What Happens to a Battery Passport After Reuse, Repurposing or Remanufacturing?

Which batteries are in the Battery Passport regime?

The Battery Passport obligation in Article 77(1) applies from 18 February 2027 to:

• each LMT battery
• each industrial battery with a capacity greater than 2 kWh
• each electric vehicle battery

when placed on the market or put into service. ¹

The wider Batteries Regulation applies more broadly, but that does not make every battery a Battery Passport battery.

A lifecycle operation can also change the battery's category. Article 45 requires the operator placing or putting the transformed battery into service to assess compliance while taking account of the fact that the operation may have moved the battery into a different category. ¹

"Second life" is useful language, but it is not the legal test

The Regulation uses several different concepts that should not be collapsed into one label.

This distinction is operationally important. A business should not decide the passport workflow from the marketing phrase "second life" alone.

Does the original Battery Passport remain?

The Regulation requires the new passport to be linked to the original Battery Passport or passports. ¹

That establishes a lineage requirement. It is particularly important where a later battery is created from more than one original battery, because Article 77(7) expressly allows the link to be to more than one original passport.

What the Regulation does not say is that every historic field must be copied into the new passport. It also does not prescribe a particular public user interface for showing the chain of passports.

A safer architecture is therefore:

1. preserve the identity of each source passport
2. create the new passport for the post-operation battery where Article 77(7) applies
3. link the new passport to the original passport or passports
4. update the new battery's current data under the responsibility of the new responsible operator
5. preserve history as history rather than silently rewriting the original state

The exact technical presentation of that lineage remains an implementation detail. The legal requirement is the link.

Who becomes responsible for the new Battery Passport?

Article 77(4) says the economic operator placing the battery on the market must ensure that the passport information is accurate, complete and up to date. Written authorisation can be given to another operator to act on its behalf. ¹

For a battery that has undergone one of the Article 77(7) operations, that responsibility transfers to the economic operator that places the resulting battery on the market or puts it into service. ¹

There is a wider responsibility consequence too. Article 38(11) treats economic operators that carry out preparation for re-use, preparation for repurposing, repurposing or remanufacturing and then place the battery on the market or put it into service as manufacturers for the purposes of the Batteries Regulation. ¹

So this is not merely a database handover. The lifecycle transition can move regulatory responsibility.

Is a repurposed or remanufactured battery treated as newly placed on the market?

For the listed transformation routes, yes in the sense established by the Batteries Regulation.

Recital 16 says batteries that have been subject to preparation for re-use, preparation for repurposing, repurposing or remanufacturing are considered to be placed on the market anew and should therefore comply with the Regulation. ¹

Article 45 then requires the economic operator placing or putting such batteries into service to ensure the relevant examination, testing, packing and shipment controls and to ensure compliance with the Batteries Regulation and other relevant Union law. The operator must account for the possibility that the battery has changed category. ¹

Do not extend that statement to simple re-use. Recital 16 distinguishes re-use from the operations treated as a new placing on the market.

What information changes after the lifecycle transition?

Annex XIII separates stable model information from information specific to the individual battery.

For individual batteries, point 4 includes, among other things:

• performance and durability values when the battery is placed on the market and when its status changes
• state of health
• battery status, including original, repurposed, re-used, remanufactured or waste
• use-derived information such as charging/discharging cycles and negative events
• periodically recorded operating and environmental information, including temperature and state of charge

¹

This is one reason a Battery Passport should not be modelled as a static certificate. It contains lifecycle data whose current value can change.

Do all original values get replaced?

No general rule says to overwrite all original data.

A good data model separates:

• stable product/model facts
• current individual-battery state
• event history
• source-passport lineage
• evidence and responsible operator for each update

The Regulation requires accuracy and currency, but also requires the new passport to link to the original passport or passports. Treating every change as destructive overwrite would work against that lineage requirement.

What happens when the battery becomes waste?

Article 77(7) contains a separate responsibility transfer when the battery's status changes to waste.

