Your battery passport is only as valid as its identifier

Most of the attention on battery passports goes to the data: carbon footprint, recycled content, state of health, the eighty-odd Annex XIII fields. Comparatively little goes to the string that identifies the product those fields describe. That is a mistake, because the identifier is the one part of a passport that can invalidate everything attached to it.

Here is the clause. In the Ecodesign for Sustainable Products Regulation, Annex III, second paragraph: the data carrier and the unique product identifier "shall, where relevant for the products concerned, comply with standards ISO/IEC 15459-1:2014" through "15459-6:2014". The Battery Regulation says the same thing about battery passports, and without the softening qualifier: the QR code and the unique identifier shall comply with those ISO/IEC standards or equivalent.

What that actually requires

ISO/IEC 15459 is the family of standards governing unique identification. Its central idea is that identifiers are not invented locally — they are issued under a registered issuing agency, which is what makes them unique everywhere rather than merely unique in your database. GS1 is the best-known issuing agency, and the GTIN is its identifier; ISO/IEC 15459-6 is named in the regulation precisely in that context. Other agencies exist and serve particular sectors.

The practical consequence is unglamorous and easy to miss: a serial number your ERP generates, a UUID your software mints, a product code your team agreed in a spreadsheet — none of these satisfy the requirement, however genuinely unique they are within your own operation. Uniqueness is necessary but not sufficient. The identifier has to come from somewhere with the authority to guarantee it globally.

For a manufacturer already carrying GTINs on its products, this is a non-event. For an importer bringing in batteries made elsewhere, or an authorised representative acting for a non-EU manufacturer, it is a question worth answering early: do you hold identifiers issued under a recognised scheme for the products you are placing on the market, and if not, whose identifiers will you use? That is a procurement and process question, with a lead time, and it sits upstream of every other passport task. No amount of data quality compensates for it.

Why we now block on it

We treat this as a hard gate in our platform, and it is worth explaining why we chose that rather than a warning.

Passports without a compliant identifier can be created, imported and edited freely. That matters: real data arrives incomplete, and a system that refuses incomplete data is a system that gets bypassed. Load everything you have, work on it, fill the gaps.

But such a passport cannot be published, and it cannot be included in a registry submission batch. Not with a warning, not with a confirmation dialogue, not with an override. The reasoning is that both of those actions assert something to the outside world — publishing puts a passport behind a QR code that anyone can scan; submitting registers it as the compliant passport for a product placed on the EU market. An identifier that does not meet the standard makes both assertions untrue, and a system that lets you make an untrue assertion about your own compliance is not doing you a favour.

So the platform shows the outstanding work instead. A count of passports not yet submittable, a reason on each one, and a direct path to the field that fixes it. The state to be in before February 2027 is not "no warnings"; it is zero not-yet-submittable.

The registry will not be gentle about this either

Worth noting how this compounds. The Commission's DPP Registry takes the unique product identifier as a resolvable URL and fetches it during validation; its documented failure causes include redirect chains and protocol downgrades. The identifier has to be standards-compliant, globally unique, and cleanly resolvable — three separate properties, each capable of failing a registration on its own.

Battery passport registration is not yet possible for anyone; the Commission has not yet defined the semantic catalogue for the product group. That gap is temporary, and it is the last quiet period before 18 February 2027, when every LMT, EV and industrial battery above 2 kWh placed on the EU market needs a registered passport. Identifier procurement, if you need it, is exactly the kind of task that is trivial with six months and painful with six weeks.

If you are working out where your organisation stands, the companion piece to this one is our walk-through of economic operator verification — the other prerequisite that has to be completed before registration opens, and the other one nobody can do on your behalf: verifying as an economic operator.