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Battery Passport - EU Requirements, Mandatory Data and Timeline from 2027

What is a Battery Passport? Learn everything about the EU Battery Regulation 2023/1542, what data the Battery Passport must contain, who is affected and how to prepare for the obligation starting February 2027.

Author: myDPP Team

Battery Passport - EU Requirements, Mandatory Data and Timeline from 2027

The Battery Passport is the first Digital Product Passport (DPP) to become mandatory in the EU. From February 2027, industrial and traction batteries with a capacity exceeding 2 kWh must carry a digital passport that provides origin, composition, performance data and recycling information in a machine-readable format. This makes the Battery Passport not just a regulatory obligation but also a trailblazer for all future product categories under the ESPR.

In this article we explain what the Battery Passport is, what data it must contain, who is affected and how companies can prepare.

If you are not yet familiar with the Digital Product Passport topic in general, we recommend our introductory article: Digital Product Passport in 15 minutes.

What is a Battery Passport?

A Battery Passport is a digital data record that makes the essential information about a battery available in a structured and machine-readable way. It is linked to the physical battery via a unique identifier, typically through a QR code or a GS1 Digital Link.

The Battery Passport is not a voluntary label and not a marketing tool. It is a legal obligation arising from the EU Battery Regulation (Regulation (EU) 2023/1542). Every battery placed on the EU market that exceeds the capacity threshold must carry such a passport.

Unlike existing product data sheets or safety data sheets, the Battery Passport is:

  • Standardised - uniform data format and defined mandatory fields.
  • Digital and machine-readable - not just a PDF, but structured data that can be read and processed by software.
  • Lifecycle-oriented - it accompanies the battery from production through use to recycling.
  • Accessible to various stakeholders - manufacturers, market surveillance authorities, recyclers and (to a limited extent) consumers.

Legal basis - the EU Battery Regulation 2023/1542

Regulation (EU) 2023/1542 entered into force on 17 August 2023 and replaces the old Battery Directive (2006/66/EC). It is the first EU law to mandate a Digital Product Passport for a specific product category.

Key regulatory areas of the Regulation:

  • Supply chain due diligence - economic operators must trace the origin of critical raw materials (cobalt, lithium, nickel, natural graphite).
  • Carbon footprint - for traction batteries and rechargeable industrial batteries, manufacturers must declare the carbon footprint.
  • Recycling requirements - minimum quotas for material recovery and the share of recycled raw materials.
  • Performance and durability parameters - information on capacity, lifespan and energy density.
  • Battery Passport - the digital data record that brings all relevant information together.

The Battery Regulation is considered a blueprint for future DPP regulations under the ESPR. Companies that engage with the Battery Passport now are gaining valuable experience for upcoming product categories.

What data must the Battery Passport contain?

The Battery Regulation and the associated delegated acts define an extensive data catalogue. The mandatory data can be grouped into the following categories:

General product information

  • Manufacturer (name, registration number, contact details)
  • Place and date of manufacture
  • Battery type and chemistry
  • Weight and dimensions
  • Unique identifier

Composition and materials

  • Cathode materials and their proportions
  • Anode materials
  • Electrolyte type
  • Share of recycled raw materials (cobalt, lithium, nickel, lead)
  • Presence of critical raw materials and their countries of origin
  • Information on substances of concern

Carbon footprint

  • Carbon footprint of the battery over the lifecycle (in kg CO2 equivalent per kWh)
  • Carbon footprint performance class
  • Reference to the calculation methodology used

Performance data and durability

  • Rated capacity and rated voltage
  • Expected lifespan (in cycles and years)
  • Energy density (volumetric and gravimetric)
  • Minimum remaining capacity (State of Health indicators)
  • Temperature range for optimal operation

Circularity and recycling

  • Disassembly information (steps, tools, safety instructions)
  • Recyclability of the design
  • Information on second life use
  • Disposal instructions

Conformity and certification

  • EU Declaration of Conformity
  • Results of relevant tests
  • Reference to applied harmonised standards

Timeline - when does the Battery Passport become mandatory?

