DPP · BATTERY PASSPORT
Battery Passport 2027: Obligations, Deadlines & Data Requirements for Manufacturers
From 18 February 2027, LMT batteries, electric vehicle batteries and industrial batteries with a capacity greater than 2 kWh require a digital battery passport when placed on the EU market or put into service from that date. The 2 kWh threshold applies only to industrial batteries. The passport contains information about the model and the individual battery, accessed through a QR code and unique identifier.
A reliable data foundation supports implementation. It does not replace specialist evidence, passport operation, access controls, registration or updates. PIM can support part of this data work. It does not establish compliance “at the push of a button”.
Sources reviewed: 9 November 2026. The basis is the consolidated Batteries Regulation, dated 13 August 2026, particularly Articles 13, 77, 78 and Annex XIII, together with the linked Commission information. apollon explains these for product data projects; applicability needs assessment for each battery and market role.
Scope · Data and access · Dates · Preparation · FAQ
When does the battery passport apply, and which batteries are covered?
Article 77(1) identifies three categories. Classify a battery using the definitions in Article 3, rather than relying only on a product name such as “electric scooter battery”.
| Category | Trigger for the passport obligation | Example and distinction |
|---|---|---|
| Electric vehicle battery (EV) | Category under Article 3; no general 2 kWh threshold | Traction batteries for electric or hybrid vehicles; battery weight also matters for category L vehicles. |
| Industrial battery | Capacity greater than 2 kWh | For example stationary storage or other industrial applications; check the statutory category. |
| Light means of transport battery (LMT) | Category under Article 3; no general 2 kWh threshold | For example e-bike or e-scooter batteries within the legal definition. |
“Placing on the market” means first making a battery available on the EU market. “Putting into service” concerns first use for its intended purpose in the EU where the battery has not previously been placed on the market. This matters for own use and supply chains. Resale is not automatically a new first placing on the market.
QR codes and battery passports are separate obligations
Article 13(6) requires QR-code marking for all batteries from 18 February 2027. For the three categories above, the code provides access to the battery passport; for other categories, it leads to their required information. A battery with a QR code therefore does not necessarily require a full battery passport.
The code must be visible, legible and indelible on the battery. Where this is not possible or warranted because of the battery’s nature and size, Article 13(7) specifies packaging and accompanying documents as alternatives. Assess the actual marking together with passport delivery.
Who is responsible for the battery passport?
Under Article 77(4), the economic operator placing the battery on the market must ensure that passport information is accurate, complete and up to date. It may authorise another operator in writing to act on its behalf. Service agreements should therefore specify tasks, sources, approvals, access and availability.
Responsibility does not necessarily remain unchanged with the original manufacturer. After preparation for reuse or repurposing, repurposing or remanufacturing, Article 77(7) provides for a transfer of responsibility. The subsequently responsible operator creates a new passport linked to the original passport. The Regulation identifies further responsible actors when the battery becomes waste. Under Article 77(8), the passport ceases to exist after recycling. An unconditional, perpetual maintenance obligation for the original operator would therefore be incorrect.
For project organisation, maintain technical data and responsibilities together. Define who approves changes, how status changes are reported and how access to required information is retained through a handover.
What data must the battery passport contain?
Article 77 and Annex XIII distinguish model information from individual-battery data. Not every listed data point applies equally to every category. Carbon footprint, recycled content and due diligence requirements also have their own application rules. A list of possible fields is therefore not a list of every mandatory field to complete on 18 February 2027.
The Commission provides a data-point overview by battery category. Its page identifies 19 October 2026 as the latest revision, including clarifications on formats and access rights. The explanatory announcement from August distinguishes mandatory, optional, conditionally applicable and not-yet-required entries at the start date. The guidance supports legal assessment and does not create additional statutory obligations.
| Area under Annex XIII | Examples | Distinguish access carefully |
|---|---|---|
| Public model information | Identification, category, basic composition, performance, declaration of conformity; other information according to applicability | Public information does not mean all confidential model or usage data are public. |
| Restricted model information | Detailed composition, spare parts, dismantling and safety | Apply legitimate-interest and authority/Commission access rights under Article 77 and Annex XIII. |
| Conformity test reports | Test results demonstrating compliance | Notified bodies, market surveillance authorities and the Commission. |
| Individual-battery data | Performance and durability, state of health, status, usage including cycles and negative events | Access for entitled persons under applicable rules; not general publication of all usage data. |
This table explains information groups. Implementation needs each data point mapped to category, legal source, access and timing. Add source, format, unit, approval and update trigger. Keep “not applicable”, “not yet required”, “unknown” and a confirmed measured value separate.
State of health needs an appropriate source
The condition of an individual battery cannot be derived from a generic product description. Usage and condition data need suitable technical sources, such as the battery management system, and an agreed transfer and update process. PIM is neither a measuring instrument nor a battery management system. It can manage relevant master data and relationships used in the handover.
