Battery Passport 2027: Obligations, Deadlines & Data Requirements for Manufacturers
DPP · BATTERY PASSPORT
From 18 February 2027, the digital battery passport is mandatory — for every electric-vehicle, industrial (over 2 kWh) and LMT battery you place on the EU market. The good news: at its core, the battery passport is not a compliance monster but a data task. If you keep your product data structured, complete and up to date today, you will meet the obligation later at the push of a button — not as an emergency project three months before the deadline. That is exactly the thesis we carry through this article: the battery passport is decided not by the technology, but by your data foundation.
In this article you will get the hard facts (date, threshold, affected battery types), the list of required data fields, a clear distinction between the EU Battery Regulation and the general digital product passport under the ESPR — and an honest plan for what you should do now.
As of July 2026. The Battery Regulation is settled, the start date is settled. What is still moving are the detailed rules in the delegated acts (access rights, register connection). We flag these points in the text and will update them before editorial close.
When the battery passport applies — and to whom (Feb 2027, 2 kWh)
The legal basis is Regulation (EU) 2023/1542 (the EU Battery Regulation). It was published in the Official Journal of the EU on 28 July 2023 and entered into force on 17 August 2023. The obligations, however, apply in stages — the digital battery passport is one of the last major building blocks.
The key date: from 18 February 2027, every battery in the affected categories that is placed on the market or put into service must have a digital battery passport, accessible via a QR code on the battery.
Three categories are affected:
| Battery type | Threshold | Examples |
|---|---|---|
| Electric-vehicle batteries (EV) | no kWh threshold (category-based) | traction batteries for EVs, hybrids, electric motorcycles |
| Industrial batteries | > 2 kWh | stationary storage, industrial applications |
| LMT batteries (light means of transport) | category-based | e-bikes, e-scooters, electric mopeds |
The frequently cited 2 kWh threshold applies precisely to industrial batteries. EV and LMT batteries fall under the passport obligation by category, without the 2 kWh limit being the decisive trigger. This distinction matters — shorthand claims like “battery passport for all batteries over 2 kWh” are not quite correct.
A second point on scope: the QR-code labelling obligation applies from February 2027 to essentially all battery types — even portable batteries below the passport threshold must carry a QR code. Only the full battery passport behind it is limited to the three categories named above.
Who is responsible
Responsibility for the battery passport lies with the economic operator placing it on the market — typically the manufacturer, and in certain constellations the importer or distributor. This operator is liable for the accuracy, completeness and currency of all passport information — not only at the point of sale, but continuously over the lifecycle, including the use, reuse and recycling phases.
This is exactly where many projects go wrong in their thinking: the battery passport is not a document you create once and file away. It is a living data record that must be updated whenever the battery’s status changes (repurposing, remanufacturing, transition into the waste phase). Without a system that maintains and versions product data centrally, this quickly becomes expensive.
The required data fields (Annex XIII)
What specifically must go into the passport is governed by Article 77 in conjunction with Annex XIII of the Regulation. For EV batteries alone, the catalogue comprises roughly 80 to over 100 data points (depending on the source and counting method) across the entire lifecycle. The fields are divided into tiered access levels.
Publicly accessible (to anyone via QR code):
- manufacturer/producer identification, place and date of manufacture
- product identification (batch and serial numbers)
- battery category, weight, capacity
- chemical composition (basic data)
- carbon footprint and supply-chain due diligence on raw materials
- recycled content and share of renewable materials
- technical performance and durability parameters (e.g. capacity, voltage, service life)
- EU declaration of conformity, collection and recycling information
Only for actors with a legitimate interest and authorities (repair, remanufacturing and recycling operators, notified bodies, market surveillance, the European Commission):
- detailed material composition
- state of health (SoH), charge cycles, ageing status
- disassembly and safety instructions
- documented incidents and technical test reports
The SoH value is a good example of why the passport is a living data record: it reflects the current lifecycle status of the individual battery and must be updated on repurposing, reuse or remanufacturing.
If you look at this list, you will spot the pattern: almost all of it is product data that already exists within the company — just scattered across ERP, spreadsheets, supplier documents, lab reports and PDFs. The real work is not inventing this data, but consolidating, normalising and keeping it current in one central place. That is the core competence of a PIM/product-data system — and the reason we say: whoever builds the data foundation now will meet the passport requirement later at the push of a button.
