The EU Battery Passport: What You Need to Know
A complete guide to the Digital Battery Passport — mandatory from February 2027 under Regulation (EU) 2023/1542 — covering which batteries are affected, what data is required, and the full compliance timeline.
What is the EU Battery Passport?
The Digital Battery Passport (DBP) is a mandatory digital record that accompanies certain batteries placed on the EU market. It is established by Regulation (EU) 2023/1542 — the EU Battery Regulation — which entered into force in August 2023 and became applicable from 18 February 2024.
The Battery Passport is the first mandatory Digital Product Passport to take effect under EU law. It predates the broader ESPR DPP framework and operates under its own legal architecture, though both share the same underlying principle: product-level data must be accessible to consumers, regulators, recyclers, and supply chain actors throughout the product's lifetime.
Which Batteries Are Affected?
The Battery Regulation covers five battery categories: portable, SLI, LMT, electric vehicle and industrial batteries. The Digital Battery Passport applies to three of them:
- Electric Vehicle (EV) batteries: Traction batteries for cars, vans, trucks, buses and trailers (vehicle categories M, N and O) at any weight, and for L-category vehicles such as motorcycles above 25 kg
- Light Means of Transport (LMT) batteries: Batteries up to 25 kg for e-bikes, e-scooters, and e-mopeds
- Industrial batteries with a capacity greater than 2 kWh
Portable batteries (sealed batteries of 5 kg or less) and Starting/Lighting/Ignition (SLI) batteries for conventional vehicles are subject to other requirements under the regulation but are not covered by the full Digital Battery Passport obligation. Stationary battery energy storage systems are industrial batteries under Article 3, so those above 2 kWh need a passport.
The Carbon Footprint Timeline
The Battery Regulation also requires a carbon footprint declaration (Article 7), phased by battery category. It is not yet applicable. Each phase depends on two Commission acts: a delegated act setting the calculation and verification methodology, and an implementing act setting the format of the declaration. The obligation applies from the date below, or 12 months (EV batteries) or 18 months (other categories) after both acts have entered into force, whichever is later:
| Earliest date | Obligation | Battery Category |
|---|---|---|
| 18 February 2025 | Carbon footprint declaration | EV batteries |
| 18 February 2026 | Carbon footprint declaration | Rechargeable industrial batteries (>2 kWh), except those with exclusively external storage |
| 18 August 2028 | Carbon footprint declaration | LMT batteries |
| 18 August 2030 | Carbon footprint declaration | Rechargeable industrial batteries (>2 kWh) with external storage |
As of 11 October 2026 neither act has been adopted for any category, so the declaration is not required yet, even where the calendar date has passed. The Commission's batteries passport FAQ confirms that carbon footprint information "will not yet be required" in passports from February 2027. Watch for both acts: the clock starts when the later of the two enters into force.
Under Annex II of the Regulation, the methodology must comply with the Commission's Product Environmental Footprint (PEF) method. Batteries will later be sorted into carbon footprint performance classes, with class A the best; the number of classes is left to a delegated act. Maximum carbon footprint thresholds follow from 18 February 2028 at the earliest for EV batteries, with later dates for the other categories, each applying 18 months after its own delegated act if that is later.
Full Digital Battery Passport: February 2027
The complete Digital Battery Passport becomes mandatory on 18 February 2027 for LMT batteries, EV batteries, and industrial batteries with capacity above 2 kWh.
From that date, every battery in scope must:
- Carry a durable, indelible QR code permanently attached to the battery
- The QR code must be readable at no cost to the end user
- Scanning the QR code must resolve to the battery passport data in real time
- Data must remain accessible for the entire operational life of the battery
Article 77 of the Battery Regulation establishes the general DPP requirements. The QR code that gives access to the passport comes from Article 13(6), and Article 77(3) links it to a unique identifier. Article 78 sets the essential requirements for the passport's technical design and operation, such as interoperability, free access according to each user's access rights, data storage, integrity and security. Annex XIII specifies the information the passport must hold. The Commission's Digital Batteries Passport guidance of 21 August 2026 maps it to 71 data points across EV, LMT and industrial batteries, each flagged as mandatory, optional or conditional.
