[Regulatory Update] EU Battery Regulation implementation takes shape ahead of the 2027 Battery Passport mandate — battery data management becomes the next focus

The EU Battery Regulation has already applied since 2024. What deserves attention as of 2026 is therefore not "the Regulation has begun" but the fact that future, concrete obligations are now moving into the implementation stage. In particular, the Battery Passport — a mechanism for digitally managing a battery's lifecycle information — becomes mandatory from 18 February 2027 for EV batteries, LMT batteries and industrial batteries above 2 kWh (portable batteries and starter batteries are excluded). The need to collect and manage battery lifecycle information is growing not only for battery manufacturers but also for materials, component and recycling businesses, and companies need to prepare the Battery Passport not merely as a regulatory reporting tool but as a data infrastructure connecting information from material sourcing through manufacturing, use, repair, reuse and recycling. Coverage should move on from the 2023–2024-era framing of "the EU Battery Regulation has launched" towards the phase now underway: from the base Regulation, through delegated and implementing acts, to implementation infrastructure and then concrete obligations.