Battery passport and ESPR DPP: distinct legal bases, connected systems
The battery passport is based on the Batteries Regulation 2023/1542. The general DPP framework is in the ESPR 2024/1781. The battery-passport date therefore does not await a product-specific ESPR act. At the same time, Article 78 requires interoperability with other product passports, and Article 77(10) refers to the Registry under ESPR Article 13.
The Commission launched the DPP Registry on 20 July 2026, together with a testing environment. The Registry contains unique identifiers and associated registration data. Complete passport data remain with the responsible company or its authorised operator. Plan registration and full passport operation as distinct tasks.
Article 78 requires controlled access and update rights, authenticity, integrity, security and availability even after the responsible operator ceases activity. A registration identifier or QR code alone does not fulfil these requirements. Our DPP guide explains the cross-sector framework.
Interpret deadlines and detailed rules correctly
| Topic | Rule | Planning implication |
|---|---|---|
| Battery passport | Article 77(1) | 18 February 2027 for the specified categories placed on the market or put into service. |
| QR code | Article 13(6) | 18 February 2027; distinguish scope and linked information by category. |
| Legitimate interest and access | Article 77(9) | 18 August 2026 was the statutory deadline for Commission implementing acts, not an alternative passport start date. Check current publications separately. |
| EV carbon-footprint performance classes | Article 7(2) | 18 August 2026 or 18 months after the relevant delegated or implementing acts enter into force, whichever is later. The calendar date alone is not an unconditional start. |
| Battery due diligence | Articles 47 and 48 | For covered operators from 18 August 2027; check scope and exemptions. This does not postpone the passport obligation. |
The Commission portal places the implementing act on battery access rights in Q4 2026 in its indicative timeline. A planning entry does not replace a published act or assessment of it. Keep the obligation’s start, the Commission’s deadline and actual publication separate.
Prepare the battery passport in five practical steps
1. Record categories and market roles
For each product family, document battery type, capacity where relevant, and placing on the market or putting into service. Establish your company’s actual role. A supplier of individual components is not automatically the creator of the finished battery’s passport.
2. Build a data matrix with evidence
Use Annex XIII and the current Commission overview. Assign each applicable data point to a source and owner. Check calculations, measurements and supplier evidence. Not all required information already exists in ERP systems or product data sheets.
3. Connect master data and individual-battery data
Link the model, individual battery, unique identifier and supporting documents. Determine authoritative systems. PIM/DAM can manage product information and evidence; BMS, specialist systems or other sources provide different parts. Our MDM guide explains the foundations of clear data ownership.
4. Test the passport, Registry and access controls
Test the complete route from approved data to the QR code, passport view and registration. Include denied access, failed transfers, corrections and recovery. A successful public display is only one part of acceptance.
5. Organise updates and handovers
Agree how changes in condition, reuse, repurposing, remanufacturing and waste status are handled. Test links to a new passport and transfer of responsibility. Include availability, operator changes and termination after recycling.
A suitable pilot case: A battery receives a new status. Check that the responsible operator is identified, permitted information is updated and the relationship to the previous passport remains intact. This is a practical acceptance scenario, not a claim about a completed customer project.
Frequently asked questions about the battery passport
When does the battery passport apply?
From 18 February 2027 for batteries specified in Article 77 that are placed on the market or put into service from that date. Other requirements of the Batteries Regulation have their own dates and conditions.
Does every battery above 2 kWh need a passport?
The precise scope is industrial batteries above 2 kWh, plus LMT and electric vehicle batteries according to their statutory categories. For the latter two categories, the 2 kWh threshold is not the trigger. Check classification under Article 3.
Which data must be available at the start date?
Check Annex XIII, the relevant articles and their application dates for the specific category. The Commission overview supports that mapping. Not every described data point is mandatory for every category and at the same time.
Can a service provider operate the passport?
Article 77 permits written authorisation. Data operation, access and availability must fulfil Article 78. Define responsibilities and handovers explicitly; a hosting contract alone does not demonstrate complete fulfilment.
Does the original manufacturer always remain responsible?
No. The Regulation provides for responsibility transfers, including after repurposing or remanufacturing and when a battery becomes waste. A new passport may need linking to the original. The passport ceases to exist after recycling.
Is a PIM system or PDF sufficient?
PIM can support product data maintenance; a PDF may provide evidence. Neither automatically replaces the structured, access-controlled passport, unique identifier, registration and update processes. The complete agreed workflow must be demonstrated.
What happens in the event of non-compliance?
A missing or non-compliant required passport can lead to market surveillance measures. Specific measures and penalties depend on applicable law and national rules. This article does not assume a universal fine amount.
Further information
Prepare product data and evidence for the battery passport
Bring your battery categories, data sources and existing evidence. We can assess OMN’s contribution to product information and documents, and identify additional specialist systems, passport services and integrations needed.