Battery Passport: mandatory from 18 February 2027
The Battery Passport is the Digital Product Passport for the product group of batteries. Article 77 of the EU Battery Regulation (EU) 2023/1542 makes it mandatory for three battery categories.
Which batteries are affected
LMT batteries
power for light means of transport such as e-bikes and e-scooters, sealed, 25 kg or less
Art. 3(1)(11)Industrial batteries above 2 kWh
designed for industrial uses, passport required above a capacity of 2 kWh
Art. 3(1)(13)Electric vehicle batteries
traction power for hybrid and electric vehicles of categories M, N and O, and of category L above 25 kg
Art. 3(1)(14)Portable and SLI (starter) batteries do not need a passport, but from 2027 they also carry a QR code (Art. 13(6)).
Responsibility lies with whoever places the battery on the EU market, that is the manufacturer or the importer. They may authorise a third party in writing (Art. 77(4)). If a battery is repurposed or remanufactured, it receives a new passport linked to the original one (Art. 77(7)).
What data the Battery Passport contains
The mandatory information is listed in Annex XIII of the Battery Regulation. DIN DKE SPEC 99100 translates it into concrete data attributes. I initiated and supported its development in the ELSTA research project. We use its structure of seven areas on our DPP platform as well:
- Identifiers and product data
- Symbols, labels and conformity
- Carbon footprint
- Supply chain due diligence
- Materials and composition
- Circularity and resource efficiency
- Performance and durability
Three levels of access
Not every piece of information is visible to everyone. Article 77(2) distinguishes three levels:
Annex XIII points 1 to 4 BattReg
What the passport does for the circular economy
The Battery Passport stays with the battery at every stage. Its data help on every route back into the cycle.
In the technical cycle, four routes lead back; organic materials return through the biological cycle. The smaller the loop, the more value is retained.
Point at or tap a number.
Take-back
Batteries are collected after a period of use and sorted by recovery route.
Product passport: makes strategic take-back schemes easier and allows sorting by manufacturer, category, type, mass and more, so that each item takes the right recovery route.
Service and resale
Extending the life cycle through inspection and maintenance.
Product passport: allows a precise assessment of whether a repair is worthwhile and documents the quality for reuse.
Disassembly, repair and refurbishment
A second life for battery modules, cells and other components by taking the battery apart.
Product passport: provides key information for efficient and safe disassembly and repair.
Recycling of materials
Materials are separated and recycled into secondary raw materials for new components and to meet future mandatory targets.
Product passport: shows the material composition including critical raw materials, sharpens the economic assessment and makes technical recycling processes easier.
Biological cycle
Organic, biodegradable materials are first used several times. At the end they are composted or digested: anaerobic digestion yields biogas as energy, the nutrients return to the soil, and new raw materials grow from them. This only works with materials that can safely return to nature.
Product passport: shows the material composition and hazardous substances, so it is clear which parts can safely enter the biological cycle.
Technical requirements
QR code and identifier
Each battery carries a QR code that leads to the passport via a unique identifier according to ISO/IEC 15459 (Art. 77(3)).
Open, interoperable data
Machine-readable, based on open standards and compatible with the other EU product passports, without vendor lock-in (Art. 77(5), Art. 78(a)).
Available even without the manufacturer
The passport must remain accessible if the responsible operator ceases to exist (Art. 78(e)). That is what our backup service is for.
Authenticity and integrity
The data must be authentic, reliable and protected against fraud (Art. 78(g) and (h)).
Legal framework and standards
The Battery Regulation does not stand alone. The Ecodesign Regulation sits above it, and standards below it specify the implementation.
Tap a document for details.
DIN/DKE joint committee Digital Product Passport, national, mirrors JTC 24
CEN/CLC/JTC 24 Digital Product Passport, European, author of EN 18216 to 18223
ISO/IEC JTC 5 Digital Product Passport, international
DKE/K 371, CLC/TC 21X, IEC/TC 21, accumulators, technical standards
The framework for the Digital Product Passport across many product groups. A delegated act sets out which data each product group needs (Art. 4). The Commission sets up a central EU registry for passport identifiers, including battery passports (Art. 13).
Makes the Battery Passport mandatory from 18 February 2027 for LMT batteries, industrial batteries above 2 kWh and electric vehicle batteries (Art. 77). It sets the basic requirements for technology and access (Art. 78); the content is listed in Annex XIII.
Cites the harmonised standards for the Digital Product Passport, EN 18216 to EN 18223.
Governs producer responsibility at national level in Germany. It requires reporting of category and mass per battery and scales fees by ecological criteria.
Protocols and data formats so that passport data flows between systems securely, in machine-readable form and without vendor lock-in.
Unique identifiers for products, economic operators and facilities: globally unique, persistent, with defined syntax and granularity.
Requirements for data carriers such as QR codes: format, error correction, print quality, durability, placement and recognisability.
Storage, archiving and persistence. The data remain available even if the economic operator is no longer active. This includes replication to a backup service provider.
A uniform application programming interface (API) to create, update and search passports throughout their life cycle.
Semantic description of products and a common information model, so that passports from different systems fit together.
Identification Link: a link that works as a digital nameplate and leads from the product to its information.
Data attributes of the Battery Passport: translates Article 77 and Annex XIII of the Battery Regulation into concrete data fields, structured in seven areas.
Draft on product-related data exchange for the circular economy (CEco).
What I take on, what you provide
What I take on
- checking which batteries are affected
- defining data fields and identifying data gaps
- a questionnaire for your suppliers
- the passport on the platform with all three access levels
- identifier and QR code
- registration in the EU registry (Art. 77(10))
- hosting and backup copy
What you provide
- product data from your systems
- information from your suppliers
- keeping the data up to date in ongoing operation, since you remain responsible for accuracy and currency (Art. 77(4))
- the QR code on battery and label
How this works in two phases is described on the Digital Product Passport page.
Frequently asked questions
Does the obligation apply to batteries already in stock?
Yes, if they are only placed on the market on or after 18 February 2027. What counts is the individual battery and the first time it is made available on the EU market, for example by delivery to a retailer (Art. 3(1)(16) and (17)). If that happened before the deadline, the battery needs no passport. If it is still with the manufacturer or importer on the deadline, it needs one (Art. 77(1)).
Do I have to host the Battery Passport myself?
No. The data are stored by the responsible economic operator or by a service provider authorised by them (Art. 78(c) and (d)).
Sources
- Regulation (EU) 2023/1542 concerning batteries and waste batteries (Battery Regulation, BattReg)
- Regulation (EU) 2024/1781, Ecodesign for Sustainable Products Regulation (ESPR), Art. 13 and 78
- DIN DKE SPEC 99100:2025-02, Requirements for data attributes of the battery passport
This guide does not replace legal advice.
Questions about the Battery Passport?
Write to me via the contact form or take a look at the DPP platform.