Battery Passport: obligation, requirements and strategic opportunity from 2027

The Battery Passport in numbers

What is the Battery Passport?

The Battery Passport is the digital product passport for batteries. Each individual product receives a unique, machine-readable data record that can be retrieved via a data carrier on the physical product. In practice this is usually done with a QR code directly on the housing. A scan leads to the data that must be documented and made available under the EU Battery Regulation.

In terms of content, the Battery Passport goes far beyond classic CE marking or technical data sheets. It maps the entire lifecycle of a battery: origin of raw materials, carbon footprint in production, share of recycled materials, performance metrics, maintenance information as well as details on reuse and recycling. The EU's aim is to make the circular economy for batteries verifiable and to give market participants along the value chain a reliable data basis.

The Battery Passport is neither a standalone IT system nor a file. It is a data space that is fed from the manufacturer's systems and is interoperably accessible via a standardised interface. The European Commission is currently building the central DPP registration infrastructure for this purpose. National authorities access defined subsets of the data, while consumers and economic operators each access their own layers.

Important for the regulatory classification: the Battery Passport belongs legally to the "batteries" sector. The topic of digital product passports as a whole is governed by the Ecodesign for Sustainable Products Regulation (ESPR). The Battery Passport is, however, the first sector-specific implementation on which later DPPs (textiles, furniture, electronics) build technically and logically. Anyone building a Battery Passport today is at the same time building the foundation for the next regulatory step.

Key point The Battery Passport is product identity, compliance proof and data space in one. It accompanies the battery throughout its entire lifecycle.

Battery Passport obligation: the key deadlines at a glance

The EU Battery Regulation has been in force since 17 August 2023, and most obligations have applied since 18 February 2024. The Battery Passport itself follows in stages, together with further requirements around carbon transparency and recycled content.

The carbon footprint obligations are deliberately left undated in this timeline: there is no fixed application date yet for the carbon footprint declaration (EV and industrial batteries) or the carbon performance classes. It depends on the still-pending delegated act on the calculation methodology, with the EU staging EV batteries ahead of industrial batteries.

Note (as of June 2026): The European Commission has put forward a simplification proposal that affects, among other things, the timing for providing information in the simplified battery passport (“DPP light”), partly because the secondary legislation on battery labelling is still pending. This is currently only a proposal; the final deadlines remain to be confirmed.

18 February 2027 is the central date. From that day no battery of the named types may be placed on the EU market without a Battery Passport. Companies that introduce their products only from 2027 are just as affected as existing suppliers.

At first glance the time seems sufficient. In practice it is tight: capturing data from the supply chain, calculating the carbon footprint to PEFCR methodology and integrating into ERP, PLM and MES systems take considerably longer than pure software implementations.

Key point 18 February 2027 is fixed in law. Anyone starting implementation today gets through safely and with room to shape the outcome.

Which batteries need a digital passport?

The EU Battery Regulation distinguishes five battery categories. Not all are subject to the passport obligation. The following overview shows which battery types need a Battery Passport and which only have to comply with parts of the regulation.

For portable batteries and SLI batteries the other obligations of the regulation still apply, for example on labelling, separate collection and take-back. The formal Battery Passport is, however, not required. Manufacturers of such products should nonetheless watch how the regulation develops. The EU plans to scale the DPP across sectors over time.

The industrial batteries category deserves particular attention. The threshold of 2 kWh is low. Many storage systems in commercial settings, drives in robots or intralogistics, stationary building storage and numerous niche products lie above this limit. Anyone who does not deliberately check today whether their products are affected often overlooks the obligation only once the deadline is already noticeably close.

Key point Subject to the obligation are EV, industrial (above 2 kWh) and LMT batteries. Portable and SLI batteries are exempt today, but not guaranteed to be in the future.

Are you affected?

The Battery Passport obliges all economic operators that "place on the market" batteries subject to the obligation in the EU (Article 77, Regulation 2023/1542). In practice these are considerably more companies than pure battery manufacturers. Machine builders, OEMs and importers of battery-powered products are also covered.

In practice that means: a German machine builder who fits batteries into its forklifts carries just as much responsibility as a car manufacturer, a producer of stationary home storage or the importer of an Asian e-bike manufacturer. B2B companies that source batteries via system partners and bring them to market under their own name also count as operators placing products on the market.

