LOOBA Circularity

Legal

Digital battery passport.

From 18 February 2027, each LMT battery, each industrial battery above 2 kWh and each electric-vehicle battery placed on the market or put into service must have an electronic record — the battery passport (Article 77).

Article 77

An electronic record for the life of the battery.

The passport contains model-level and individual-battery information, including data resulting from use, as set out in Annex XIII. Access is through the QR code required by Article 13(6), linked to a unique identifier attributed by the economic operator placing the battery on the market.

The operator placing the battery on the market must keep the information accurate, complete and up to date. The passport must remain available if that operator ceases activity in the Union. It ceases to exist after the battery has been recycled.

Digital Battery Passport

—days remaining

Mandatory from 18 February 2027 for LMT batteries, industrial batteries above 2 kWh and EV batteries (Article 77).

Wider DPP framework

The battery passport is the first legally fixed Digital Product Passport.

A Digital Product Passport (DPP) is a structured electronic record that links a physical product to origin, composition, compliance, environmental performance and end-of-life data. The Ecodesign for Sustainable Products Regulation — Regulation (EU) 2024/1781 — makes DPPs the general instrument for most physical goods, through product-specific delegated acts. Batteries do not wait for those acts. Their passport is already set in Regulation (EU) 2023/1542, Article 77, from 18 February 2027.

Battery Regulation

Binding passport for LMT and EV batteries, and for industrial batteries above 2 kWh. This is the near-term legal deadline for LOOBA counterparties.

ESPR / DPP registry

By 19 July 2026 the Commission must set up the DPP registry (ESPR Article 13). It stores unique identifiers — including those for batteries under Article 77(3) — not proprietary passport content.

Interoperability

Article 78 requires the battery passport to be interoperable with other digital product passports required by Union eco-design law — open standards, machine-readable, no vendor lock-in.

ESPR also amends Article 77: the economic operator that places the battery on the market or puts it into service must upload the unique identifier to that registry. The registry deadline is a Commission infrastructure date. The battery passport obligation itself remains 18 February 2027 — 2026 is the year to assemble data, identifiers and QR workflows, not the year the passport is already mandatory.

In scope

Which batteries need a passport.

  • LMT batteries

    Light means of transport batteries placed on the market or put into service from 18 February 2027.

  • Industrial batteries > 2 kWh

    Including stationary energy storage (BESS) above the capacity threshold.

  • Electric-vehicle batteries

    EV batteries placed on the market or put into service from the same date.

From the same date, all batteries must be marked with a QR code. For batteries outside the passport categories, that code gives access to labelling, conformity and waste-management information rather than a full Article 77 passport. The 2 kWh threshold applies to industrial batteries. LMT and EV batteries are in scope of the passport without that capacity test.

Responsibility

Who must issue and maintain it.

Economic operator placing the battery on the market

That operator attributes the unique identifier, ensures the QR code links to the passport, and keeps the data accurate and current (Article 77(4)). It may authorise another operator in writing to act on its behalf. For an EU manufacturer, that is typically the manufacturer.

Importers, second life and recycling

Where the manufacturer is established outside the Union, the importer that places the battery on the EU market carries the placing-on-the-market duties. After preparation for re-use, repurposing or remanufacturing, a new passport is required, linked to the original (Article 77(7)). After recycling, the passport ceases to exist.

Content

What the passport carries.

Annex XIII sets the data fields. Public and restricted access are separated: regulators, economic operators and end-users see only the layer assigned to them. A passport is not a static PDF or a marketing page. Article 77(5) and Article 78 require open standards, an interoperable format, machine-readable structured data, and controlled access.

  • Battery identification and unique identifier
  • Composition and critical raw materials
  • Carbon footprint information (where required)
  • Recycled content
  • Performance and durability parameters
  • Due-diligence / responsible sourcing
  • Collection, treatment and recycling information
  • State of health and use data (restricted access)

LOOBA

Passport-linked EPR. Operations as an option.

LOOBA is not a passport issuing authority. The base product records batteries against the unique identifier so EPR financial assurance sits alongside the electronic record. End-of-life treatment under LOOBA is the point at which that record, under Article 77, ceases after recycling.

Producers who already have a host share the identifier. Producers who do not can add passport operations to the EPR contract — identifier, QR, register upload and lifecycle updates — under written authorisation, delivered with a specialised operator. LOOBA does not build a competing host, and does not couple vendor by vendor.

Open Regulation (EU) 2023/1542Open ESPR (EU) 2024/1781EU Battery Regulation overviewFor passport operatorsFor producers

Orientation for professional counterparties. Not legal advice.