Battery passport: the Commission moves to EN 18219 and EN 18220

What the text actually changes

The draft has two operative articles. Article 2(1) replaces the second subparagraph of Article 77(3) of Regulation (EU) 2023/1542 with one sentence:

> The QR code shall comply with EN 18220:2026 and the unique identifier shall comply with EN 18219:2026, or their equivalent.

Article 3 sets entry into force on the twentieth day following publication in the Official Journal. Nothing else in the draft concerns the passport, apart from Annex II, which amends Annexes IV, V and VII of the Regulation on technical parameters.

The rest of the text is about something else: minimum values for the electrochemical performance and durability of rechargeable industrial batteries above 2 kWh, excluding those with exclusively external storage.

Why two passport standards sit inside a batteries regulation

Until now the Batteries Regulation and the Ecodesign Regulation have had separate technical stories. The battery passport relies on Article 77(3), which points to the ISO/IEC 15459 series for the unique identifier. The ESPR passport relies on harmonised standards whose references the Commission published on 15 July 2026, through Implementing Decision (EU) 2026/1736.

That decision lists six standards, and two of them are exactly the ones the draft picks up:

The consequence is easy to state and heavy to implement: once the act applies, a manufacturer selling both batteries and products covered by the ESPR can use a single identifier and a single carrier for both regimes. One architecture, two obligations.

The calendar gap nobody has closed yet

The battery passport obligation starts on 18 February 2027 for electric vehicle batteries, light means of transport batteries and industrial batteries above 2 kWh. That date is set by the Regulation itself, and neither of the standards the draft picks up is the one Article 77(3) currently points to.

As of our check on 20 October 2026, no act has been adopted: the text is still a draft delegated regulation, open for feedback until 27 October 2026. Feedback published on 8 October 2026 by TracePass, a battery passport provider based in Bulgaria, states that the Commission expects to adopt the act later in 2027, after the 18 February deadline.

The same submission raises the practical problem: batteries placed on the market between 18 February 2027 and the act's entry into force will carry codes and identifiers that comply with the standards Article 77(3) references today. The draft has no transitional provision, and its recital 10 does not address them. Must those batteries be relabelled, or will their compliance be treated as equivalent? The text does not say.

This is the point to watch if you make batteries: the question is not whether the standards change, but whether codes already applied will remain valid.

What it changes for a manufacturer, starting now

Three decisions are worth taking before the end of the year, because their lead times in procurement and tooling are longer than a regulation's publication cycle.

1. Pick an identifier that works in both worlds. An identifier compliant with the ISO/IEC 15459 series remains the legal basis until the act applies. If your identification scheme can also conform to EN 18219, you avoid a migration in 2027.
2. Check the carrier, not just the code. EN 18220 is about data carriers, not about QR symbology alone. A code that reads today is not necessarily compliant with the standard that will apply tomorrow.
3. Document equivalence from day one. The text keeps the phrase "or their equivalent" without defining what counts as equivalent. Until the Commission clarifies it, the demonstration rests on the manufacturer, and it is built with dated evidence, not with a declaration.

What else the draft contains

The performance and durability part deserves a look, even though it has nothing to do with the passport.

The draft sets minimum values for four parameters: capacity fade, expected lifetime in cycles, expected lifetime in years and energy round-trip efficiency. The thresholds depend on the category: residential battery energy storage systems, repetitive energy supply batteries, on-demand batteries, and lead-based batteries, which are treated separately because of their inherent characteristics.

Two technical changes touch the passport indirectly. Annex V is amended so that internal short circuit is addressed through thermal propagation protection rather than as a stand-alone test. Annex VII, Part A, point 4, replaces the requirement on the evolution of self-discharging rates with a conditional formula: "where possible". Passport operators are waiting for a convention on what to display when the value cannot be determined, an empty field or an explicit statement.

How to weigh in before 27 October

Public feedback is open until 27 October 2026 at midnight Brussels time, on the Commission's Have your say portal. Eight contributions were published as of our check on 20 October 2026.

Two lines of argument stand out. Identification players ask for precision, particularly on which identifier schemes EN 18219 covers and on carriers other than QR codes. Passport providers mostly ask for a transitional provision, because their production calendar does not follow the legislator's.

If you are affected, the submission does not need to be long. A dated use case, with the equivalence question stated plainly, weighs more than a general position.

What to remember

The battery passport is not changing its content. It is changing its technical basis, and it is moving to the standards already used by the ESPR passport. That is good news for architecture and bad news for timing: the 18 February 2027 deadline arrives before the act that specifies the applicable standards, and the text does not settle the fate of codes issued in between.

The right reaction is not to wait for the act. It is to choose an identifier and a carrier that can be shown to comply with both regimes, and to keep evidence of the date that choice was made.

To place your product in the timeline, the DPP scope checker gives the applicable date and legal basis in three questions. For the battery sector, the dedicated page details the required data and the deadlines.

Sources

• European Commission, draft delegated regulation Ares(2026)9188325, text and annexes, consulted on 20 October 2026 (Article 2(1); Article 3; recital 10; Annex II)
• European Commission, Have your say, initiative 14460, Industrial batteries – minimum values for electrochemical performance and durability, feedback period 29 September to 27 October 2026, consulted on 20 October 2026
• European Commission, feedback from TracePass LTD, reference F33578012, published on 8 October 2026, consulted on 20 October 2026
• Commission Implementing Decision (EU) 2026/1736 of 14 July 2026 on harmonised standards for digital product passports, OJ L, 2026/1736, 15.7.2026
• Regulation (EU) 2023/1542 concerning batteries and waste batteries, Article 77
• European Commission, Digital Product Passport page, indicative timeline, consulted on 20 October 2026