EU Battery Passport: Requirements and Deadlines

The battery passport is the first Digital Product Passport to become mandatory in the European Union. Under the Battery Regulation (EU 2023/1542), LMT batteries, industrial batteries above 2 kWh and EV batteries placed on the EU market must have a digital passport starting February 18, 2027. This is not a distant deadline — it is less than a year away.

Here is everything you need to know.

What is the EU Battery Passport?

The battery passport is a specific implementation of the Digital Product Passport (DPP) concept. It is set by the Battery Regulation itself, not by an ESPR delegated act, but it must be interoperable with the passports ESPR introduces. It is a structured digital record containing detailed information about a battery's composition, performance, manufacturing, and end-of-life handling.

The passport is accessible via a QR code on the battery, and the battery's unique identifier must be uploaded to the EU DPP Registry (launching July 19, 2026; update: live since 20 July 2026).

Which Batteries Are Covered?

The passport requirement (Article 77) applies to three categories:

Electric Vehicle (EV) Batteries

Traction batteries used in electric cars, buses, trucks, and other electric vehicles. This is the largest category by economic impact and the primary driver of the regulation.

Industrial Batteries

Batteries with a capacity above 2 kWh used in energy storage systems, industrial equipment, and similar applications. This includes stationary storage for renewable energy installations.

LMT Batteries

Light means of transport batteries — the batteries in e-bikes, e-scooters and similar light electric vehicles.

What is NOT Covered

Portable batteries (AA, AAA, button cells), SLI batteries (the 12V starter batteries in conventional vehicles) and industrial batteries of 2 kWh or less do not need a battery passport. Other parts of the regulation still apply to them.

Required Data Fields

The Battery Regulation specifies detailed data requirements. These go well beyond what most battery manufacturers currently track in their systems.

Identification and General Information

  • Unique battery identifier
  • Manufacturer name and contact
  • Manufacturing date and place
  • Battery weight and dimensions
  • Chemistry type (NMC, LFP, NCA, etc.)
  • Rated capacity and voltage

Performance and Durability

  • Original rated capacity (Ah)
  • Capacity fade (State of Health)
  • Cycle life expectation
  • Round-trip energy efficiency
  • Internal resistance
  • C-rate capability

Material Composition

  • Cathode active material composition
  • Anode material
  • Electrolyte composition
  • Critical raw material content (cobalt, lithium, nickel, manganese, natural graphite)
  • Recycled content percentage (mandatory minimums apply from 2031)

Supply Chain Due Diligence

  • Source of critical raw materials
  • Due diligence report summary
  • Compliance with OECD Due Diligence Guidance
  • Third-party audit results

Carbon Footprint

  • Total carbon footprint (kg CO2e per kWh)
  • Carbon footprint per lifecycle stage (raw material extraction, manufacturing, distribution)
  • Carbon footprint performance class (class A is the best; the classes are still to be set by delegated act)

End-of-Life Information

  • Disassembly instructions
  • Safety information for handling
  • Recycling process requirements
  • Hazardous substance content
  • Extinguishing agent requirements

The Carbon Footprint Rules

The Battery Regulation introduces a phased approach to carbon footprint requirements:

  1. Carbon footprint declaration — For EV batteries, from 18 February 2025 or 12 months after the Commission's calculation methodology enters into force, whichever is later. That delegated act had not been adopted by October 2026, so the obligation has not yet started.
  2. Carbon footprint performance classes — For EV batteries, from 18 August 2026 or 18 months after the delegated act setting the classes, whichever is later
  3. Maximum carbon footprint thresholds — For EV batteries, from 18 February 2028 or 18 months after the delegated act setting the threshold, whichever is later; batteries above it cannot be placed on the EU market

Industrial and LMT batteries follow on later dates (Article 7).

This means the battery passport is not just an information tool — it becomes a gate to market access. A battery with a high carbon footprint may literally be unsellable in the EU.

