with a QR code per Part C of Annex VI. For LMT, industrial above 2 kWh and electric vehicle batteries, that code leads to the passport. Marking and the passport are therefore not two projects with two deadlines but one deadline with two delivery parts.
The practical consequence for planning
Stock you intend to supply after 18 February 2027 must have a passport. With long lead times this means the decision to prepare the data arrives well before the deadline itself — for batteries you order today for delivery next spring, that decision is now.
What we do not claim on this page
We do not state how any individual Member State will enforce this, nor what penalties will apply — those follow national law that we have not verified. Nor do we claim how customs will act in practice. We stay with what the regulation says and what can be derived from it.
What to do first
Check which duties are already running — there are eight, and some reach into product design where nothing can be fixed retrospectively. Only then plan the fields that fall due with the deadline. Sequence matters more than speed.
Check where you stand
The free check runs through every mandatory field for your battery category.
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