The timeline for the introduction of the Battery Passport is staggered:

MilestoneDate
Entry into force of the Battery RegulationAugust 2023
Carbon footprint declaration for EV and industrial batteriesFebruary 2025
Battery Passport obligation for traction and industrial batteries (> 2 kWh)February 2027
Minimum share of recycled raw materials (first stage)August 2031
Increased recycling quotas (second stage)August 2036

February 2027 is the key deadline. From that point, no affected batteries may be placed on the EU market without a compliant Battery Passport. This means: companies should not wait until 2027 to start preparing but need to build data structures and processes now.

Who is affected?

The Battery Passport affects the entire value chain:

Battery manufacturers and cell producers bear the primary responsibility for creating the Battery Passport. They must document composition, performance data and carbon footprint.

Automotive manufacturers and OEMs source batteries as components and must ensure that their suppliers deliver compliant Battery Passports. At the same time, they may need to add their own data (e.g. on vehicle integration).

Importers and authorised representatives are responsible when batteries from outside the EU are introduced to the European market. They must verify that a compliant Battery Passport is in place.

Recycling companies benefit from the Battery Passport as it provides disassembly and material information that enables more efficient recycling.

Market surveillance authorities use the Battery Passport to verify conformity - it is thus also an instrument of market surveillance.

How does the Battery Passport differ from the general DPP under the ESPR?

The Battery Passport is based on the Battery Regulation (2023/1542), while future DPPs for other product categories will be governed under the ESPR (Ecodesign for Sustainable Products Regulation). The key differences:

  • Legal basis - a standalone regulation vs. delegated acts under the ESPR.
  • Level of detail - the Battery Regulation defines very specific data fields, while ESPR DPPs will be specified separately for each product category.
  • Timeline - the Battery Passport comes earlier (2027), ESPR DPPs for other categories will follow from 2028-2030.
  • Technical architecture - the Battery Regulation envisages a central EU registry where Battery Passports are to be retrievable.

Despite these differences, the underlying logic is identical: structured, machine-readable product data linked to a unique identifier and accessible via a data carrier.

Preparing for the Battery Passport - 5 practical steps

1. Conduct a data inventory

Check which of the required data fields already exist in your systems (ERP, PLM, MES) and where gaps remain. Experience shows that 60-70% of the required data is typically already available, but it is scattered across different systems and not in the required format.

2. Build supply chain transparency

The requirements for the origin of critical raw materials demand data from upstream suppliers. Start early by engaging your suppliers and defining data formats and handover processes.

3. Calculate the carbon footprint

The carbon footprint declaration has been required since February 2025. If you have not yet completed this step, it should be your top priority, as the data feeds directly into the Battery Passport.

4. Evaluate IT infrastructure

A compliant Battery Passport requires a platform that consolidates data from various sources, converts it into the required format and provides it via standardised interfaces. Solutions like myDPP offer exactly this functionality - from data integration through passport creation to linking with GS1 Digital Link.

5. Start a pilot project

Do not start with the entire product portfolio. Choose one battery line or product type, create a pilot passport and identify challenges early.

Frequently Asked Questions (FAQ)

Does the Battery Passport also apply to batteries produced before February 2027?

No. The Battery Passport obligation applies to batteries that are placed on the market in the EU from the deadline onwards. Batteries already on the market are not retroactively affected. What matters is the date of placing on the market, not the production date.

Which battery types are affected?

The Battery Passport obligation from February 2027 applies to traction batteries (e.g. in electric vehicles) and rechargeable industrial batteries with a capacity exceeding 2 kWh. Portable batteries (e.g. in smartphones) and starter batteries are not affected in the first phase but may be added later.

Do manufacturers outside Europe also need to create a Battery Passport?

Yes. The Battery Regulation applies to all batteries placed on the EU market, regardless of the place of manufacture. Importers and authorised representatives in the EU bear the responsibility for ensuring a compliant Battery Passport is in place.

What happens in case of non-compliance?

The sanctions are determined by the Member States. The Battery Regulation stipulates that sanctions must be effective, proportionate and dissuasive. In practice, non-compliant batteries can be excluded from the EU market, which represents a significant business risk for manufacturers and importers.

Further reading

Sources

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