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Create your digital product passports in no time and with minimal effort.
Which batteries need a passport?
Article 77 of the Batteries Regulation sets the scope. Portable batteries and starter batteries are outside it, but they still get a QR code requirement of their own.
| Battery type | Examples | Battery passport from 18 Feb 2027 | QR code from 18 Feb 2027 |
|---|---|---|---|
| Electric vehicle (EV) batteries | Traction batteries in cars, vans, trucks | Yes | Yes |
| LMT batteries | E-bikes, e-scooters, e-mopeds | Yes | Yes |
| Industrial batteries above 2 kWh | Home storage, forklifts, stationary storage | Yes | Yes |
| Industrial batteries up to 2 kWh | Smaller industrial packs | No | Yes |
| Portable batteries | Phones, laptops, power banks, AA cells | No | Yes |
| SLI batteries | Starter batteries in combustion cars | No | Yes |
If your batteries sit in the lower half of that table, you don't need a passport, but you do need a QR code that leads to label information and the declaration of conformity. We cover that case in batteries without a passport. E-bike and e-scooter brands have their own specifics, see our battery passport guide for e-bikes and LMT.
Who is responsible for the battery passport?
The economic operator that places the finished battery on the EU market. That is usually the manufacturer, or the importer if the battery comes from outside the EU. Suppliers of cells or modules are not responsible for the passport, although you will need their data to fill it.
You can hand the technical work to a service provider, but not the legal responsibility. When a battery is repurposed, remanufactured or prepared for reuse, the operator doing that work creates a new passport that links back to the original one.
What goes into the battery passport?
Annex XIII of the regulation lists the content. On 21 August 2026 the Commission published updated guidance, "Digital Batteries Passport: data points by category", which breaks that content down into 71 data points and marks each one per battery category as mandatory, optional, conditional, or not required as of February 2027. The guidance is not legally binding, but it is the closest thing to an official checklist.
The data points fall into roughly six groups:
- Identification and general information: manufacturer, battery model, unique identifier, category, place and date of manufacture, weight
- Compliance and labels: declaration of conformity, symbols, hazardous substances, critical raw materials
- Carbon footprint: the declaration and performance class, once the relevant delegated act applies
- Supply chain due diligence: the due diligence report and third-party verification
- Materials and composition: cathode, anode and electrolyte materials, recycled content shares
- Performance, durability and end of life: rated capacity, voltage, expected lifetime, state of health, dismantling and safety information
Not every field has to be filled on day one. Carbon footprint fields follow the timeline of Article 7, and the delegated act with the calculation method for EV batteries had still not been adopted in September 2026. The Omnibus IV package postponed the battery due diligence obligations to 18 August 2027. Recycled content phases in under Article 8. The Commission guidance tells you which fields can stay empty in February 2027 for your category. Many of these attributes (materials, recycled content, hazardous substances) also show up in ESPR and packaging rules, see one product data model.
Who can see which battery passport data?
The battery passport is not one open web page. Annex XIII splits the data into access groups:
| Access level | Who | Typical content |
|---|---|---|
| Public | Anyone who scans the QR code | General information, capacity, chemistry, hazardous substances, carbon footprint, recycled content |
| Legitimate interest, model data (Annex XIII point 2) | Persons with a legitimate interest, such as repairers, remanufacturers, second-life operators and recyclers, and the Commission | Detailed composition, part numbers, dismantling and safety information |
| Test reports (Annex XIII point 3) | Notified bodies, market surveillance authorities, the Commission | Test reports proving compliance |
| Legitimate interest, battery-specific data (Annex XIII point 4) | Persons with a legitimate interest | Data about the individual battery, such as state of health |
One piece is missing: the implementing act that defines who counts as having a "legitimate interest" was due on 18 August 2026 and missed that date. The Commission now lists it for Q4 2026. We explain what that means for your build in battery passport access rights.
Is the battery passport per battery or per model?
Many teams underestimate this. An ESPR passport for a T-shirt will often work at model level. The battery passport works at item level: each battery gets its own unique identifier and its own passport, and some data (state of health, for example) changes over the battery's life.
That has direct consequences for your systems. Your PIM holds model data. Serial numbers usually live in ERP or MES. State of health comes from the battery management system. The passport has to pull all three together for each battery and stay available after the battery changes hands. It's the same problem we describe in digital twin vs. digital product passport: without a persistent identity per item, you can't build this properly.
How does the battery passport connect to the EU registry and DPP standards?
Battery passports are registered in the EU Digital Product Passport registry, which went live on 20 July 2026 (see our registry launch article). Implementing Regulation (EU) 2026/1778 explicitly treats the battery passport as a digital product passport. Before you can register a single battery, your company must become a verified economic operator through an eIDAS identity check. We walk through the steps in how to register a DPP in the EU registry.
On the technical side, six harmonised standards (EN 18216, EN 18219, EN 18220, EN 18221, EN 18222 and EN 18223) have been cited since July 2026 and cover identifiers, data carriers, APIs, data exchange, storage and interoperability, see Implementing Decision 2026/1736 explained. The two standards for access rights (EN 18239) and data authentication (EN 18246) weren't finished yet in September 2026.
How to prepare for the battery passport by February 2027
- Confirm which of your batteries are in scope and in which category. Home storage above 2 kWh is industrial, not portable.
- Download the Commission's data point guidance and map each mandatory field to a source system and an owner.
- Decide how each battery gets its unique identifier and how that identifier reaches the QR code on the battery.
- Request the data you don't have from cell and module suppliers now. Composition and materials data is usually the slowest part.
- Get your eIDAS credentials (a qualified electronic seal for companies) sorted before you need to register.
- Build the public layer first, and design the restricted layer so roles can change once the access rights act lands.
"The data format is the smaller problem with the battery passport. The harder part is that every battery needs its own record, and that record still has to be right years later, when the battery has long ended up in a home storage system or with a recycler."
Benedikt Biallowons, CTO, dpp.cloud
How dpp.cloud fits
dpp.cloud was built so that every physical product can have its own persistent record, which is how the battery passport works too. We connect to the systems where your data already lives, Akeneo, SAP and other PIM and ERP systems, map it to the passport structure and publish it behind a QR code. If you're weighing this against an internal project, our build-vs-buy comparison lays out the real costs.
Five months is enough time if you start with the data mapping now. Book a strategy session and we'll go through your battery categories and data sources with you.
Sources
- Regulation (EU) 2023/1542 (Batteries Regulation), EUR-Lex: eur-lex.europa.eu/eli/reg/2023/1542/oj
- European Commission, Digital Batteries Passport: single-market-economy.ec.europa.eu
- European Commission, guidance to support preparations for the Digital Batteries Passport (21 August 2026): single-market-economy.ec.europa.eu/news
- Implementing Regulation (EU) 2026/1778 (DPP registry), EUR-Lex: eur-lex.europa.eu
