Battery Digital Product Passport Requirements

Which batteries need a Battery Passport?

Regulation (EU) 2023/1542 applies broadly to all categories of batteries, but the Battery Passport obligation in Article 77 is narrower.

From 18 February 2027, a passport is required for:

• LMT batteries, including batteries used in light means of transport such as many e-bikes and e-scooters
• industrial batteries with a capacity greater than 2 kWh
• electric-vehicle batteries.¹

The passport rule does not simply mean that every portable, SLI or smaller industrial battery needs the same passport.

The legal trigger is also important. Article 77 applies to covered batteries placed on the market or put into service from 18 February 2027.¹

Scope in practical terms

A battery business should therefore classify the finished battery before building passport logic. The first questions are:

1. What legal battery category does the finished battery fall into?
2. If it is an industrial battery, is capacity greater than 2 kWh?
3. Is the battery being placed on the EU market or put into service from the application date?
4. Which information requirements apply to that battery category and to the underlying substantive obligation?

Do not use the presence of a QR code, a serial number or a product's commercial label as a substitute for the legal category test.

When does the Battery Passport apply?

The key dates are different legal events, not one generic "DPP deadline".

The 18 February 2027 date is law. The Commission's current Q4 2026 timing for the still-pending battery access-rights implementing act is an indicative implementation timetable, not a new statutory deadline.⁴

What information does the Battery Passport contain?

Article 77 and Annex XIII create a hybrid information model. Some information is about the model. Some is specific to an individual battery and can change during the battery's life.

The table below groups the legal requirements into useful information territories. It is not a substitute for the Regulation and should not be read as saying every listed data point is populated in exactly the same way for every covered battery on day one.

A field can be in the schema without being populated in every case on 18 February 2027

This is an important implementation distinction.

Annex XIII references information that depends on other substantive provisions of the Batteries Regulation. Carbon-footprint, recycled-content and other sustainability obligations have their own scopes, staged application dates and secondary-law dependencies.

So there are two separate questions:

1. Is this information territory part of the Battery Passport legal architecture?
2. Is this exact value legally required to be populated for this battery category at this point in time?

The Commission's August 2026 guidance is useful because it organises this complexity by battery category and marks data points as mandatory, optional, conditional or not needing to be filled or displayed as of February 2027.³

That document is Commission guidance. It is not legislation and it expressly says it does not introduce additional legal requirements or provide an authoritative interpretation of the law.³

Identifiers and the QR code

The Battery Passport is a category where the law is specific about the carrier.

Article 77 requires the passport to be accessible through the QR code referred to in Article 13(6). The QR code links to a unique identifier attributed to the battery by the economic operator placing it on the market. Article 77 also requires the QR code and unique identifier to comply with the ISO/IEC 15459 series named in the Regulation, or equivalent standards where the law provides for that possibility.¹

From 18 February 2027, Article 13(6) also requires all batteries to carry a QR code, although what that QR code provides access to depends on the battery category. For the Battery Passport categories, it provides access to the passport.¹

Three distinctions matter:

• The unique identifier is not automatically the same thing as a GTIN.
• The QR code is the data carrier, not the passport itself.
• Battery law specifying a QR code does not mean every other DPP regime must use a QR code.

For the cross-category identifier question, use Barcodes and Product Identifiers: What You Need.

Is the Battery Passport model-level or item-level?

Neither description is complete on its own.

Article 77 says the passport contains:

• information relating to the battery model
• information specific to the individual battery
• including information resulting from the use of that battery.¹

That makes the Battery Passport a hybrid model + individual/lifecycle architecture.

This distinction is more important than calling the passport simply "item-level". A battery producer needs a data model that can separate stable model truth from changing individual-battery data.

There is also lifecycle continuity. If a battery is prepared for re-use, repurposed or remanufactured, the Regulation requires a new passport linked to the original passport or passports. The battery passport ceases to exist after the battery has been recycled.¹

For the wider comparison, see Model, Batch or Item Level for a Textile Passport, which is the existing estate destination to expand into the cross-category granularity reference.

Who can see what?

Battery law is the strongest current example of why "DPP data is public" is too broad.

Article 77 and Annex XIII provide three broad access classes.

General public

Annex XIII Part 1 covers the model information made accessible to the general public. This includes a wide range of identity, technical, sustainability, performance and end-of-life information where applicable.¹

Notified bodies, market surveillance authorities and the Commission

Annex XIII Part 3 reserves test-report results proving compliance to notified bodies, market surveillance authorities and the Commission.¹

Persons with a legitimate interest

Annex XIII Parts 2 and 4 cover commercially and operationally sensitive information for legitimate-interest actors. Examples include:

• detailed cathode, anode and electrolyte composition
• component part numbers and replacement-spare sources
• detailed dismantling information
• safety measures
• individual performance and durability values
• state of health
• battery status
• charging/discharging cycles
• negative events
• operating conditions and state-of-charge information.¹

Article 77 links legitimate-interest access to purposes such as repair, remanufacturing, second-life operations and recycling, or certain purchaser/energy-market purposes.

The unresolved access-rights point

Article 77(9) required the Commission to adopt an implementing act by 18 August 2026 specifying which persons qualify as persons with a legitimate interest, what information they can access and the extent to which they may download, share, publish and re-use it.¹

As at 1 September 2026, no such adopted implementing act was identified in the current primary-source verification. The Commission's DPP implementation page still places the Battery access-rights implementing act in Q4 2026 and labels the timeline indicative.⁴

That means the law already establishes the access architecture and Annex XIII data classes, but a material part of the detailed legitimate-interest access implementation remains pending.

See Who Can See What in a Digital Product Passport for the cross-category access question.

Registry, storage and persistence

The Battery Passport should not be described as a record fully stored inside one central EU database.

