Battery Passport: Requirements and 2027 Deadline

This guide covers scope, responsibility, content, access and the points that are still open.

Which batteries are in scope

The Batteries Regulation sorts batteries into categories. Three of them need a passport.

Category	Typical examples	Passport from 18 February 2027
LMT battery (light means of transport)	Batteries for e-bikes, e-scooters, e-mopeds	Yes
Industrial battery above 2 kWh	Stationary energy storage, batteries for industrial machinery	Yes
Electric vehicle battery	Traction batteries for cars, vans, buses, trucks	Yes
Industrial battery up to 2 kWh	Smaller industrial packs	No
Portable battery	Batteries in consumer electronics, household batteries	No
SLI battery	Starter batteries for vehicles	No

The category depends on the legal definitions in Article 3 of the regulation, which use criteria such as weight, design purpose and vehicle type. If a battery sits near a boundary, for example a storage unit just above or below 2 kWh, check the definition before you plan.

The trigger is "placed on the market or put into service". It applies to each individual battery, including batteries built into a vehicle or device, and regardless of whether the battery was made in the EU or imported.

The QR code requirement

The passport is opened through a QR code. Article 77 says the passport shall be accessible through the QR code referred to in Article 13(6), and that the QR code links to a unique identifier which the economic operator placing the battery on the market assigns to it.

• The QR code must comply with the ISO/IEC 15459 series or equivalent, as the regulation states.
• Annex VI requires the QR code to be in high contrast to its background and of a size that common QR readers, such as those in handheld devices, can read easily.
• The QR code duty in Article 13 applies from the same day, 18 February 2027, and is wider than the passport: it concerns batteries in general and gives access to the information that the regulation prescribes for each category.

How identifiers and web links can be structured is covered in our article on DPP data carriers.

Who is responsible

Article 77 places the duty on the economic operator placing the battery on the market. That is usually the battery manufacturer or, for batteries from outside the EU, the importer. For a battery built into a product, it is the operator that places that battery on the market for the first time. The Commission's battery page adds a practical clarification: the obligation to create and maintain the passport falls on the operator placing the finished battery on the market, not on suppliers of individual components or modules.

The responsible operator must ensure that the information in the passport is accurate, complete and up to date. It may authorise another operator in writing to act on its behalf.

Responsibility moves when the battery changes status:

• A battery that is prepared for re-use, repurposed or remanufactured gets a new passport linked to the passport of the original battery. The operator that places it on the market or puts it into service becomes responsible.
• When a battery becomes waste, responsibility passes to the producer, a producer responsibility organisation or the waste management operator, as the regulation specifies.
• The passport ceases to exist once the battery has been recycled.

What the battery passport must contain

Annex XIII lists the information. It is split by who may see it.

Publicly accessible information about the battery model includes, among other items:

• the labelling information from Annex VI, such as manufacturer, battery category, weight, capacity and chemistry
• material composition, including hazardous substances and critical raw materials
• the carbon footprint information required by Article 7
• information on responsible sourcing from the due diligence report
• recycled content information required by Article 8
• the share of renewable content
• rated capacity, voltage, power capability and expected lifetime in cycles
• the period of the commercial warranty for calendar life
• the EU declaration of conformity
• information on prevention and management of waste batteries

Information for persons with a legitimate interest and the Commission includes the detailed composition of cathode, anode and electrolyte, part numbers and contact details for spare parts, dismantling information including diagrams and sequences, and safety measures.

Information for notified bodies, market surveillance authorities and the Commission covers the results of test reports that prove compliance.

Information on the individual battery, for persons with a legitimate interest, includes performance and durability values, state of health, the status of the battery (for example original, repurposed, remanufactured or waste) and data from its use.

Some of these data points depend on other articles of the regulation that phase in at their own dates, such as the carbon footprint declaration. The Commission publishes a working document, "Digital Batteries Passport: data point by category", which was last updated on 19 October 2026 and maps each data point to the battery categories. Use the current version of that document rather than any third-party list. Our DPP data checklist builder gives a first structured overview.

Technical rules for the passport

Article 78 sets the design principles. The battery passport must:

• be fully interoperable with other digital product passports required by EU ecodesign law
• be based on open standards, in an interoperable format, machine-readable, structured and searchable, without vendor lock-in
• give free access to consumers, operators and other actors according to their access rights
• store data with the responsible operator or with operators authorised to act for it, who may not sell or re-use the data beyond the service
• remain available if the responsible operator ceases to exist or to operate in the EU
• ensure data authentication, reliability, integrity, security and privacy

The EU DPP registry also covers batteries. Implementing Regulation (EU) 2026/1778 names batteries under Article 77 in its scope, and the Commission describes the registry as ready ahead of the February 2027 date. The registry holds identifiers and metadata, not the battery data itself.

What is still open

Access rights for "persons with a legitimate interest". The regulation required the Commission to adopt, by 18 August 2026, an implementing act that specifies who has a legitimate interest, which information they may access and how far they may download, share and re-use it. No such act had been published in the Official Journal when this article was written. The Commission's timeline lists it for the fourth quarter of 2026. The passport date does not depend on it.

Remaining harmonised standards. Six harmonised DPP standards were cited in July 2026. The two that deal with access rights management and with data authentication were still pending.

Simplification proposals. Changes to the Batteries Regulation are being discussed as part of EU simplification packages. As of 11 November 2026, we found no adopted change to the passport date or its scope. Check the consolidated text on EUR-Lex before you finalise plans.

How to prepare in practice

1. Classify your batteries. Decide for each model whether it is an LMT, industrial or electric vehicle battery and, for industrial batteries, whether it exceeds 2 kWh.
2. Clarify your role. Are you placing the battery on the EU market, or is your supplier? If you import devices with built-in batteries in scope, the duty may be yours.
3. Map the Annex XIII data. For each data point, note where it comes from: your own engineering data, cell suppliers, test labs or battery management system data.
4. Decide on identifiers. Each battery needs a unique identifier behind its QR code.
5. Plan storage and back-up. Decide whether you host the passport yourself or authorise a service provider, and how the data stays available long term.
6. Follow the open acts. Watch for the access rights act and the remaining standards.

For the wider context, see the DPP timeline by product group and how to prepare for the DPP.

Checklist before 18 February 2027

• Every battery model is assigned to a legal category.
• For in-scope batteries, the responsible economic operator is named in writing.
• Each Annex XIII data point has an owner and a source.
• A unique identifier scheme and QR code layout are tested on the battery.
• The passport is machine-readable and reachable without registration for public data.
• Restricted data is separated from public data.
• A process exists to update the passport when the battery's status changes.
• Someone monitors EUR-Lex and the Commission's battery page for the pending acts.

Sources

• Regulation (EU) 2023/1542 (Batteries), EUR-Lex
• European Commission: Digital Product Passport for batteries
• Regulation (EU) 2025/1561 postponing battery due diligence obligations, EUR-Lex
• Implementing Regulation (EU) 2026/1778 on the DPP registry, EUR-Lex
• European Commission: The DPP registry is now live (20 July 2026)

This article is general information, not legal advice. Status checked on 11 November 2026.