Battery passports are linked to the EU DPP registry. Implementing Regulation (EU) 2026/1778 on the registry entered into force on 6 August 2026. It requires each Member State to appoint a national registry administrator by 18 February 2027, the date of the first registrations for certain large batteries.
Two parts of the framework are still open. Part of the passport is public, but it is still undecided who counts as a person with a legitimate interest, such as a repairer or recycler, for the restricted parts. The implementing act on access rights under Article 77(9) was due by 18 August 2026 and has not been adopted. The Commission expects a draft for feedback in October or November 2026 and, according to its 30 September 2026 webinar, aims for a committee vote in December 2026 or early January 2027 (indicative). On standards, Implementing Decision (EU) 2026/2048 cited the first harmonised standard under the Battery Regulation on 16 September 2026, EN 18060:2025 on EV battery performance and durability. No harmonised standard yet covers the passport's technical design under Article 78.
Proposed, not law: a draft Commission delegated act, open for feedback until 27 October 2026, would require the passport QR code to comply with EN 18220:2026 and the unique identifier with EN 18219:2026, "or their equivalent", in place of the ISO/IEC 15459 series cited today. The Commission says the current standards can still be used as equivalents and expects adoption in 2027. The draft also sets the first minimum performance and durability values for rechargeable industrial batteries above 2 kWh.
What Data Must the Battery Passport Contain?
Annex XIII of the Battery Regulation defines the minimum required content:
- Unique identifier code linked to the QR code
- Chemical composition by weight — active materials, electrolytes, exact percentages
- Carbon footprint declaration (per manufacturing plant, per battery model)
- Recycled content percentages for cobalt, lead, lithium, and nickel
- State of health and remaining capacity
- Expected and actual lifespan
- Recycling, reuse, and repurposing instructions
- Supply chain traceability — sourcing of critical raw materials including cobalt, lithium, nickel, and natural graphite
- Due diligence documentation references confirming responsible sourcing
- Safety information
Not all of this is required from day one. According to the Commission's batteries passport FAQ, carbon footprint, recycled content and due diligence information "will not yet be required" when passports begin in February 2027. Each has its own application date.
The recycled content data point is particularly significant. Article 8 of the Regulation sets the rules, and the battery passport is where that information is made available. Documentation of the recycled share of cobalt, lead, lithium and nickel is required from 18 August 2028, or 24 months after the Commission's methodology delegated act enters into force if that is later. That act was due by 18 August 2026 and has not been adopted. Minimum recycled shares then apply from 18 August 2031: 16% cobalt, 85% lead, 6% lithium and 6% nickel. From 18 August 2036 they rise to 26% cobalt, 85% lead, 12% lithium and 15% nickel. These rules cover EV batteries, SLI batteries and industrial batteries above 2 kWh, except those with exclusively external storage. LMT batteries need the documentation from 18 August 2033 and must meet the 2036 minimum shares.
Due Diligence Obligations
From 18 August 2027, economic operators placing batteries on the EU market must also comply with supply chain due diligence requirements. The date was postponed from 18 August 2025 by Regulation (EU) 2025/1561, which amended Article 48(1). Operators with a net turnover below €40 million, and not part of a group above that limit, are exempt under Article 47. That is the current law.
Proposed, not law: a provisional agreement of 26 June 2026 on the small mid-cap omnibus would raise the threshold to €200 million. Parliament's plenary vote is indicatively set for 23 November 2026, and the threshold stays at €40 million until the change is adopted and published in the Official Journal.
These obligations cover the sourcing of cobalt, natural graphite, lithium, and nickel — materials classified as critical raw materials under the EU's Critical Raw Materials Act (Regulation (EU) 2024/1252). Due diligence documentation must be referenced in the battery passport.