Not directly affected are pure resellers who neither modify the product nor sell it under their own brand name. In practice, however, the boundary is often unclear. At the latest when a company passes on products with its own label, its own warranty or its own documentation, the obligation must be checked. Retailers and platforms will additionally enforce the requirement as a condition for listings, before authorities even become active.

Key point Anyone placing batteries subject to the obligation or battery-powered products on the EU market is affected, regardless of sector, size or B2B/B2C.

Battery Passport content: which data must be captured?

Annex XIII of the EU Battery Regulation defines the mandatory content of the Battery Passport. In total the list comprises more than 90 data points, which fall into seven content blocks.

We will publish a field list with all individual data points separately as a deep-dive, "Battery Passport requirements" (in production, going live July 2026).

Key point More than 90 data points spread across seven blocks. Anyone who sets up the data flow from the supply chain in a structured way additionally gains a permanently better picture of their own value chain.

Who may see which data?

Not all data in the Battery Passport is visible to everyone. The regulation provides for three access levels with different data depths. The separation is technically demanding and significantly determines the platform architecture.

Anyone working here without a clear platform architecture quickly builds up complexity that can no longer be resolved later. The permissioned level in particular requires a robust roles and rights concept with authentication, audit logs and data-field-granular control.

Key point Three access levels, three role concepts. Anyone who cleanly separates these layers in the platform architecture from the start gains regulatory certainty and an open path for new data services.

How does the Battery Passport work technically?

From a technical perspective, the Battery Passport is a chain of four building blocks: unique product identity, data carrier on the product, data space in the backend and connection to the central EU registry. Each of these building blocks has its own requirements.

The unique product identity (unique identifier) is assigned per individual product or per batch and follows international standards such as GS1 Digital Link. It is the indivisible anchor information to which all further data is attached. Anyone violating standards here risks interoperability problems along the entire supply chain.

The data carrier on the product is in most cases a QR code. NFC or RFID tags are discussed as a supplement; their regulatory admissibility for the Battery Passport has not yet been finally clarified in detail. The data carrier is not the Battery Passport itself but only leads to the data space. The regulation requires that it remains readable throughout the entire product lifetime, which makes material choice and attachment demanding in industrial environments with heat, vibration or chemical exposure.

The data space sits in the backend and contains the structured mandatory data plus optional extensions. It is usually multi-tenant, role-based and versioned. Connections to ERP, PLM, MES, PIM or quality systems must populate the data flows automatically, because manual maintenance does not scale across thousands of products and 90+ data points.

The EU registry connection is mandatory. The European Commission is currently building the central DPP registration infrastructure, which must be live for Battery Passports from February 2027. Through the registry, the existence of the Battery Passport, the responsible party and the access layers are centrally recorded. In-house implementations without a connection do not satisfy the regulatory obligation.

Key point Identity, data carrier, data space, EU registry. Four building blocks that work together. Anyone who thinks of them as shared infrastructure builds not just the mandatory Battery Passport but a viable data architecture for the years ahead.

Battery Passport and Digital Product Passport

The Battery Passport is the first sector-specific implementation of the Digital Product Passport. Legally it runs under the EU Battery Regulation. Technically and logically it belongs to the broader DPP system that the Ecodesign for Sustainable Products Regulation (ESPR) will introduce for almost all product categories.

Two levels help with understanding. At the regulation level, the Battery Regulation and ESPR are two separate legal acts. The Battery Regulation came earlier and has its own deadlines. ESPR is the horizontal framework that introduces the DPP for further product groups (textiles, furniture, electronics, steel, chemicals and more). Each delegated act for a product group triggers a transition period there.

At the system level, both build on the same infrastructure. The EU DPP registry, the identification and data carrier standards, the access models and the semantic data models are standardised horizontally. Responsible for this is the Joint Technical Committee 24 (JTC 24) of CEN-CENELEC, which develops the horizontal DPP standards. Anyone building a Battery Passport today should know the state of this standardisation work, because the Battery Passport and later DPPs run technically on the same basis.

The decisive strategic point: the Battery Passport is not the end but the beginning. Companies that today rely exclusively on an isolated Battery Passport solution build a point solution that will have to be touched a second time when ESPR expands. Anyone who instead chooses a platform such as the Narravero DPP platform, which serves both worlds, saves themselves this second round of integration.

The overarching view can be found at the Digital Product Passport, the regulatory basis at the ESPR.

