The battery passport: the EU's first mandatory digital product passport

The battery passport is the first digital product passport to have a precise, legally binding start date: 18 February 2027. While the passports for the product categories covered by the ESPR (textiles, steel, furniture) are still waiting on delegated acts, for batteries the obligation is set out in a standalone, directly applicable EU regulation. This article walks through who it applies to, what data it must contain, and when the related thresholds take effect.

Why is this the first "live" DPP?

Most digital product passports will come from the ESPR framework regulation (EU) 2024/1781, but there the specific data content and deadline for each product group are set by a separate delegated act — and as of mid-2026 not a single one had been finally adopted. Batteries take a different route: the passport obligation is contained not in the ESPR but in the standalone EU Battery Regulation 2023/1542, and it is tied to a specific calendar date.

The regulation was published in the Official Journal of the EU on 28 July 2023, entered into force on 17 August 2023, and generally applies from 18 February 2024. The digital passport requirement appears in Article 77 of the regulation, and Article 77(1) itself fixes the mandatory start date of 18 February 2027 (the regulation's general entry into force and application are governed by Article 96). Because this is a regulation (not a directive), no national transposition is needed: the obligation applies directly and simultaneously across all 27 Member States. If you are just getting to grips with the topic, it is worth first reading the What is a DPP primer, then the ESPR/DPP deadlines overview.

Who does it apply to? The exact scope

From 18 February 2027 the battery passport obligation applies to batteries that are placed on the market or put into service in the EU and fall into one of the following three categories:

• EV batteries — any battery powering an electric vehicle (passenger car, van, truck, bus), regardless of capacity.
• Light means of transport (LMT) batteries — the traction batteries of e-bikes, electric scooters, mopeds and hoverboards, again with no size threshold.
• Industrial batteries above 2 kWh — the 2 kWh lower threshold applies only to industrial batteries.

An important clarification: many secondary sources wrongly frame the scope as "EV above 2 kWh". Under Article 77 of the regulation, the 2 kWh threshold applies only to industrial batteries; for EV and LMT batteries the passport is mandatory regardless of capacity. SLI batteries (starting, lighting and ignition batteries — i.e. the classic automotive starter batteries) are not covered by the passport obligation — although other obligations (such as the recycled-content declaration) may still extend to them.

"Placing on the market" means making the product available on the EU market for the first time in the course of a commercial activity. This also means that, after the deadline, the responsible economic operator (manufacturer, importer or authorised representative) cannot lawfully place the battery on the market in any Member State without a passport; compliance is checked by market surveillance authorities and customs.

What data must it contain?

Each passport must relate to a specific physical battery (to an individual unit, not a product type), and the exact data points, together with their associated access rights, are defined in the regulation's Annex XIII. The main elements of the mandatory content are:

• Unique identifier + QR code on the physical battery, leading to the online passport.
• Basic data: manufacturer, type, model, place and date of manufacture, weight, category.
• Material composition and chemistry: the materials used in the battery, along with the critical raw materials and hazardous substances.
• Carbon footprint declaration: the carbon footprint value specific to the manufacturing site and production batch.
• Recycled content: the share of recycled cobalt, lead, lithium and nickel present in the active materials.
• Electrochemical performance and durability: rated capacity, power, expected lifetime, cycle count.
• State of Health (SoH) and other dynamic data that are updated over the battery's life.
• Due diligence status: information on responsible sourcing across the supply chain.

In practice, at launch on 18 February 2027 the initial expectations are mainly basic identification, type, model and the key technical characteristics; the more detailed life-cycle and durability statistics, as well as field-by-field access, will be specified by further implementing/delegated acts (the implementation of Annex XIII).

Three-tier access and the QR code

The battery passport is not a single dataset open to everyone. The regulation prescribes three-tier, role-based access:

1. Public — anyone who scans the QR code (consumers): basic information, environmental data, recyclability.
2. Authorised parties — recyclers, repairers, second-life operators: dismantling and composition data, with SoH and dynamic data typically available only to them or to the current owner.
3. Authorities — market surveillance, customs: full access for verifying compliance.

The data carrier is essentially a QR code that physically appears on the battery and, via a unique identifier, leads to the online passport. Why it is worth using a standardised (GS1 Digital Link) identifier behind the QR, and how the same symbol can be both human- and machine-readable, is covered in a separate article: QR codes and GS1 Digital Link in the DPP.

