Who it's for

The duty sits with whoever places the battery on the EU market.

Not the cell maker in Asia. Not the distributor. The brand or importer whose name is on the declaration of conformity. CellHash is built for the three groups that carry that duty with the fewest people to discharge it.

LMT · light means of transport

E-bike and light-transport brands

About 1,200 companies sold 5.1 million e-bikes in the EU and UK in 2023. Most are brands and importers with packs sourced from Asia, low margin per unit and no compliance function. From 18 February 2027 each of those packs needs a passport before it can be placed on the market.

The consortium's own advice. The Battery Pass LMT spotlight calls the market fragmented, SME-heavy and low-margin per battery, notes that batteries without a BMS need extra effort for performance data, and recommends battery-passport-as-a-service providers.

What is usually missing

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    Expected lifetime in cycles and test evidence per model.
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    Material composition, which sits with the cell supplier.
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    Dismantling information for packs bought as sealed units.
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    An item-level identifier scheme and QR artwork with lead time for pack tooling.

What CellHash does

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    Maps your bill of materials and supplier attestations to the 71 data points and names the gaps per model.
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    Issues item-level identifiers and QR codes in bulk for a production run, with label templates.
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    Registers and hosts every passport as authorised operator, so eIDAS onboarding is not your problem.
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    Starter plan priced for a brand, not an OEM. Under €500 a month.
Industrial · above 2 kWh

Home and commercial storage makers

The EU installed 27.1 GWh of battery storage in 2025, up 45 percent: 9.8 GWh residential, 2.3 GWh commercial and industrial, about 15 GWh utility. A home battery is typically above 2 kWh, so residential and C&I systems are both in scope as industrial batteries.

Nobody is serving you yet. A September 2026 comparison of nine European passport platforms found no vendor built for home-storage makers, and a German installer-software note from May 2026 says it is still unclear which providers will offer passport import by February 2027.

What is usually missing

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    A clear view of which entity places each system on the market when integrators and installers are in the chain.
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    Performance and durability data in the conditional form the guidance expects for industrial batteries.
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    A route for state of health from the BMS into the item-level tier over the life of the system.
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    Hosting that survives the installer and the brand.

What CellHash does

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    Multiple models and facilities on one account, with the gap list per model and per tier.
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    BMS export ingestion with column mapping, so state of health lands in the passport without an integration project.
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    Legitimate-interest access management for installers, repairers and recyclers.
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    EU-resident hosting as authorised operator for the life of the system.
Importers and subsidiaries

EU importers of non-EU cells and packs

Chinese makers held over half of the EU EV battery market in 2025, and nearly all LFP demand is imported. A non-EU maker cannot sell into the Union without an EU-hosted passport, and the liability for it sits with the importer or EU subsidiary whose name is on the paperwork.

Article 78 is the importer's clause. The record must be stored by the economic operator or an operator authorised on its behalf, and must remain available after that operator ceases to exist or leaves the Union. Customs can check the registry entry.

What is usually missing

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    Recognition that the duty is the importer's, discovered late.
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    Supplier data in a form that maps to the Commission's data points rather than a spreadsheet per shipment.
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    An eIDAS-verified operator identity for the registry.
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    A hosting arrangement inside the Union that does not depend on the seller.

What CellHash does

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    Multi-entity accounts: one importer, many suppliers and brands, strict isolation between them.
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    Supplier intake by CSV and API with column mapping, so the data arrives once per model, not once per shipment.
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    Registration on your behalf as authorised operator, with proof of registration retained for customs questions.
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    AAS and Catena-X exchange for the OEM customers who ask for it.
Second wave

UK exporters, recyclers, repairers and fleets

UK companies selling into the EU or Northern Ireland face the EU rules now and a Great Britain regime later. Recyclers, repairers, remanufacturers and fleet operators become legitimate-interest users of the same records once the access-rights act lands. Both groups use the record CellHash already hosts.

73%
of UK battery firms exporting to the EU were unaware of the rules
Loughborough University, January 2026
10–20%
lower recycling pre-processing cost with a passport, per the Battery Pass value assessment
Battery Pass, April 2024

Not sure which group you are in?

The readiness check asks which entity places the battery on the market and tells you what follows. Fourteen questions, in your browser.