Battery Passport Requirements Under ESPR

The Battery Regulation: First Sector to Require Digital Product Passports

The European Union's Battery Regulation (EU) 2023/1542, which entered into force on 17 August 2023, makes batteries the very first product category to require mandatory Digital Product Passports under EU law. This regulation is both a standalone piece of legislation and a precursor to the broader DPP requirements that will be rolled out under the Ecodesign for Sustainable Products Regulation (ESPR).

The Battery Regulation applies to all batteries placed on the EU market, including portable batteries, automotive batteries, electric vehicle (EV) batteries, light means of transport (LMT) batteries, and industrial batteries. However, the DPP requirement specifically targets EV batteries, LMT batteries, and industrial batteries with a capacity above 2 kWh, the categories with the most significant environmental impact and the greatest potential for circular economy interventions.

Battery Passport at a Glance

The significance of the Battery Regulation extends far beyond the battery sector itself. It serves as a template and testing ground for the DPP concept, establishing precedents for data requirements, technical standards, and enforcement mechanisms that will inform the delegated acts developed under the ESPR for other product categories. Businesses in every sector should be paying close attention to how battery passport requirements are implemented, as similar approaches are likely to be replicated elsewhere.

With the compliance deadline of February 2027 now clearly on the horizon, battery manufacturers, EV producers, and industrial battery suppliers must be well advanced in their implementation efforts. The window for preparation is closing rapidly.

The February 2027 Deadline: What It Means in Practice

From 18 February 2027, every EV battery, LMT battery, and industrial battery with a capacity above 2 kWh placed on the EU market must be accompanied by a Digital Product Passport. This means that products manufactured or imported after this date must have a compliant battery passport at the point of sale, there is no grace period for products already in production pipelines.

The timeline implications are particularly significant for businesses with long product development cycles. An EV battery that will be manufactured in early 2027 is likely already in the advanced stages of design and testing. If the DPP requirements have not been integrated into the product design and data management process, retrospective compliance will be difficult and costly.

For importers, the deadline applies at the point of placing the product on the EU market, not at the point of manufacture. This means that batteries manufactured before February 2027 but imported into the EU after that date will need to comply. Importers must ensure their non-EU suppliers understand this requirement and can provide the necessary data in the required format.

Market surveillance authorities will begin enforcement from the compliance date. Products found to be non-compliant may be refused entry at EU borders, removed from the market, or subject to financial penalties. Given the high value of EV and industrial batteries, the financial exposure from non-compliance is substantial.

Specific Data Requirements for Battery Passports

The Battery Regulation specifies a detailed and extensive set of data requirements for the battery passport. These go significantly beyond what most battery manufacturers currently disclose and require data collection across the entire battery lifecycle. The Digital Product Passport must include:

• Battery identification: Manufacturer details, manufacturing date and place, battery model and batch or serial number, weight, and a unique identifier linked to the DPP.
• Capacity and performance: Rated capacity, expected lifetime expressed in cycles and calendar years, charge and discharge rates, round-trip energy efficiency, and internal resistance.
• State of health (SoH): For batteries in use, real-time or regularly updated data on state of health, including remaining capacity relative to original rated capacity and state of charge.
• Carbon footprint: The carbon footprint of the battery manufacturing process, calculated using the methodology specified in the regulation, expressed as kg CO2 equivalent per kWh of battery capacity.
• Recycled content: The share of recycled cobalt, lithium, nickel, and lead used in the battery, verified through chain-of-custody documentation.
• Hazardous substances: Information on hazardous substances contained in the battery, including those on the REACH candidate list, with details of their location within the battery.
• Supply chain due diligence: Documentation of due diligence policies and practices relating to the sourcing of raw materials, particularly cobalt, lithium, natural graphite, and nickel.
• Collection and recycling information: Details of available collection schemes, recycling processes, and the role of the producer in facilitating end-of-life management.
• Dismantling and safety information: Instructions for the safe removal, handling, and transport of the battery, including any specific safety precautions required.

The Battery Passport Unique Identifier and QR Code

Each battery subject to the DPP requirement must carry a unique identifier that links to its Digital Product Passport. This identifier must be machine-readable and accessible via a data carrier affixed to the battery itself. The regulation specifies that a QR code must be used as the primary data carrier, though additional data carriers may also be employed.

