A readiness checklist for 18 February 2027
Fourteen checks to work through before the battery passport deadline, in the order they usually need to happen, with the dates behind each one.
The deadline is 18 February 2027, and most of the work takes longer than people expect because it depends on suppliers. Work through these in roughly this order. Most of them are covered in more depth elsewhere in our guides.
Scope and ownership
1. Confirm which batteries are in scope. EV, LMT and industrial batteries above 2 kWh need a passport; all batteries need a QR code. List each line with its type, capacity and first EU sale date.
2. Confirm who is responsible. The company that places each battery on the EU market: the manufacturer, or for overseas products usually the importer. Write it down per product line.
3. Name an owner. One person who owns the passport, with a coordinator for complex supply chains, and written authorisation for anyone outside the company who does the work.
Data
4. Run a gap analysis. Use the seven DIN DKE SPEC 99100 categories, or the Commission's list of 71 data points. Basic product data is usually in ERP or PLM; materials, carbon, recycled content, dismantling and due diligence usually aren't.
5. Start on suppliers now. Identify the suppliers behind cobalt, lithium, nickel and natural graphite, and request material declarations and carbon data in a standard format. Allow 6 to 12 months; it is the main cause of delay.
6. Prepare the carbon footprint. The declaration isn't required yet, but calculate per kWh across raw materials, production, distribution and end of life, per model and per plant, so you are ready when the acts arrive.
7. Check due diligence. From 18 August 2027 for companies at or above €40 million turnover: a policy, notified-body verification and an annual report. Below the threshold, the passport still has due diligence fields to fill from supplier reports.
8. Plan for recycled content. Minimum shares apply from 2031. Record shares per model, year and plant now, and write them into supply contracts that run past 2031.
Systems
9. Choose the tool. It must cover all seven categories and the mandatory fields, export structured data (JSON) and documents (PDF), generate QR codes, take supplier input and keep the public, restricted and authority levels apart.
10. Plan serial numbers. One record and identifier per battery (Art. 77(1)), so decide how serial numbers are created and passed from production to the passport. Manual entry doesn't scale.
11. Design the QR code and label. GS1 Digital Link is the usual choice. Durable, legible for the battery's life, on the battery itself, linking to a permanent address for that unit. Keep label space for the general labelling and carbon class still to come.
12. Prepare for the registry. Get your organisation verified with a qualified electronic seal, and try the Commission's test environment. Battery registration opens once the semantic catalogue and interfaces are published.
Proof
13. Keep an audit trail. Every figure with its source and date, every change with who made it and when, filed per model with the raw supplier data, the calculations and each published version.
14. Pilot one product. Take one real battery model to a published passport behind a scannable QR code, ideally at least six months before the deadline. Then plan who updates condition data and status changes after sale.
A workable timeline
If you are starting now, with roughly four months to go, compress rather than skip:
| When | Focus |
|---|---|
| November 2026 | Scope, ownership, gap analysis, supplier requests out |
| December 2026 | Tool chosen, identifiers and label designed, seal ordered |
| January 2027 | Pilot passport live and scanned, data for the remaining models |
| February 2027 | Remaining models published, registration as soon as it opens |
FAQ
How long does battery passport preparation take?
Typically 6 to 12 months, mostly waiting on supplier and carbon data. With less time left, prioritise scope, supplier requests and one complete pilot.
What should we do first for the battery passport?
Confirm which of your batteries are in scope and who places each on the EU market, then request material and carbon data from suppliers, since that takes longest.
Can we wait for the remaining Commission acts before starting?
Not safely. The passport deadline is fixed, and the data that the pending acts cover takes longer to collect than the acts are likely to take to publish.
Sources
- Battery passport checklist 2027, DPP Hero
- EUBR compliance checklist, Kezzler
- How to create a battery passport, DPP Hero
General information, not legal advice. Checked against the sources above on 31 October 2026; the Commission is still adopting the acts that fill in the detail, so check before relying on a date.