EU Battery Regulation 2027: What Changes for Business

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The 2027 Battery Regulation Milestone

The EU Battery Regulation (Regulation (EU) 2023/1542) represents the most ambitious product-specific sustainability regulation the EU has ever enacted, and 2027 marks the year when its most transformative requirements take effect. From 18 February 2027, every light means of transport battery, every electric vehicle battery, and every industrial battery with a capacity above 2 kWh placed on the EU market must carry a Digital Product Passport — the battery passport.

This is not a distant regulatory prospect. Businesses across the battery value chain — cell manufacturers, pack assemblers, automotive OEMs, energy storage integrators, and importers — must have their DPP systems operational by this date. The requirements are detailed, the data is extensive, and the compliance infrastructure takes significant time to build.

The Battery Regulation serves as a pathfinder for the broader ESPR framework, establishing precedents for DPP implementation that will influence how Digital Product Passports are designed for other product categories. Businesses that successfully implement battery passports will gain transferable expertise and infrastructure that accelerates their compliance with future ESPR delegated acts.

Battery Passport Data Requirements

The battery passport must contain an extensive set of data attributes covering the battery's identity, technical characteristics, environmental impact, and lifecycle information. The Commission's implementing acts specify the exact data model, but the regulation's text provides clear direction on the categories of required information.

Core battery passport data includes:

• Battery identification — manufacturer, manufacturing date and place, battery category, model, weight, and unique identifier.
• Technical performance — rated capacity, voltage, expected lifetime in cycles and years, energy round-trip efficiency, temperature operating range, and internal resistance.
• Chemistry — cathode, anode, and electrolyte active materials, with specific composition detail to enable recycling.
• Carbon footprint — lifecycle CO2 equivalent per kWh of total energy provided over the battery's service life, calculated and verified according to the regulation's methodology.
• Recycled content — percentage of cobalt, lithium, nickel, and lead recovered from battery waste in active materials.
• Supply chain due diligence — compliance with due diligence obligations for raw material sourcing, referencing the OECD Due Diligence Guidance.
• End-of-life information — collection, reuse, and recycling instructions, including safety information for handling spent batteries.

The depth of data required is unprecedented in EU product regulation, establishing a new standard for product transparency that other sectors will eventually be expected to match.

Carbon Footprint Declaration and Performance Classes

The Battery Regulation introduces a phased approach to carbon footprint transparency. The Regulation set 18 February 2025 as the target date for EV battery carbon footprint declarations and 18 February 2026 for rechargeable industrial batteries, but each obligation only starts 12 months after the Commission adopts the delegated act on the calculation methodology, which was still outstanding in September 2026. Carbon footprint performance classes follow 18 months after their own delegated act, and maximum lifecycle carbon footprint thresholds, set by a further delegated act, apply to EV batteries from 18 February 2028 or 18 months after that act enters into force, whichever is later.

The carbon footprint must be calculated on a lifecycle basis, covering raw material acquisition, pre-processing, manufacturing, distribution, and end-of-life treatment. The calculation methodology, specified in Commission Delegated Regulation (EU) 2024/1773, requires facility-specific data for the manufacturing stage and allows the use of default values for upstream stages where primary data is not available.

Carbon footprint performance classes (A through E) will allow consumers, procurers, and regulators to compare batteries quickly. A battery in class A has a significantly lower carbon footprint than one in class E, and this classification must be prominently displayed alongside the battery passport data.

For battery manufacturers, the carbon footprint requirement creates a competitive dynamic that rewards clean manufacturing. Producers using renewable energy, efficient processes, and low-carbon materials will achieve better performance classes, while those relying on coal-intensive electricity grids and inefficient processes will be progressively disadvantaged — and potentially excluded from the market if they exceed the maximum threshold.

Recycled Content Targets

The Battery Regulation introduces mandatory recycled content targets that ramp up over time. By 2031, batteries must contain minimum percentages of recycled cobalt (16%), lithium (6%), nickel (6%), and lead (85%) recovered from battery manufacturing waste or post-consumer battery waste. These targets increase further by 2036.

The DPP must declare the actual recycled content percentages for each regulated material, verified by a conformity assessment body. This verification requires a documented chain of custody from the recycling facility through material processing to battery cell manufacturing, ensuring that recycled content claims are substantiated and auditable.

For the battery industry, meeting these targets requires investment in battery recycling capacity and the establishment of commercial relationships between recyclers and battery manufacturers. The regulation's recycled content targets are designed to create demand that makes battery recycling economically viable, closing the loop on critical raw materials and reducing dependence on mining.

The battery passport requirements guide provides detailed coverage of how recycled content data should be structured within the DPP, including guidance on chain-of-custody documentation and verification standards.

