
From 18 February 2027, no electric car battery can be placed on the European market without its own digital record. That record is the EU battery passport, created by Regulation (EU) 2023/1542, and it applies in Portugal exactly as it does in Germany or France. For anyone buying an EV here, it is the most visible part of the new battery passport rules for electric cars arriving in 2027.
The pitch is simple: scan a QR code and see where the battery came from, what it's made of and what condition it's in. Reality is messier. Some deadlines have slipped, several data fields will be empty on day one, and the used EV you're looking at today will never get a passport at all.
The digital battery passport is an electronic record tied to a unique identifier and accessed through a QR code on the battery or the vehicle. Its data fields are set out in Annex XIII of the regulation and detailed in the technical specification DIN DKE SPEC 99100.
It isn't just for cars. Three categories are covered:
Consumer electronics are excluded. And contrary to what some articles published in Portugal have suggested, this is not an "environmental passport" for every car — petrol and diesel models are not in scope.
Access is tiered. Some information is public and anyone can read it with a phone. Other data is reserved for notified bodies and market surveillance authorities. A third tier is for parties with a "legitimate interest": repair shops, reuse operators and recyclers.
Responsibility for the passport lies with whoever first places the battery on the EU market — usually the carmaker or its EU importer, even though much of the data comes from cell suppliers.
This is where most of the confusion lies. On paper, the full passport covers carbon footprint, recycled content, supply-chain due diligence, performance and durability parameters, state of health (SoH) and dismantling information. In February 2027, not all of that will be there.
The easy data goes in from the start: manufacturer, chemistry, nominal capacity, production date, material composition and hazardous substances. Fields whose underlying obligations haven't kicked in yet can stay blank.
| Obligation | Applies to EVs? | Date |
|---|---|---|
| SoH data in the BMS, with read-only owner access (Art. 14) | Yes | 18 Aug 2024 |
| Digital battery passport (Art. 77, Annex XIII) | Yes | 18 Feb 2027 |
| Battery removable by the end user (Art. 11) | No (portable; LMT by a professional) | 18 Feb 2027 |
| Supply-chain due diligence (Art. 48) | Yes | 18 Aug 2027 (postponed) |
| Carbon footprint declaration (Art. 7) | Yes | 12 months after the delegated act; not before H2 2027 |
| Carbon footprint performance classes and maximum thresholds | Yes | Later, via delegated act |
| Minimum recycled content: cobalt 16%, lithium 6%, nickel 6%, lead 85% | Yes | 18 Aug 2031 |
| Minimum recycled content: cobalt 26%, lithium 12%, nickel 15%, lead 85% | Yes | 18 Aug 2036 |
EV battery carbon footprint declarations were supposed to start in February 2025. They didn't: as of mid-2026, the delegated act setting the methodology for EV batteries still hadn't been adopted. Realistic estimates put the start of declarations in the second half of 2027 at the earliest.
Due diligence on cobalt, lithium, natural graphite and nickel slipped too — from August 2025 to 18 August 2027, under Regulation (EU) 2025/1561. Recycled-content quotas only become binding in 2031. The upshot: anyone opening a passport in March 2027 will mostly find identification data, not a full environmental profile.
Another common mix-up. The user-removability and replacement rules that start on 18 February 2027 apply to portable batteries (phones, appliances) and, for LMT, to replacement by an independent professional. They do not apply to EV traction batteries. Nobody will be swapping their car's battery in the garage.
No — at least not retroactively. Cars already on the market before 18 February 2027 won't automatically get a passport. The practical exception is a replacement battery: a new traction pack sold after that date counts as newly placed on the market and needs its own passport.
For Portugal's used market, that has a direct consequence. For the next few years, a used EV with a battery passport will be rare. They'll only show up in numbers once cars registered from 2027 onward come off their first leasing contracts and reach the second-hand market — roughly 2030 and beyond. Until then, the exceptions are the brands that moved early.
A less-discussed rule is already in force. Under Article 14 of the regulation, since 18 August 2024 an EV's battery management system (BMS) must store data on state of health and expected lifetime, with read-only access for the owner or a third party acting on their behalf — for example, to assess residual value. In practice, how each brand provides that access still varies, so it's worth asking the seller or dealer how to get the data before you sign anything.
Not all SoH methods are equal either. An OBD reading is quick but depends on each brand's algorithms — some high-mileage cars still show 100%. A dynamic test at a dealer such as Hyundai, Renault or Kia can produce a battery health certificate. A controlled discharge is the most reliable method and the reference in disputes, but it's slow and expensive.
Alongside the battery regulation, the Euro 7 standard (Regulation (EU) 2024/1257) sets minimum durability requirements for EV batteries. The figures reported for passenger cars are around 80% of capacity at 5 years or 100,000 km and 72% at 8 years or 160,000 km (75% and 67% for vans). These numbers appear across several sources, but it's worth checking the official text before relying on them in a negotiation.