Responsibility for the Article 77(4) passport obligations transfers to either:

• the producer
• the producer responsibility organisation where appointed under the specified rule
• or the selected waste management operator

depending on the applicable arrangement. ¹

Annex XIII point 4 also includes waste as a battery status value.

That does not mean the passport ends the moment the battery becomes waste. Article 77(8) sets the end point after the battery has been recycled. ¹

Does one battery always lead to one later battery?

No such one-to-one assumption should be built into the data model.

Article 77(7) says a new passport can link to the original passport or passports. That wording allows the regulatory lineage to represent a battery whose post-operation identity depends on multiple originals. ¹

A system designed only around old_passport_id -> new_passport_id may therefore be too narrow. The lineage relationship should support one or more source passports.

What should operators record in practice?

A practical lifecycle event should capture at least:

This is a product-data design recommendation derived from the legal structure. It is not an additional statutory field list.

What the law does not yet fully specify

Several points should remain explicitly open rather than being invented:

• the detailed legitimate-interest access rules for Annex XIII points 2 and 4
• the detailed technical/user-interface mechanics for presenting links between new and original passports
• exactly how each platform will expose historical values versus current values, beyond the Regulation's requirements for up-to-date information, interoperability and linked passports

Article 77(9) required the Commission to adopt the detailed legitimate-interest access implementing act by 18 August 2026. On 2 September 2026, the Commission's current DPP implementation timeline still placed the Battery access-rights implementing act in Q4 2026. ³

That pending act matters because second-life operators are expressly among the actors/purposes contemplated by the restricted-data access architecture.

Common mistakes

"A second-life battery keeps the same passport"

Too broad. The listed Article 77(7) operations require a new passport linked to the original passport or passports.

"Every re-used battery needs a new passport"

Too broad. Article 77(7) says preparation for re-use, not simple re-use. Recital 16 distinguishes the two.

"Repurposing just changes one field in the old passport"

Not where Article 77(7) applies. The law requires a new linked passport.

"The old passport should be deleted once the new one exists"

Not supported. The law requires the new passport to be linked to the original passport or passports. The Regulation identifies recycling, not repurposing or remanufacturing, as the point after which a Battery Passport ceases to exist.

"Every second-life operator can see all historic data"

Not established. Annex XIII contains restricted information and the detailed Article 77(9) legitimate-interest access rules remain implementation-pending.

Practical conclusion

Treat Battery Passport lifecycle change as a lineage event, not an overwrite event.

For an in-scope Battery Passport battery:

• identify the legal operation precisely
• do not equate simple re-use with preparation for re-use
• create a new linked passport when Article 77(7) applies
• transfer passport responsibility to the operator placing the post-operation battery on the market or putting it into service
• reassess battery category and regulatory compliance
• update current individual-battery information while preserving source-passport lineage
• treat the detailed restricted-data access layer as still implementation-pending

What we're watching

1. Adoption of the Article 77(9) Battery access-rights implementing act, which the Commission currently places in Q4 2026.
2. Any official technical clarification on how linked original and successor Battery Passports should expose lineage and historic values in practice.
3. Any later changes to the Annex XIII data model or access treatment that affect second-life operators.

Sources

• Regulation (EU) 2023/1542 on batteries and waste batteries, consolidated text used for current verification. Articles 3, 38, 45, 77 and 78; Annex XIII.

  View official source

• European Commission, Digital Product Passport for Batteries. Current implementation overview and Battery Passport timing.

  View official source

• European Commission, Digital Product Passport implementation timeline. Current status of the Battery access-rights implementing act.

  View official source

• European Commission, Guidance to support preparations for the Digital Batteries Passport, 21 August 2026. Used as non-binding implementation context only. This resource explains the current EU regulatory position and does not constitute legal advice.

  View official source

https://single-market-economy.ec.europa.eu/news/guidance-support-preparations-digital-batteries-passport-2026-08-21_en

This resource explains the current EU regulatory position and does not constitute legal advice.