The GS1 Digital Link standard is expected to play a central role in the technical implementation of battery passport identifiers. GS1 Digital Links encode product identification data in a web URI format that can be resolved to the DPP data, providing a standardised, interoperable approach to linking physical products with their digital twins.

The QR code must be affixed to the battery in a manner that ensures it remains readable throughout the battery's lifetime. Given that EV and industrial batteries can have operational lifetimes of 10 to 15 years or more, this requires careful consideration of label materials, printing methods, and placement. The QR code must withstand the physical and environmental conditions the battery will be exposed to, including temperature extremes, vibration, and potential contact with chemicals.

The unique identifier system must also support the updating of DPP data over the battery's lifetime. Unlike many consumer products, batteries are dynamic, their state of health changes with use, they may be refurbished or repurposed, and their ownership may change multiple times. The DPP system must be able to accommodate these updates whilst maintaining data integrity and an auditable history of changes.

Carbon Footprint Declaration and Performance Classes

One of the most significant requirements of the Battery Regulation is the mandatory carbon footprint declaration. From 18 February 2025, all EV batteries placed on the EU market must carry a carbon footprint declaration. From 18 August 2026, carbon footprint performance classes will be introduced, and from 18 February 2028, maximum carbon footprint thresholds will apply.

The carbon footprint data must be calculated using the methodology specified in the Commission Delegated Regulation, which covers the entire lifecycle of the battery from raw material extraction through manufacturing to end-of-life. This requires detailed data from across the supply chain, including the energy mix used in manufacturing facilities, transport distances and modes, and the carbon intensity of raw material extraction processes.

The progressive tightening of carbon footprint requirements, from disclosure, to performance classes, to maximum thresholds, creates a clear trajectory towards lower-carbon batteries. Manufacturers that invest early in decarbonising their production processes and supply chains will be best positioned to meet increasingly stringent thresholds, whilst those that delay may find their products excluded from the EU market.

For battery passport purposes, the carbon footprint data must be included in the DPP and updated as the calculation methodology is refined. This requires ongoing data collection and calculation capabilities, not just a one-time assessment. Businesses need systems that can manage carbon footprint data as a living dataset that evolves over time.

Supply Chain Due Diligence: Cobalt, Lithium, and Beyond

The Battery Regulation imposes extensive supply chain due diligence obligations on economic operators, reflecting the significant human rights and environmental risks associated with the extraction of battery raw materials. Cobalt mining in the Democratic Republic of Congo, lithium extraction in South America, and nickel production in Indonesia all raise serious concerns about child labour, unsafe working conditions, environmental degradation, and community displacement.

The due diligence requirements are modelled on the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. Economic operators must establish and implement a supply chain due diligence policy, identify and assess risks in their supply chain, implement strategies to mitigate identified risks, carry out independent third-party audits, and report publicly on their due diligence practices.

The battery passport must include documentation of these due diligence efforts. This creates a direct link between supply chain responsibility and product compliance, a battery that cannot demonstrate adequate due diligence will not have a compliant passport and will therefore be barred from the EU market.

For businesses sourcing battery raw materials, this requires establishing traceability systems that can track materials from mine to finished product. This is particularly challenging for materials like cobalt and lithium, which pass through multiple intermediaries and processing stages between extraction and incorporation into a battery cell. Industry initiatives such as the Global Battery Alliance's Battery Passport and the Responsible Minerals Initiative can provide frameworks and tools to support this effort.

Practical Implementation Guide for Battery Passports

Implementing a battery passport system requires coordination across multiple functions within a business and across the supply chain. The following practical guide outlines the key steps for battery manufacturers, EV producers, and industrial battery suppliers.

Start with a data gap analysis. Compare the data you currently hold for each battery product against the full list of DPP requirements in the regulation. For many manufacturers, data on basic specifications (capacity, voltage, chemistry) will already be available, but data on carbon footprint, recycled content, and supply chain due diligence may require significant new collection efforts.

Establish data exchange agreements with your supply chain partners. You will need data from cell manufacturers, component suppliers, and raw material producers. These agreements should specify the data points required, the format and frequency of data provision, and the responsibilities of each party for data accuracy and verification.

Select and implement a battery passport platform. The platform must support the unique identifier system required by the regulation, generate compliant QR codes, host the DPP data for the lifetime of the battery (which may be 15 years or more), and support data updates as the battery's state of health changes over time. MyProductPassport offers battery-specific DPP capabilities designed to meet these requirements.