Distinction: EU Battery Regulation vs. ESPR DPP
A lot of confusion arises here in practice, so let us make it explicit. There are currently two parallel regulatory tracks around the digital product passport:
| Battery passport | Digital product passport (DPP), general | |
|---|---|---|
| Legal basis | EU Battery Regulation (EU) 2023/1542 | Ecodesign Regulation ESPR (EU) 2024/1781 |
| Scope | batteries only (EV, industrial > 2 kWh, LMT) | progressively many product groups (textiles, electronics, furniture, etc.) |
| Start date | fixed: 18 February 2027 | staggered per product group via delegated acts (from ~2027 onwards) |
| Character | standalone, battery-specific information obligation | framework instrument for the broad DPP wave |
Important for context: the battery passport is the pioneer in timing. It came before the ESPR DPP and is regarded as its “blueprint”. Technically it aligns with the same standardised DPP data formats, but legally it is a standalone instrument (lex specialis) — not simply “the DPP for batteries under the ESPR umbrella”. So if you are thinking about the ESPR timeline for other product groups, you should treat the battery passport as a separate, earlier deadline.
You will get the full ESPR roadmap with all product groups and deadlines in the series article “Digital Product Passport: Timeline & Deadlines 2026–2030” (appears 14 October 2026). This article here is the battery deep-dive that goes with it.
The deadlines at a glance (as of July 2026)
Besides 18 February 2027, there are two more dates you should know:
- 18 August 2026 — deadline for the European Commission to adopt the central delegated act on Article 77. It governs detailed questions such as access rights and the rules for introducing, changing and updating the passport information. (As of July 2026: recheck this point before publish — the regulation is volatile here.)
- 18 August 2026 — from this point, labelling in carbon-footprint performance classes additionally applies to traction batteries (once the Commission publishes the thresholds per class).
- 18 February 2027 — the digital battery passport and the QR-code obligation take effect.
For orientation, the rule of thumb is enough: the actual battery-passport cutoff is February 2027. The 2026 dates concern upstream labelling and detailed rules.
What you should do now
No alarmism, but no procrastination either. Five steps worth taking from today:
- Clarify whether you are affected. Do you place EV, LMT or industrial batteries (> 2 kWh) on the EU market — including built into devices or vehicles? Then you are an operator placing them on the market within the meaning of the Regulation.
- Map your data gaps. Go through the Annex XIII fields and mark which data is already available cleanly and which is stuck in PDFs, emails or suppliers’ heads. This is usually the most sobering but most important step.
- Build a single source of truth. Consolidate product data in one place instead of maintaining it separately per channel. That is exactly what a master-data/PIM approach delivers — see our foundational piece on Master Data Management.
- Involve the supply chain. Carbon footprint, recycled content and due-diligence evidence rarely come from your own house alone. Clarify early how you will obtain this data from suppliers in a structured form.
- Define an update process. The passport lives. Determine who updates the SoH and lifecycle status, and when — technically and organisationally.
If your product data is structured, complete and centrally maintained, the battery passport becomes an output function rather than a project: the attributes are in place, the passport is generated, the QR code points to it. That is the difference between “at the push of a button” and “firefighting just before the deadline”.
FAQ
When does the battery passport apply?
From 18 February 2027 for all affected batteries placed on the EU market or put into service from that date onward. The legal basis is the EU Battery Regulation (EU) 2023/1542.
Which batteries need a battery passport?
Electric-vehicle batteries (EV), LMT batteries for light means of transport (e-bikes, e-scooters) and industrial batteries with a capacity over 2 kWh. The QR-code labelling itself applies more broadly to all battery types.
Does the 2 kWh threshold apply to all batteries?
No. The 2 kWh limit specifically concerns industrial batteries. EV and LMT batteries fall under the passport obligation by category, regardless of this threshold.
Who is responsible for the battery passport?
The economic operator placing it on the market — usually the manufacturer, sometimes the importer or distributor. They are continuously liable for the accuracy, completeness and currency of the data, including during use and recycling.
What data must the battery passport contain?
Roughly 80 to over 100 data points (depending on the source and counting method) under Annex XIII — including manufacturer and product identification, chemical composition, carbon footprint, recycled content, technical performance data, plus (for authorised actors) state of health/SoH, charge cycles and disassembly instructions. The fields are tiered into public and access-restricted levels.
What is the difference between the battery passport and the digital product passport (DPP)?
The battery passport is based on the Battery Regulation (EU) 2023/1542 and applies only to batteries, with a fixed start in 2027. The general DPP is based on the ESPR (EU) 2024/1781 and is introduced in stages for many product groups. The battery passport is the pioneer in timing and legally standalone.
What happens in the event of non-compliance?
Without a valid battery passport, an affected battery may not be placed on the market from February 2027 — risking market-access bans and sanctions from national market surveillance. (Specific fine levels follow from national implementing rules — check the current status before publish.)
Ready to make your product data battery-passport-ready?
The battery passport is 90% a data task. With a clean, central product-data foundation, you meet Annex XIII without setting up a new project for every deadline. See how this works with our platform.