Recycling Targets Unchanged
On 11 September 2026 the Commission reported, in COM(2026) 470, that it is "not considered appropriate to revise" the recycling-efficiency and material-recovery targets in Annex XII, Parts B and C. The next assessment is due by 18 August 2031.
Battery Pass Consortium Guidance
The Battery Pass consortium — a cross-industry initiative that concluded in March 2025 — produced the most detailed implementation guidance available for the Digital Battery Passport. Their 2023 Content Guidance and 2024 Technical Guidance describe how to structure data fields, select data carriers, and implement the QR code architecture consistent with the regulation.
This guidance, while not legally binding, reflects the consensus of automotive, battery, and technology industry actors on how to meet the regulation's requirements in practice.
Practical Steps for Compliance Officers
If you manufacture or import EV or industrial batteries above 2 kWh: prepare carbon footprint data now, but track the two Commission acts it depends on, one on the calculation method and one on the declaration format. Neither has been adopted. The declaration becomes due 12 months (EV batteries) or 18 months (industrial batteries) after the later of the two enters into force, or on the calendar date in the Regulation, whichever is later.
For all in-scope battery producers: the full Digital Battery Passport must be live by 18 February 2027. This requires not just the data, but the technical infrastructure — a QR code physically attached to the battery, a data system that resolves to battery passport data, and registration in the EU DPP registry, which has been live since 20 July 2026.
Sources
- Regulation (EU) 2023/1542, Articles 3, 7, 8, 13, 47, 48, 77, 78, and Annexes II and XIII — EUR-Lex: https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng
- Regulation (EU) 2025/1561 (due diligence postponed to 18 August 2027) — EUR-Lex: https://eur-lex.europa.eu/eli/reg/2025/1561/oj/eng
- Implementing Regulation (EU) 2026/1778 (DPP registry) — EUR-Lex: https://eur-lex.europa.eu/eli/reg_impl/2026/1778/oj/eng
- COM(2026) 470, report on Annex XII recycling targets — EUR-Lex: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52026DC0470
- European Commission — Guidance to support preparations for the Digital Batteries Passport, 21 August 2026: https://single-market-economy.ec.europa.eu/news/guidance-support-preparations-digital-batteries-passport-2026-08-21_en
- European Commission — Digital Product Passport Registry now live, 20 July 2026: https://single-market-economy.ec.europa.eu/news/digital-product-passport-registry-now-live-2026-07-20_en
- European Commission — Batteries and waste batteries implementation page: https://environment.ec.europa.eu/topics/waste-and-recycling/batteries_en
- Implementing Decision (EU) 2026/2048 (harmonised standard EN 18060:2025), EUR-Lex: https://eur-lex.europa.eu/eli/dec_impl/2026/2048/oj/eng
- European Commission, EU Digital Product Passport FAQ for Batteries: https://single-market-economy.ec.europa.eu/single-market/digital-product-passport/eu-digital-product-passport-faq-batteries_en
- European Commission, third webinar on the batteries DPP, 30 September 2026: https://single-market-economy.ec.europa.eu/events/eu-digital-product-passport-batteries-third-webinar-2026-09-30_en
- Have Your Say 14460, draft delegated act on minimum performance and durability values for rechargeable industrial batteries (proposed): https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14460
- Have Your Say 16473, implementing regulation on access rights to certain parts of the battery passport: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/16473
- Provisional agreement on the small mid-cap omnibus, procedure 2025/0130(COD), European Parliament: https://www.europarl.europa.eu/RegData/commissions/econ/inag/2026/06-26/CJ58_AG(2026)790249_EN.pdf
- Battery Pass consortium — Content Guidance (2023) and Technical Guidance (2024): https://thebatterypass.eu/
- Regulation (EU) 2024/1252 (Critical Raw Materials Act) — EUR-Lex: https://eur-lex.europa.eu/eli/reg/2024/1252/oj