Summary

  • From 18 February 2027, each industrial battery with a capacity greater than 2 kWh that is placed on the market or put into service must have an electronic battery passport; a data-centre owner must first prove that the UPS battery falls within that legal category and threshold.
  • The useful replacement option combines electrical and safety evidence with custody of the passport identifier, required data, access rights, update responsibility and the link to any later reuse, repurposing or remanufacturing passport.

The rack can fit while the evidence does not

UPS replacement planning usually begins with cells, strings and cabinets. Engineers test voltage, fault current, autonomy, protection, battery-management interfaces, cooling and fire strategy. Those checks remain indispensable. Regulation (EU) 2023/1542 adds a different dependency for qualifying batteries: information continuity.

Article 77 applies from 18 February 2027 to each light-means-of-transport battery, each industrial battery above 2 kWh and each electric-vehicle battery placed on the market or put into service. A large UPS installation should not be swept into scope by intuition. The owner needs a documented battery classification, capacity and market event. A site may contain several battery types, procurement dates and responsible economic operators.

The passport is not a certificate that the battery will fit the DC bus, communicate with the controller or meet the site's safety case. It is an electronic record with model-level and individual-battery information specified in Annex XIII. Its value is traceability: the evidence can remain associated with the physical asset rather than being scattered among delivery files, service portals and a supplier's private systems.

The identifier has an owner

The passport is accessible through the QR code required by Article 13(6). That code links to a unique identifier attributed by the economic operator placing the battery on the market. The same economic operator must ensure that passport information is accurate, complete and up to date, although it may authorise another operator in writing to act on its behalf.

That allocation matters in a data-centre supply chain. The equipment vendor, battery manufacturer, integrator, maintenance contractor, asset owner and facility operator may be different organisations. If the contract merely promises a compliant battery, the buyer may discover too late that the identifier is controlled by one party, operational data by another and update authority by neither of them.

Access is also layered. Some passport information is public. Other fields are reserved for notified bodies, market-surveillance authorities and the Commission, or for persons with a legitimate interest under the access rules. A buyer should not assume that scanning a code reveals every field needed for service, residual-value assessment or second-life planning. It should map each required field to a lawful access route.

Second life requires a linked record

Article 77(7) is particularly important for replacement economics. When a battery has been prepared for reuse or repurposing, repurposed or remanufactured, responsibility transfers to the economic operator that places that battery on the market or puts it into service. The battery must receive a new passport linked to the original passport or passports.

The physical asset and its record therefore have to survive the same hand-off. A missing identifier, inaccessible source record or ambiguous update owner can weaken resale and reuse options even when the cells retain value. Conversely, a complete passport does not prove remaining capacity. State-of-health data, protection tests and site acceptance still need their own evidence.

Procure the chain, not only the cabinet

For each qualifying UPS battery, maintain a schedule covering legal category, capacity, economic operator, placement or commissioning event, unique identifier, QR/passport linkage, Annex XIII fields, source system, access class, update authority, retention, service changes, transfer and second-life responsibility. Reconcile it with the electrical asset register and commissioning dossier without treating either record as a substitute for the other.

The defensible replacement option is a battery that can be installed safely and whose evidence chain can be transferred, read and updated by the parties that need it. A compatible rack without that chain is not yet portable capacity.

Sources

https://environment.ec.europa.eu/topics/waste-and-recycling/batteries_en

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1542

http://publications.europa.eu/resource/oj/JOL_2023_191_R_0001.ENG