For context, the typical battery warranty in Portugal is around 8 years or 160,000 km, and replacement is usually considered once a battery drops to about 70% of its original capacity.
The date is fixed, but the industry is heading into 2027 without much confidence. In a European Commission survey cited by the sector, only 15% of 91 companies said they were very confident their data would be ready. In October 2026, Automotive News reported that unclear SoH calculations and fragmented supplier data leave compliance in doubt.
This is the problem that matters most to buyers. There's no harmonised way for carmakers to calculate state of health. Felix Wagner of Circunomics worries the passport will simply copy each brand's BMS estimate, making it hard to compare one car's SoH with another's. A capacity-based SoH can also differ substantially from one based on internal resistance.
In plain terms: "92%" in one brand's passport may not mean the same as "92%" in another's.
The passport relies on data from mining, refining, cell production and assembly. Christian Marston of Altilium says this data collection is where companies struggle most. Suppliers still exchanging information by spreadsheet will have a hard time.
According to Wagner, Chinese groups such as BYD already take a more advanced approach to collecting and using data, which could make compliance easier for them. An interesting twist at a time when Europe is trying to protect its own industry.
Some manufacturers didn't wait for 2027.
Volvo EX90 and ES90. The EX90 was the first EV with a battery passport, launched in 2024 with UK company Circulor. A summary is available via a QR code on the driver's door pillar; the full version goes to the authorities and includes battery state-of-health data for 15 years. The reported cost is about US$10 per car. Today the passport is available on the EX90 and ES90, and Volvo's certified used cars come with a high-voltage battery SoH certificate — which the brand describes as an estimate, not a guarantee.
Kia. The Korean brand tested a cell-level passport on a Kia EV3, working with Delft University of Technology and the EU project DATAPIPE. The system tracks the SoH of each cell in real time and shows the data on the infotainment screen. Kia plans to offer the service on all the electric and hybrid models it sells in Europe by February 2027.
There are also industry initiatives such as the Path.Era consortium, which brings together BASF, BMW, CATL, Henkel and Siemens.
The digital battery passport becomes mandatory on 18 February 2027 for every electric vehicle battery placed on the EU market, under Art. 77 and Annex XIII of Regulation (EU) 2023/1542. It also covers light means of transport batteries (e-bikes, e-scooters) and industrial batteries above 2 kWh, and is accessed via a QR code. Some sources quote 1 February, but the legal date is 18 February. The user-removability rules starting the same day do not apply to EV traction batteries.
Not retroactively: EVs placed on the market before 18 February 2027 will not get a passport, unless they are fitted with a new traction pack sold after that date. On the Portuguese used market, passports should only become common around 2030, as EVs registered from 2027 come off their first leasing contracts. Until then the exceptions are early movers such as Volvo with the EX90 and ES90. For a used EV bought today, a credible SoH report from a dealer or independent service is still what matters most.
In principle, yes: the regulation defines an electric vehicle battery as the traction battery of electric or hybrid vehicles, so new plug-in hybrids placed on the market from 18 February 2027 should carry a passport. Kia, for example, plans to offer the service on all EVs and hybrids it sells in Europe by February 2027. Combustion-only cars are not covered. For specific cases, especially hybrids with very small batteries, it is worth checking with the manufacturer.
The Euro 7 standard (Regulation (EU) 2024/1257) sets minimum durability requirements that, according to several sources, are around 80% of capacity at 5 years or 100,000 km and 72% at 8 years or 160,000 km for passenger cars (75% and 67% for vans). These figures should be checked against the official text before relying on them in a negotiation. For comparison, the typical battery warranty in Portugal is 8 years or 160,000 km, and replacement is usually considered below roughly 70% of original capacity.
Neither will be in the passport in February 2027. The carbon footprint declaration for EV batteries depends on a delegated act that was still not adopted by mid-2026 and is not expected to start before the second half of 2027, while due diligence on cobalt, lithium, natural graphite and nickel was postponed to 18 August 2027. Minimum recycled content only becomes mandatory from 18 August 2031 (cobalt 16%, lithium 6%, nickel 6%, lead 85%), rising in 2036 to 26%, 12%, 15% and 85%.
If you're buying a new EV in 2027 or later, the battery will come with a passport. In the first year, expect mainly identification and composition data, not carbon footprint or recycled-material percentages.
If you're considering a used EV, the passport isn't yet the tool that will protect you. For several years, most used EVs for sale in Portugal won't have one. What still counts is a credible EV battery health check — done at a dealer or by an independent service — plus the maintenance history.
In the medium term, the effect on residual values could be positive. Documented battery health makes it harder to hide a degraded pack, can help banks, leasing firms and insurers price risk more accurately, and rewards brands that can prove durability. But all of that hinges on one open question: a common method for calculating SoH. Until that arrives, the EU battery passport is a useful step, not the final answer.