Key point The Battery Passport and the DPP share infrastructure. Anyone who builds the Battery Passport also builds the basis for all further product groups from 2028.

The third infrastructure shift

The Battery Passport is the first visible element of an infrastructure shift that is comparable in weight to two historic events. In 1974 the barcode established a uniform product identifier along the entire retail chain. In 1991 HTTP created the standardised language with which systems worldwide exchange information. In 2027 the Battery Passport starts the third layer: standardised, machine-readable product data at individual-item level, mandatory and globally connectable.

What from a regulatory perspective looks like a compliance project is, from a business perspective, an infrastructure shift. Every product receives a permanent digital twin that can be linked, analysed and addressed. New channels arise as a result. Direct customer access without platform dependency, because the data runs through the product, not through marketplaces and platforms. First-party data arises at the product, in a quality that classic marketing stacks do not deliver. New business models become possible in data terms, from second-life use through certified resale to performance-based billing models.

Only 19 per cent of the companies affected by the DPP are comprehensively prepared, that is, with clear governance, assigned roles and C-level sponsorship.

KPMG European DPP Readiness Survey, February 2026

The remaining 81 per cent have no viable implementation plan. That is not a panic figure but an opportunity. Anyone who builds the data stack in the next 12 months has a head start over competitors who will have to catch up in a rush in 2027.

The Battery Passport is the prototype. What is built there in terms of architecture, governance and data quality can be transferred to further product groups as soon as ESPR acts for textiles, furniture or electronics follow.

Key point Barcode 1974, HTTP 1991, DPP 2027. Three infrastructure shifts. Anyone who helps shape the third one early influences the new standards and secures an advantage in data, customer channel and business model.

From compliance project to business value

Most companies see the Battery Passport as a mandatory task. That is understandable but strategically narrow. The regulatory requirements justify the budget; the actual value arises in the lifecycle that follows. Four concrete levers show how the compliance obligation becomes a business-model asset.

Lever 1: after-sales and service as a direct channel

A battery is not a throwaway product. EV batteries run for eight to twelve years, industrial storage 15 years and longer. It is over exactly this lifecycle that the service contact between manufacturer and end customer today runs in a fragmented way via repairers, OEMs and third-party providers. The Battery Passport makes the manufacturer the direct communication partner again: maintenance intervals, safety warnings, software updates, warranty handling, all run through the data space assigned to the product. That shifts a touchpoint owned today by third parties back to the brand.

Lever 2: second-life and resale as a second value-creation stage

Used EV batteries still have 60 to 80 per cent residual capacity at the end of their mobility phase. Classically they end up in recycling because there is no reliable data basis for second-life applications. With the Battery Passport this changes. The documented state-of-health history, charge cycles and operating conditions allow a differentiated assessment of the residual value. New markets arise from this: stationary storage from EV second life, certified refurbishment programmes, performance-based leasing models. Manufacturers who control this data basis control the second value-creation stage.

Lever 3: supplier transparency as a negotiating lever

The Battery Passport forces manufacturers to request supplier data on carbon footprint, raw material origin and recycled content in a structured way. At first glance that is tedious, but it creates something that barely existed before: a comparable data basis across suppliers. Anyone who collects the data consistently and integrates it into their own evaluation models gets an objective lever for purchasing decisions, risk assessment and long-term supplier development. Compliance becomes a driver of structured supplier management.

Lever 4: structured data exchange in the product ecosystem

The Battery Passport makes product data machine-readable and available in a standardised way for all relevant stakeholders. Customers, service partners, recyclers, second users and certifiers access the data released for them directly and take it into their own inventory systems. What today runs via emails, PDFs and manual data maintenance becomes a direct, auditable data stream. That reduces friction in the value chain and makes your own product more connectable in the partner network.

Key point Compliance finances the project. Service, second-life, supplier transparency and machine-readable data exchange pay it back. Anyone who thinks of both sides at once builds for the long term.

Value-creation infrastructure for the battery sector

So far we have looked at the Battery Passport from an operational perspective. Compliance, data structure, access model, service lever. At board level a different question arises: how does the Battery Passport change the strategic position of the company in a sector where competition is fought over scale, cost and raw materials?

The answer lies not in a single new revenue source but in a structural advantage. The Battery Passport establishes a data basis that is not accessible to classic competitors without a DPP strategy. This is relevant in three dimensions.

