EUBR Breakdown: Battery Passport vs QR Code Requirements - What Are the Differences and Which Battery Types Are Subject to Each

Do you know whether your batteries are subject to the EU Battery Regulation's Battery Passport or its QR code requirements? This distinction is critical as it is dependent on battery type, and it changes the types of data that must be collected, stored and kept up to date.

The primary distinction between the Battery Passport and the QR code requirements is the data that operators must store behind the QR code. The Battery Passport will require operators to map the supply chain for their batteries and store 71 specific data points behind the QR code as outlined in the Passport guidance. The QR code requirements will similarly require operators to map the supply chains for their batteries and conduct due diligence on those batteries per yet to be published guidance. A report regarding the due diligence conducted must be stored behind the EUBR QR code; however, the due diligence requirements for EUBR currently go into effect August 2027 (after the QR code requirement goes into effect). The QR codes must also store identifying information regarding the battery manufacturer, weight, capacity, chemistry, hazardous substances, and critical raw materials. 

EUBR Battery Passport - Scope, Timeline & Overview of Requirements

• Timeline: Goes into effect February 2027

• Scope: Light means of transport (LMT) batteries, electric vehicle batteries and industrial batteries with a capacity greater than 2 kWh ONLY. There are currently no plans to expand scope to other battery types.

• The Battery Passport will be the electronic record for individual batteries in scope. Accessible via QR code linked to a unique identifier. 

• Must include 71 data points relevant to Battery Passport. Intended to make relevant information related to the battery value chain publicly available. Economic operators are responsible for ensuring information stored via the Battery Passport is accurate, complete and up to date. 

• Updated guidance for the EUBR Battery Passport was published on August 21st. This published guidance only applies to the Battery Passport requirements and not the QR code requirements.

EUBR QR Code Requirements - Scope, Timeline & Overview of Requirements

• Timeline: Goes into effect February 2027. Note that due diligence obligations, which will impact content of QR code, still go into effect August 2027. Intent is that operators set up QR codes, input other required data elements by February 2027 deadline and then update the QR codes with due diligence reports by the August 2027 deadline.

• Scope: portable batteries and other batteries outside of the Battery Passport scope 

• Like the Battery Passport, the QR code will be the electronic record for individual batteries in scope. Also accessible via QR code linked to a unique identifier.

• Under Article 13(6) of the EUBR, the QR code must provide access to the relevant information applicable to that battery, including:

  • The applicable labelling and marking information, including the manufacturer, battery category and identification, place and date of manufacture, weight, capacity, chemistry, hazardous substances, and critical raw materials, where relevant. 

  • The EU Declaration of Conformity.

  • Information on the prevention and management of waste batteries, including separate collection, take-back and collection points, treatment and recycling, safe handling, and the environmental and health impacts of substances contained in batteries.

  • The report on the battery due diligence policy, where the relevant due diligence requirements apply (by August 2027)

• Updated guidance not yet published. Publication date to be announced.

  
  

To learn more about how Sourcemap can support your business with your obligations under the EU Battery Regulation, reach out to our team of experts today.