Technical Requirements

Data Carrier

Each battery must carry a QR code that links to the passport's unique identifier. The QR code and the identifier must comply with the ISO/IEC 15459 series or equivalent (Article 77(3)); a GS1 Digital Link is one way to meet that. The QR code must be:

  • Permanently affixed to the battery
  • Readable throughout the battery's expected lifetime
  • Scannable without specialized equipment

Data Accessibility

The passport must provide different access levels:

  • Public access — Basic product information, carbon footprint class, recycled content
  • Authorized access — Detailed composition, performance data, due diligence information
  • Regulatory access — Full dataset including confidential business information

State of Health Updates

Unlike most DPPs, battery passports must be updated over time. The State of Health (SoH) data must reflect actual battery performance, which means the passport needs integration with battery management systems (BMS).

This is a significant technical challenge. It requires connectivity between the physical battery, its BMS, and the DPP platform — throughout the battery's lifetime, including second-life applications.

The EU DPP Registry

The unique identifier of every battery passport must be uploaded to the EU DPP Registry (Battery Regulation Article 77(10), added by ESPR Article 78). ESPR required the registry by July 19, 2026; it went live on 20 July 2026. The registry acts as a central index — it does not store the full passport data, but it ensures every passport is findable, verifiable, and linked to the correct product.

For battery manufacturers, this means your DPP platform must support registry integration before the passport requirement kicks in on February 18, 2027.

Key Deadlines

Date Requirement
February 18, 2024 Battery Regulation applies (most provisions)
February 2025 or later Carbon footprint declaration for EV batteries — 12 months after a delegated act not yet adopted
July 20, 2026 EU DPP Registry live
February 18, 2027 Battery passport mandatory (LMT, industrial >2 kWh, EV)
Not yet fixed Carbon footprint performance classes — 18 months after their delegated act, EV batteries first
Not yet fixed Maximum carbon footprint thresholds — 18 months after their delegated act, EV batteries first
August 18, 2031 Mandatory minimum recycled content

Who is Responsible?

The economic operator placing the battery on the EU market is responsible for creating and maintaining the passport. In practice:

  • Cell manufacturers provide upstream data (chemistry, materials, carbon footprint)
  • Pack manufacturers compile the full passport
  • Importers must verify the passport exists and is accurate
  • Vehicle OEMs may have additional responsibilities for EV battery passports integrated into vehicles

The supply chain coordination challenge is significant. A typical EV battery involves materials from 5-10 countries, processed through multiple stages before reaching the pack manufacturer.

How to Prepare

Step 1: Map Your Data

Inventory every required data field against your current systems. Where does the data live? ERP? PLM? Supplier portals? Spreadsheets? Identify gaps immediately.

Step 2: Engage Your Supply Chain

Critical raw material due diligence and carbon footprint calculations require data from deep in your supply chain. These conversations need to happen now.

Step 3: Select a DPP Platform

You need a platform that handles:

  • Structured data hosting per the Battery Regulation requirements
  • GS1 Digital Link QR code generation
  • EU DPP Registry integration
  • State of Health update capabilities
  • Access control (public, authorized, regulatory)

DPP Agent provides the infrastructure for battery passport compliance, built on Blippa's proven DPP platform.

Step 4: Pilot Before the Deadline

Do not wait until January 2027 to test your system. Run a pilot with a product line now. Identify integration issues, data gaps, and process bottlenecks while there is still time to fix them.

The Broader Impact

The battery passport is a bellwether for all DPP requirements under ESPR. It sets the precedent for data granularity, supply chain transparency, and digital infrastructure that other product categories will follow. Companies that build robust systems for battery passports will have a significant advantage when textile, electronics, and other category requirements follow.

Check your battery DPP readiness now. The free assessment at dppagent.com gives you a clear gap analysis and action plan. Built by Blippa — powering Digital Product Passports for European industry.