Due Diligence and Responsible Sourcing

The Battery Regulation mandates that economic operators placing batteries on the EU market implement due diligence policies for the sourcing of raw materials — specifically cobalt, natural graphite, lithium, nickel, and the chemical compounds derived from them. These obligations align with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

The battery passport must document the company's due diligence policy, the findings of its supply chain risk assessment, and the measures implemented to mitigate identified risks. This is not a one-time declaration but an ongoing obligation — due diligence must be updated as supply chain conditions change, and the DPP must reflect the most current assessment.

For companies sourcing from regions associated with human rights risks (artisanal cobalt mining in the Democratic Republic of Congo, lithium extraction in areas with indigenous land rights concerns), the DPP creates a transparent record of how these risks are identified and managed. Third-party audit reports, certification scheme memberships (Responsible Minerals Initiative, Initiative for Responsible Mining Assurance), and corrective action plans should all be referenced in or accessible through the battery passport.

This due diligence requirement represents a significant shift for the battery industry, where many companies have historically had limited visibility beyond their Tier 1 suppliers. The regulation forces deeper supply chain mapping and engagement, and the DPP makes the results of this engagement publicly accessible.

State of Health and Second-Life Applications

One of the most innovative aspects of the battery passport is its requirement to track the battery's state of health (SoH) throughout its operational lifetime. The SoH data — including remaining capacity, round-trip efficiency, and cycle count — must be updated and accessible through the DPP, enabling informed decisions about battery reuse and second-life applications.

When an EV battery reaches the end of its automotive service life (typically at 70-80% remaining capacity), the SoH data in the battery passport enables second-life assessors to determine its suitability for less demanding applications such as stationary energy storage. Without this data, second-life evaluation requires expensive and time-consuming physical testing; with it, the assessment can be made remotely and rapidly.

The battery management system (BMS) is the primary source of SoH data, and the regulation requires that this data be made accessible to the DPP platform through a standardised interface. For battery manufacturers and automotive OEMs, this means implementing data pipelines from the BMS to the DPP system — a technical integration that must be planned and tested well before the 2027 deadline.

The economic implications are significant. A healthy second-life market for batteries reduces waste, extends the useful lifetime of critical raw materials, and creates revenue opportunities for battery owners and remanufacturers. The DPP is the enabler that makes this market function efficiently.

Collection, Recycling, and End-of-Life Obligations

The Battery Regulation establishes ambitious collection and recycling targets that build on the earlier Batteries Directive. By 2027, 63% of portable batteries must be collected (rising to 73% by 2030), and 100% of EV and industrial batteries must be collected. Recycling efficiency targets require that 65% of lithium-based battery weight be recycled by the end of 2025, rising to 70% by the end of 2030, and recyclers must additionally recover 80% of the lithium itself by the end of 2031.

The battery passport supports these targets by providing waste management operators with the information needed for safe and efficient processing. The DPP must include safety information for handling spent batteries, chemistry identification to enable appropriate recycling processes, and hazardous substance declarations. A recycler scanning a battery's QR code should have immediate access to all the information needed to safely receive, store, and process the battery.

For producers, the Extended Producer Responsibility (EPR) requirements under the Battery Regulation create financial obligations for collection and recycling. The DPP can facilitate EPR fee calculation by providing the battery's chemistry, weight, and composition data to EPR scheme operators, enabling accurate fee assessment without physical inspection.

Preparing Your Business for 2027

With the February 2027 battery passport deadline approaching, businesses across the battery value chain must accelerate their preparation. The complexity of the data requirements and the need for supply chain coordination mean that last-minute compliance is not feasible.

Priority actions for the coming months:

• For battery manufacturers — implement carbon footprint calculation systems, establish recycled content chain-of-custody tracking, develop BMS-to-DPP data interfaces for state of health reporting, and register in the EU Digital Product Passport Registry, which opened on 20 July 2026 with a testing environment.
• For automotive OEMs — coordinate with battery suppliers on DPP data provision requirements, integrate battery passport data into vehicle documentation systems, and plan for SoH data transmission from connected vehicles to the DPP platform.
• For energy storage integrators — establish DPP workflows for system-level data (not just cell-level), coordinate with cell suppliers on data exchange formats, and prepare for second-life assessment data requirements.
• For importers — verify that non-EU battery suppliers can provide the data needed for DPP population, including carbon footprint, recycled content, and due diligence documentation.

Platforms like MyProductPassport provide battery passport templates aligned with the regulation's data model, enabling businesses to begin generating compliant passports and identifying data gaps well before the compliance deadline. The ESPR compliance checklist provides a structured approach to preparation across all product categories.