Article 78 requires passport data to be stored by the responsible economic operator, or by an operator authorised to act on its behalf. It also sets requirements for interoperability, free access according to rights, persistence, controlled modification, data reliability, security and privacy.¹

Article 77(10) requires the economic operator placing the battery on the market or putting it into service to upload the unique identifier to the DPP Registry established under ESPR.¹

The EU DPP Registry became operational on 20 July 2026.⁵ Its role is a regulatory registration and discovery/enforcement layer. It is not the full central store of every battery passport data point.

See EU DPP Registry: Where Passport Data Actually Lives.

Required under other parts of battery law, not automatically a universal DPP field

The Battery Passport pulls together information connected to several substantive requirements elsewhere in the Batteries Regulation.

That does not turn those requirements into universal DPP fields for other products.

Examples include:

• battery-specific carbon-footprint obligations
• battery-specific recycled-content obligations
• battery due-diligence/responsible-sourcing information
• battery performance and durability requirements
• battery markings and end-of-life information.

The correct reading is: the Batteries Regulation deliberately connects these battery-law obligations to its own passport architecture.

What battery businesses can prepare now

PREPARE

Confirm legal battery category and capacity. Build the scope decision before the passport workflow.

Separate model data from individual-battery data. The legal architecture requires both.

Create stable battery identity. Plan for the unique identifier and its relationship to the mandatory QR carrier.

Structure the adopted Annex XIII territories. Map existing sources for manufacturer, manufacturing plant, chemistry, technical characteristics, performance, composition, sustainability and end-of-life information.

Prepare lifecycle data governance. Define who can update state-of-health, status, use-event and other changing data.

Prepare evidence provenance. Link claims and values to source documents, test evidence and the legal obligation they support.

Plan for restricted access. Do not publish the legitimate-interest or authority-only data as if Annex XIII made it public.

WATCH

• adoption of the Article 77(9) Battery access-rights implementing act
• any further revisions to the Commission's Battery Passport data-point guidance
• changes to the category-by-category February 2027 applicability of individual data points
• delegated or implementing acts underpinning carbon, recycled-content and other referenced obligations
• DPP standards and service-provider implementation changes.

IMPLEMENTATION DETAIL STILL PENDING

The most material open point at 1 September 2026 is the detailed implementing act for legitimate-interest access rights.

That is an implementation dependency, not a reason to treat the whole Battery Passport as uncertain. Scope, the 18 February 2027 application date, the hybrid model/individual architecture and the Annex XIII information classes are already in adopted law.

What the Battery Passport shows about DPPs

The Battery Passport demonstrates a hybrid model + individual lifecycle passport.

That is important because detergents and toys, although also adopted DPP regimes, use a model-level default and very different information structures.

The broader lesson is not "copy the Battery Passport". It is:

Build a flexible product-data system around the verified requirements of the relevant category.

See Digital Product Passport Requirements by Product Category for the wider architecture.

Open questions and implementation pending

As at 1 September 2026:

1. The Article 77(9) legitimate-interest access implementing act is overdue against its statutory 18 August 2026 deadline and remains pending in the Commission's implementation timetable.
2. The Commission's 71-data-point guidance may continue to evolve and should not be treated as law.
3. Some information referenced by Annex XIII depends on category-specific or staged substantive obligations and secondary measures.
4. Wider DPP standards, Registry and service-provider implementation will continue to affect technical delivery without changing the basic Battery Passport scope.

Direct questions

Which batteries need a Battery Passport?

From 18 February 2027, each LMT battery, each industrial battery above 2 kWh and each EV battery placed on the market or put into service must have a Battery Passport.¹

Is the Battery Passport item-level?

It includes individual-battery information, but it is better described as a hybrid model + individual/lifecycle architecture because Article 77 requires both model information and information specific to the individual battery.¹

Is Battery Passport information public?

Not all of it. Annex XIII separates public data from authority/notified-body data and legitimate-interest data.¹

Does a Battery Passport require a QR code?

Yes for this regime. Article 77 links the passport to the battery through the QR code required by Article 13(6).¹ That does not make QR a universal rule for every DPP category.

Does a Battery Passport require carbon-footprint information?

Carbon-footprint information is part of the Battery Passport architecture where the underlying Article 7 obligation applies. The exact population requirement depends on the battery category and the relevant staged legal obligation.¹³

What are the 71 Battery Passport data points?

The Commission's 21 August 2026 guidance organises 71 data points across covered battery categories. It is implementation guidance, not a new legal field list created independently of the Batteries Regulation.³

How we know

Material claims on this page were checked against current EU primary and official sources on 1 September 2026. The legal rule comes first. Commission implementation guidance is used only as guidance and is labelled as such.

Primary and official sources

• Regulation (EU) 2023/1542 on batteries and waste batteries, especially Articles 13, 77 and 78, Annex VI and Annex XIII. Consolidated text current to 31 July 2025 with later corrigenda listed by EUR-Lex: Original ELI

  View official source

  https://eur-lex.europa.eu/eli/reg/2023/1542/oj

• Regulation (EU) 2024/1781 (ESPR), horizontal DPP system and Registry architecture

  View official source

• European Commission, Guidance to support preparations for the Digital Batteries Passport, 21 August 2026. The Commission states that the 71-data-point guidance does not introduce additional legal requirements and is not an authoritative interpretation

  View official source

• European Commission, Digital Product Passport implementation timeline, including indicative Q4 2026 Battery access-rights implementing act

  View official source

• European Commission, DPP Registry now live, 20 July 2026

  View official source

• European Commission, Digital Product Passport for Batteries, current implementation overview

  View official source

https://single-market-economy.ec.europa.eu/single-market/digital-product-passport/batteries_en