The full timeline in one table

The Battery Regulation is not about a single date: the passport is just one milestone in a multi-year roadmap. The table below summarises the most important battery-related obligations.

Carbon footprint declaration: the most moving target

The carbon footprint declaration (Article 7 of the regulation) is staggered by battery type, and each date is tied to the condition of "either X months after the entry into force of the relevant delegated/implementing act, whichever is later". The plan is a grace period of 12 months after the legal act for EV batteries, and 18 months for industrial, LMT and stationary batteries.

In practice this is slipping: the delegated act setting out the carbon footprint calculation methodology for EV batteries had still not been finalised by mid-2026, so the nominal start date of 18 February 2025 has de facto shifted, and the compliance "clock" has not yet started. Open questions remain around system boundaries, data ownership and audit/verification. Anyone placing EV or industrial batteries on the market would do well to build up carbon footprint data collection now, but the precise, mandatory date will be fixed by the final legal act — so cautious, "expected"-style planning is warranted here.

Recycled content: declaration first, then mandatory minimums

For recycled content, two stages must be distinguished. First comes the declaration obligation (Article 8): from 18 August 2028, EV, SLI and industrial batteries above 2 kWh must state the share of recycled cobalt, lead, lithium and nickel present in the active materials (for LMT batteries from 18 August 2033). At this stage there is still no mandatory minimum — only the actual share needs to be documented.

These are followed by the mandatory minimum thresholds, below which the recycled content may not fall:

The stricter 2036 thresholds also cover LMT batteries. Importantly, these minimums are separate from the recyclers' material recovery targets (Annex XII): the latter concern how much must be recovered from waste batteries (by the end of 2027, lithium ≥50%, cobalt/copper/lead/nickel ≥90%; by the end of 2031, lithium ≥80% and the rest ≥95%), whereas the manufacturer thresholds concern how much recycled material goes into the new battery.

Due diligence: a postponed start

The due diligence obligations on responsible sourcing (Articles 48–53 of the regulation, of which Article 48 lays down the requirement for a due diligence policy) target the supply chains of cobalt, natural graphite, lithium and nickel, in line with the OECD guidance — without publicly disclosing supplier identity or place of origin. The original start date was 18 August 2025, but Regulation (EU) 2025/1561 ("stop-the-clock", part of the Omnibus IV simplification package) postponed it to 18 August 2027 by amending Article 48(1). This was adopted by the Council in July 2025 and published in the OJEU on 30 July 2025. The due diligence status is thus one of the passport fields whose content follows the postponed date.

What should an affected manufacturer or importer do now?

Because of the lead times for procurement, data collection and system integration, the date of 18 February 2027 is closer than it looks. A few concrete steps you can start now:

1. Clarify the product range: identify which of your SKUs fall into the EV, LMT or industrial-above-2 kWh categories — and which are excluded (for example SLI).
2. Introduce unique identification: every physical battery needs a unit-level identifier and QR code, not one at product-type level. It is worth choosing a standardised (GS1) identifier for this.
3. Build the data chain: gather material composition, carbon footprint inputs and recycled-content data from suppliers — these typically span several supplier tiers.
4. SoH and dynamic data: plan how state of health is updated over the battery's lifetime, and who may access it.
5. Set access levels: separate the public, authorised-party and authority fields.

Veridyn's battery passport solution covers exactly this workflow: unit-level identification, role-based access, carbon footprint and recycled-content fields, and QR code generation. If you want to walk through the preparation steps, our readiness checklist gives you a practical framework. Want to try it for real? Sign up free of charge, or get in touch for a specific discussion.

Summary

The battery passport is the EU's first mandatory digital product passport: under the EU Battery Regulation 2023/1542, it is mandatory from 18 February 2027 for every EV, LMT and industrial battery above 2 kWh. The passport contains a unique identifier, QR code, material and chemical composition, carbon footprint declaration, recycled content, performance and durability data, SoH and due diligence status, with three-tier access. The related carbon footprint and recycled-content thresholds take effect on a separate, partly slipping timeline — the exact dates are fixed by delegated acts. Anyone who starts data collection and identification now can be confident of being ready for the 2027 date.