Battery passport for home storage systems

The most common objection in conversations with storage manufacturers is: “But we don't build industrial batteries.” Yes, you do. The Battery Regulation knows no separate category for home storage. Stationary battery storage systems fall under industrial batteries, and above 2 kWh they require a passport.

A 5 kWh entry-level system is above that. A 10 kWh system all the more so. The threshold is practically meaningless in this segment, because it excludes no product of any market relevance.

Why the segment is affected sooner than expected

Two things make home storage one of the more time-critical cases.

Series production in high volumes. The passport is issued per individual battery, not per model. Anyone shipping 8,000 systems a year needs 8,000 passports with individual identifiers, each linked to the cell batch actually installed. That is not a document problem, it is a question of connecting to production.

Modular systems. Expandable storage, where the customer adds capacity later, raises the question of what exactly the battery is in the sense of the regulation: the overall system or the individual module. Settle this classification early, as it determines the number of passports and the effort in the aftermarket.

Your cell supplier is your bottleneck

In this segment the cells come almost exclusively from Asia. That puts the information which causes the most work in the passport outside your own company:

The carbon footprint has to be calculated according to the EU methodology, not according to whatever is in the supplier's data sheet. Recycled content shares for lithium, cobalt and nickel are frequently assured but not evidenced. The exact material composition counts as a trade secret at the cell manufacturer, even though it has to be held in the passport for recyclers and authorities.

You need lead time for these enquiries. Reckon with months rather than weeks, and start them independently of the software selection. How sensitive information can be made accessible under control without publishing it is set out on our battery passport page under the three access levels.

The passport is also a sales channel

One point you should weigh differently from other manufacturers: the QR code on the storage unit will be scanned. By installers during commissioning, by end customers out of curiosity, by tradespeople during servicing.

The public passport view is therefore a touchpoint with your brand, not just a mandatory field. Anyone showing a clean, understandable view there with recycled content and carbon footprint has an argument that competitors will also have to deliver from February 2027, but will not necessarily deliver well.

Timeline

If you want to be shipping on 18 February 2027, a realistic sequence looks like this:

Now to October 2026: Record exposure per product line, name an owner, send supplier enquiries to the cell manufacturers.

October to December 2026: Set up the data model, complete verification as an economic operator in the EU DPP registry, connect serialisation to production.

January 2027: Test runs, alignment with installation partners, data carrier in production.

Anyone starting the supplier enquiry in January will not hold the date. Not because of the software, but because the answer from Asia does not arrive in time.

Frequently asked questions

Is a 5 kWh home storage system really affected? Yes. Stationary storage counts as an industrial battery, and the threshold is 2 kWh.

We buy modules and only build the system. Does the obligation apply to us? If you place the finished system on the EU market under your own name, yes. The obligation attaches to placing it on the market, not to cell manufacturing.

Does every single unit need its own passport? Yes, one passport per individual battery with its own identifier.

What about storage systems we have already shipped? The obligation applies to placing on the market from the cut-off date. Existing units are not covered retroactively.