First, cost of capital. Banks and investors increasingly assess battery manufacturers by ESG metrics. The Battery Passport delivers verified carbon footprints, recycled-content rates and due diligence evidence. Companies with a reliable DPP data basis can serve EU taxonomy requirements and green-bond frameworks considerably more easily. This indirectly affects financing costs and capital availability.

Second, tier-1 position. Car manufacturers are actively reshaping their battery suppliers. It is not the cheapest supplier that wins in the long term but the one with the best data basis. Catena-X, the data ecosystem standard of the automotive industry, has established its own battery passport standard. OEMs are increasingly aligning their supplier requirements with it. Anyone who cannot demonstrate compatible data flows by 2026 risks their tier-1 position.

Third, product innovation. Anyone with real-time data on performance, state of health and usage patterns across thousands of batteries in the field can improve iteratively. Cell technology, BMS optimisation, thermal management, all of it benefits from field data that the Battery Passport provides in a structured way. Competitors who do not have this data learn more slowly.

Key point The Battery Passport is not just compliance but a lever for cost of capital, tier-1 position and product innovation. Anyone who understands it as a data platform wins strategically.

The biggest challenges in practice

Companies that start with implementation typically run into four core problems. None of them is new, all are solvable, but each costs time if recognised too late.

Data availability from the supply chain. A large part of the mandatory information arises not at the manufacturer but at upstream suppliers: cathode manufacturers, cell manufacturers, material suppliers. Frameworks such as the Catena-X Battery Passport, the Battery Pass consortium and the work of the Global Battery Alliance provide templates for standardised data exchange and continuously update the data models. Anyone who uses these structures early builds a reliable data basis before it is required by regulation.

Carbon footprint calculation to PEFCR methodology. The Product Environmental Footprint Category Rules for batteries prescribe how the footprint is to be calculated. The methodology is demanding, and LCA expertise (life cycle assessment) is often not available internally. Many companies underestimate how much data quality and what software support are needed.

IT integration. The data sits in different systems: ERP, PLM, MES, quality system, CRM, document management, PIM. The Battery Passport must bring all these sources into a consistent model and from it generate, at product level, a data record that can be queried. Point solutions regularly fail here on integration depth.

Governance and responsibilities. Who is responsible for data quality? Who updates entries when products change? Who keeps compliance stable over ten years of minimum retention? These questions are organisational, not technical. They often stay open too long, and that holds up the technical implementation.

Key point Anyone who clarifies responsibilities early and sets up the data flow from the supply chain in a structured way creates lead time, certainty and a real data advantage in the market.

The 5-step roadmap

18 February 2027 is approaching. For some that sounds far away, for others not. It makes no difference to the outcome: all manufacturers subject to the obligation must be ready in time. The following five steps give a pragmatic framework for becoming operational over the next 9 to 12 months.

Implementing the Battery Passport with the Narravero DPP platform

Narravero operates a DPP platform, an infrastructure for product data that helps ensure compliance and translate regulatory requirements into strategic competitive advantage. Over 200 enterprise customers from 12 sectors use the DPP platform, including B&W International and COR. It processes 300 million DPP accesses per month, hosted in the EU and fully GDPR-compliant. Narravero is a GS1 Solution Partner and was recognised in 2025 with the Global DPP Excellence Award.

What makes the difference: the Narravero DPP platform is not built for a single industry. The Battery Passport, future ESPR product passports and existing traceability requirements run on a shared infrastructure. The platform brings the flexibility to implement all current and future requirements for Digital Product Passports reliably, interoperably and in a connectable way.

CEO Thomas Roedding is active in a personal capacity in European standardisation bodies for the Digital Product Passport, currently as Co-Chair of CEN-CENELEC JTC 24, as Vice Chairman at DIN and in the work of ISO/IEC JC5.

The typical implementation process with Narravero begins with a DPP readiness analysis: which data points are required by regulation? Do they exist today in legacy systems such as ERP or PIM, at suppliers, or do they still need to be created? What is still missing? From this a concrete data and implementation plan emerges, which forms the basis for Battery Passport creation, EU registration and go-live.

If implementing the Battery Passport is a topic for you, the simplest next step is a 30-minute initial conversation. Not a pitch session but a factual assessment of your situation, to give clear recommendations for action and show the next steps.

Book an initial conversation →

Frequently asked questions about the Battery Passport

Next steps

You now have the overview. Two possible next steps, depending on where you stand: