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 defines six battery categories. The Digital Battery Passport applies to three of them:
- Electric Vehicle (EV) batteries: Batteries above 25 kg designed for electric road vehicles
- 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 under 5 kg), Starting/Lighting/Ignition (SLI) batteries for conventional vehicles, and Stationary Energy Storage Systems (ESS) are subject to other requirements under the regulation but are not covered by the full Digital Battery Passport obligation.
The Carbon Footprint Timeline
Before the full passport becomes mandatory, battery producers must meet an intermediate obligation: the carbon footprint declaration. This is a phased requirement:
| Date | Obligation | Battery Category | |------|-----------|-----------------| | 18 February 2025 | Carbon footprint declaration mandatory | EV batteries | | 18 February 2026 | Carbon footprint declaration mandatory | Industrial rechargeable batteries (>2 kWh) | | 18 August 2028 | Carbon footprint declaration mandatory | LMT batteries |
For EV batteries, this obligation is already in force. Manufacturers and importers who placed EV batteries on the EU market from 18 February 2025 without a carbon footprint declaration are non-compliant.
The methodology follows the Product Carbon Footprint (PCF) approach under ISO 14067 and the EU's Product Environmental Footprint (PEF) methodology. Batteries will eventually be classified into performance bands (A through D) based on rolling three-year market data, with binding performance classes applying from 2033.
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. Article 78 covers the QR code and data carrier specifications. Article 79 governs data accessibility and operator obligations. Annex XIII specifies the minimum data fields — more than 90 data points in total.
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, 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
The recycled content data point is particularly significant. From 18 August 2028, minimum recycled content thresholds become mandatory: at least 12% recycled cobalt, 4% recycled lithium, and 4% recycled nickel in EV and industrial batteries. The battery passport is the mechanism by which this compliance is declared and verified.
Due Diligence Obligations
From 18 August 2027, companies with annual turnover above €40 million placing EV, LMT, or industrial batteries on the EU market must also comply with supply chain due diligence requirements under Article 52 of the Battery Regulation.
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.
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 batteries: the carbon footprint declaration obligation is already in force (18 February 2025). Verify that your current product documentation meets this requirement.
If you manufacture or import industrial batteries above 2 kWh: the carbon footprint declaration became mandatory on 18 February 2026. Confirm your declarations are in place.
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 integration with EU registry systems once operational.
Sources
- Regulation (EU) 2023/1542, Articles 52, 77, 78, 79, and Annex XIII — EUR-Lex: https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng
- European Commission — Batteries and waste batteries implementation page: https://environment.ec.europa.eu/topics/waste-and-recycling/batteries_en
- 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