Integrate battery passport data collection into your manufacturing processes. The most efficient approach is to capture DPP data as part of the production process, drawing on quality management systems, manufacturing execution systems, and enterprise resource planning platforms. Retrofitting data collection after manufacturing is significantly more expensive and error-prone.

State of Health Monitoring and Dynamic Data

Unlike most product categories, batteries require dynamic data in their DPPs. The state of health of a battery changes continuously with use, capacity degrades, internal resistance increases, and the battery's suitability for its intended application may diminish. The Battery Regulation requires that the battery passport be updated to reflect these changes, creating a living digital record of the battery throughout its operational life.

This dynamic data requirement has significant technical implications. Battery management systems (BMS) must be capable of capturing and transmitting state-of-health data, and the DPP platform must be able to receive and store these updates. For EV batteries, this data may be transmitted via the vehicle's connectivity systems; for stationary industrial batteries, dedicated monitoring and communication infrastructure may be needed.

The dynamic nature of battery passport data also supports the growing second-life battery market. When an EV battery reaches the end of its useful life in a vehicle (typically at 70-80% of original capacity), it may still be suitable for less demanding applications such as stationary energy storage. The battery passport provides potential second-life users with the data they need to assess the battery's condition and suitability, facilitating the transition from first to second life.

Accurate state-of-health data in the battery passport also supports end-of-life decision-making. Recyclers can use the data to assess the residual value of materials in the battery and select the most appropriate recycling process, improving both the economics and environmental performance of battery recycling.

Preparing for the February 2027 Deadline

With the February 2027 deadline now less than a year away, battery businesses must be in the advanced stages of implementation. The time for scoping and planning has passed, businesses should now be building systems, testing data flows, and conducting pilot DPP creation for their products.

Key milestones for the remaining preparation period include completing supply chain data agreements by mid-2026, finalising the DPP platform selection and integration by late 2026, conducting pilot battery passport creation for representative products, training staff on data collection and DPP management processes, and establishing quality assurance procedures for DPP data accuracy.

The European Commission and relevant standardisation bodies are continuing to develop detailed technical standards and guidance for battery passport implementation. Businesses should monitor these developments closely and ensure their implementation plans align with the latest guidance.

The battery passport is not just a compliance obligation, it is the foundation for a more transparent, sustainable, and circular battery industry. Businesses that implement battery passports effectively will build trust with customers, differentiate their products in the market, and contribute to the EU's ambitious goals for battery sustainability and circularity.

10-Step Action Plan for Battery DPP Readiness

1. Confirm scope. Identify which batteries in your portfolio fall under the mandatory categories (EV, LMT, industrial above 2 kWh). Date stamp each model's compliance trigger.
2. Engage cell suppliers immediately. Cell-level data is the foundation. Multi-tier supplier engagement takes 12 to 24 months to mature, so start the contracts now.
3. Build carbon footprint declarations. Mandatory since 18 February 2025 for EV batteries. Align methodology with the Commission's published rules and select a verifier.
4. Track raw material sourcing. Cobalt, lithium, nickel, lead, and natural graphite all have due diligence requirements. Document supply chain and certification.
5. Plan recycled content reporting. Targets bite from 2031 but data collection must begin now. Map current vs target recycled content per material.
6. Implement state-of-health tracking. Battery passports include dynamic data. Define how state-of-health is measured, transmitted, and updated through the battery's life.
7. Choose a passport hosting model. Internal hosting, third-party platform, or hybrid. Persistence matters because battery passports last beyond the original sale.
8. Assign unique battery identifiers. Each individual battery (not just SKU) needs a unique ID. Plan how this scales across production volume.
9. Run a battery passport pilot. Choose one battery pack family, build the full passport including dynamic data flows, register with the test registry endpoint.
10. Train aftermarket teams. Service networks, dismantlers, and recyclers all need to read and update battery passport data. Training starts before the February 2027 deadline.

Frequently Asked Questions

When does the battery passport become mandatory?

The battery passport becomes mandatory on 18 February 2027 under the EU Battery Regulation 2023/1542, for EV batteries, light means of transport batteries, and industrial batteries over 2 kWh.

Which batteries are in scope?

Electric vehicle batteries, light means of transport batteries (e-bikes, scooters), and industrial batteries with capacity above 2 kWh. Portable batteries below the threshold are outside the mandatory passport scope but follow other Battery Regulation rules.

What data must a battery passport contain?

Required fields include unique battery identifier, manufacturer details, battery chemistry an