PASSreadyEU DPP Readiness

What a battery passport is, and what it isn't

The battery passport is the first Digital Product Passport the EU has made mandatory. Here is what it holds, where it lives and how it differs from the wider DPP regime.

Updated · 4 min read

A battery passport is an electronic record for one physical battery. It follows the battery from production through use, second life and recycling, and anyone holding the battery can reach it by scanning a QR code on the pack. From 18 February 2027 it is mandatory under the EU Battery Regulation, Regulation (EU) 2023/1542, for EV batteries, LMT batteries (e-bikes, e-scooters and similar) and industrial batteries above 2 kWh.

It is often described as a document. It is better thought of as a governed data set: structured, machine-readable fields, kept accurate for the life of the battery, with different parts visible to different people.

What goes into it

The binding content is set out in Annex XIII of the regulation. In practice most teams organise it using the seven categories of DIN DKE SPEC 99100, a free specification published in February 2025 that turns Annex XIII into a data structure:

  1. Identification and product data: unique identifier, manufacturer, model, production date and site.
  2. Materials and composition: cathode, anode and electrolyte chemistry, hazardous substances and critical raw materials.
  3. Carbon footprint: kilograms of CO₂ equivalent per kWh over the battery's life.
  4. Supply-chain due diligence: the policy and verification behind the raw materials.
  5. Circularity: recycled content, dismantling, spare parts and end-of-life information.
  6. Performance and durability: capacity, power, expected cycle life, internal resistance and state of health.
  7. Labelling and conformity: CE marking, the EU declaration of conformity and test evidence.

The passport attaches to the battery as it is placed on the market (usually the pack), not to each cell or module inside it. Some information is the same for every battery of a model; some, like state of health, belongs to the individual unit and changes over its life.

Where the data lives

There is no central EU database of passport content. The responsible company, or a provider acting for it, hosts the data (Art. 78). The EU registry, which went online in July 2026, holds only identifiers and references that point to where each passport lives.

That puts real obligations on whoever hosts it:

  • The data must be accurate, complete and up to date (Art. 77(4)).
  • It must stay available even if the company responsible stops trading or leaves the EU market (Art. 78(e)).
  • A provider hosting it may not sell or reuse the data beyond the service it provides (Art. 78(d)).
  • There is no approval step in advance. Market surveillance authorities check compliance after batteries are on the market (Art. 79).

What it isn't

It isn't the general Digital Product Passport. The Ecodesign for Sustainable Products Regulation (ESPR, Regulation (EU) 2024/1781) sets up passports for almost every physical product, one product group at a time through delegated acts. Iron and steel, textiles, tyres, aluminium, furniture and mattresses are on the Commission's working plan between 2026 and 2030. The battery passport came first and has its own legal basis in the Battery Regulation; the ESPR supplies shared infrastructure such as the registry. Where the two meet, the Battery Regulation governs what goes into a battery passport.

It isn't a replacement for the product's own passport. A battery built into an e-bike or a power tool needs its own battery passport. The finished product may later need an ESPR passport too, with a different legal basis, a different responsible party and a different deadline. The regulation asks for the two to be interoperable, not merged.

It isn't the Global Battery Alliance passport. The GBA runs a voluntary reporting and certification scheme. It can help with evidence, but it doesn't satisfy the EU obligation on its own.

It isn't a certificate. Registering a passport or having one hosted by a software provider says nothing about whether the battery complies. Responsibility for the content stays with the company that places the battery on the market.

Batteries already made

The obligation follows the date a battery is first placed on the EU market, not the date it was made. A battery sold into the EU before 18 February 2027 needs no passport, even if it is resold later. A battery made in 2026 but first sold in March 2027 does.

FAQ

Is the battery passport the same as a Digital Product Passport?

It is the first Digital Product Passport to become mandatory, but it comes from the Battery Regulation rather than the ESPR. The two share infrastructure, such as the EU registry, and must be interoperable, but the battery passport's content is set by Annex XIII of the Battery Regulation.

Where is battery passport data stored?

With the company responsible for the battery, or a provider it authorises. The EU registry stores identifiers and links, not the passport content itself.

Do batteries made before February 2027 need a passport?

Only if they are first placed on the EU market on or after 18 February 2027. The trigger is first sale or entry into service in the EU, not the production date.

Sources

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.