Battery passport for forklift and traction batteries

The passport obligation attaches to category and capacity, not to cell technology. A PzS lead-acid battery is affected just as much as a lithium system. Anyone assuming that the regulation will not reach them as a manufacturer of classic traction batteries is wrong.

For scale: a 48 V battery with 500 Ah comes to around 24 kWh. In this segment the 2 kWh threshold is exceeded by practically every product, including small batteries for low-lift pallet trucks.

Assembling means placing on the market

The second widespread misconception concerns the role. Many businesses in this market see themselves as a dealer or a workshop, not as a manufacturer.

What counts, however, is who places the finished battery on the EU market under their own name. Anyone who buys cells, sets them into a tray, wires, tests and ships them is placing the battery on the market. That holds even where neither plates nor cells come from their own production. Anyone reselling finished batteries of other brands exclusively is not.

Check this classification before you think about software. It determines whether you may ship at all from February 2027.

The variant count is the real problem

In hardly any other segment is the product matrix this broad. Tray dimensions to DIN and in special sizes, 24 V to 80 V, capacities across a wide range, plus customer-specific adaptations. Many businesses carry several hundred deliverable combinations.

Two consequences follow:

The data model has to be able to represent the variance. An approach requiring its own configuration per product line does not scale here. What works is a shared schema with variant-specific attributes.

The link to the shipment has to hold. The passport is issued per individual battery and has to reflect the cell or plate batch actually installed. Where production documentation sits on routing slips or in Excel, that is the point at which implementation genuinely creates work, not the passport generation itself.

Second life is an opportunity, not an edge case

Refurbishment, cell replacement, tray reconditioning and take-back are normal business in this market. The battery passport has to stay current across the entire lifecycle and be carried forward on remanufacturing or repurposing. It expires only once the battery is recycled.

At first that sounds like additional effort. In practice it gives you a complete history per battery, which today exists in most businesses only in people's heads and in service reports. If you have to build it anyway, you can use it for maintenance contracts, warranty handling and take-back logistics.

On lead you are better placed than you think

One argument you can make visible in the passport: the recycled content of lead in Europe is in fact very high, and the closed loops have worked for decades. What is missing is not the substance, it is the evidence.

If you get this information from your plate supplier in structured form, the passport ends up carrying a figure that looks good next to lithium competitors. Request the data now, while you still have room to follow up calmly.

Timeline

Now to October 2026: Settle the role (placing on the market, yes or no), delimit the affected product groups, send enquiries to cell and plate suppliers on carbon footprint and recycled content.

October to December 2026: Set up the variant model, verification in the EU DPP registry, connect production documentation.

January 2027: Test operation, data carrier in production, training for sales and service.

Frequently asked questions

Does this apply to lead-acid batteries too? Yes. The regulation distinguishes by category and capacity, not by cell chemistry.

We only assemble and buy everything in. Are we affected? If you ship the finished battery under your own name, yes.

What about refurbished batteries? The passport has to be updated on remanufacturing. For batteries placed on the market before the cut-off date, no retroactive passport obligation arises.

We have several hundred variants. Is that manageable at all? Yes, if you use a shared schema with variant-specific attributes instead of maintaining every variant individually. That is exactly what the model level in the passport is there for.