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.

Guide · As of October 2026 · by Nico Kimpel

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:

  1. Identifiers and product data
  2. Symbols, labels and conformity
  3. Carbon footprint
  4. Supply chain due diligence
  5. Materials and composition
  6. Circularity and resource efficiency
  7. Performance and durability

Three levels of access

Not every piece of information is visible to everyone. Article 77(2) distinguishes three levels:

General public label information, material composition, carbon footprint, recycled content, performance and lifetime, declaration of conformity
Legitimate interest for repair, second life and recycling: detailed composition, dismantling, spare parts, state of health and usage data of the individual battery
Authorities notified bodies, market surveillance and the Commission: test reports proving compliance

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.

Circular model: routes back into the cycle Energy Biological cycle · organic materials Technical cycle · non-biodegradable materials Raw materials, recyclates Components and cellsSuppliers Battery packsManufacturer Sale and useCustomer Return and collectionRetail, collection points, recyclers 5 1 2 3 4

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.

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.

Harmonised standards
Also referenced
Standardisation committees

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

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.