From 18 February 2027, LMT batteries, EV batteries and industrial batteries above 2 kWh placed on the EU market must carry a digital battery passport accessible by QR code under Articles 77–78 and Annex XIII. The Commission's August 2026 guidance consolidates 71 data points and their mandatory, conditional or optional status. This paper explains the architecture, the access tiers and — critically for nickel-metal hydride (NiMH) exporters — why portable NiMH cells are exempt.
The passport obligation attaches to three categories: LMT batteries (e-bikes, e-scooters), EV batteries, and rechargeable industrial batteries with capacity above 2 kWh. It applies to batteries placed on the market from 18 February 2027 — batteries already in service before that date are not retroactively required to carry one. Below the threshold, portable batteries and industrial batteries at or below 2 kWh carry a QR code under Article 13 linking to label information, the Declaration of Conformity, due-diligence policy and waste guidance, but not the full passport. At 1.2 V per NiMH cell, 2 kWh equals roughly 1,667 Ah, so virtually all catalog NiMH cells and packs sit below the passport line.
The August 2026 Commission guidance breaks the passport into data points grouped by identity and traceability (manufacturer, model, batch, unique identifier, dates), technical specifications (chemistry, nominal capacity, voltage, materials), performance and durability (Annex IV parameters, SOH history), composition and recycled content (Article 8 shares per metal), carbon footprint where applicable, due-diligence information, maintenance and dismantling guidance, and compliance documents (CE, DoC, certificates). Each point is classed mandatory from day one, conditional (required only when the scenario applies), optional, deferred to a later implementing act, or permanently exempt for a category. The donut above illustrates the illustrative distribution across groups; the authoritative split is the guidance matrix per category.
Annex XIII defines who sees what. The public tier, open to anyone scanning the QR, contains general information: chemistry, capacity, safe-handling, collection points, dismantling basics. The legitimate-interest tier, available to repairers, second-life operators and recyclers under verified identity and confidentiality terms, contains detailed composition, dismantling and SOH data needed for reuse and recovery. The authority tier, for market surveillance and customs, contains the full compliance file. The economic operator placing the battery on the market owns the passport; when a battery is repurposed or remanufactured, a new passport is issued and linked to the original, and at final recycling the passport is deactivated. Data must be kept accurate and updated through life.
Exemption from the passport is not exemption from digital information. From February 2027 every battery, including portable NiMH, carries an Article 13 QR linking to: label and marking data, the EU Declaration of Conformity, the public due-diligence policy, separate-collection and recycling guidance, and the general-information block from the 2026 requirement. In practice this means a stable landing page per model family, kept online for the product lifetime, in the languages of destination markets — a lightweight but permanent data-hosting obligation that belongs in the technical file and on the quality manager's checklist.
First, classify each product and record the 2 kWh arithmetic. For covered large packs, begin the data infrastructure now: unique batch/serial identifiers, a data model mapped to the 71-point matrix with mandatory/conditional flags, hosting with role-based access, and update workflows for SOH and ownership changes; implementation advisories estimate 6–12 months of system work. For portable lines, build the model-family QR landing pages and link them to existing DoC, policy and waste documents. Validate both routes against the August 2026 guidance before the mandate date and keep evidence of conformance in the Annex VIII file.
Weijiang Power classifies every NiMH product against the passport threshold in writing, provides Article 13 QR-ready model landing content (DoC, due-diligence policy, composition and recycling guidance), and supplies the structured data fields large industrial packs above 2 kWh need for passport population. Send your pack Wh and target categories and we return the scope decision plus a data-point checklist mapped to the August 2026 guidance.
