The EU Digital Battery Passport becomes mandatory on 18 February 2027. Yet with only a few months to go, several parts of its technical and regulatory implementation are still being finalised. For battery manufacturers, importers and companies building Digital Product Passport (DPP) solutions, this raises a practical question: how do you implement a compliant Battery Passport today when some of the rules governing it are still evolving?
The answer starts with separating three situations:
- Requirements already established: obligations clearly defined in existing EU legislation.
- Requirements awaiting clarification: implementing acts, standards and practical guidance that are still being finalised.
- Possible future developments: changes that EU legislation allows for or that policymakers may consider, but which are not yet mandatory.
This distinction matters. Companies should neither postpone their whole Battery Passport project until every technical detail is settled, nor invest in capabilities that may never become mandatory. This article looks at the main uncertainties at the time of the last regulatory review, the changes expected over the next few years and how to prepare a future-ready Battery Passport architecture.
1. What is already certain about the Battery Passport?
Under Article 77 of Regulation (EU) 2023/1542, an electronic Battery Passport is mandatory from 18 February 2027 for each of the following batteries placed on the market or put into service:
- electric vehicle (EV) batteries;
- light means of transport (LMT) batteries, such as e-bike and e-scooter batteries;
- industrial batteries with a capacity greater than 2 kWh.
The 2 kWh threshold is not universal: an LMT battery needs a passport even when its capacity is below 2 kWh.
The QR code on each covered battery links to a unique identifier, which must follow ISO/IEC 15459 (Art. 77(3)). The passport contains the applicable information listed in Annex XIII, partly at battery model level and partly for the individual battery. Article 77(5) requires the passport to be based on open standards, interoperable with other digital product passports, transferable without vendor lock-in, and machine-readable, structured and searchable. Access is organised by stakeholder group, and the passport must meet requirements on data availability, security and integrity.
Under Article 77(4), the economic operator placing the battery on the market is responsible for the information being accurate, complete and up to date. It can give another operator written authorisation to act on its behalf, but it keeps the responsibility. We explain the roles in more detail in who is responsible for the Digital Product Passport.
These foundations are established. What remains uncertain is not whether the Battery Passport will exist, but how certain parts of the system will be implemented and evolve.
2. Battery Passport data: are all required attributes finally defined?
One of the biggest implementation challenges is knowing exactly which information a Battery Passport must contain from February 2027. Annex XIII sets out the main requirements, but they do not apply equally to every battery: some data is mandatory, some depends on the battery category or design, and some is tied to obligations that start only after February 2027.
What has already been clarified?
The Commission's guidance "Digital Batteries Passport - data points by category", version 2.0 dated 15 August 2026 and published on 21 August, maps 71 data points for EV, LMT and industrial batteries. Each data point is assigned to one of four classes:
- mandatory;
- optional;
- applicable only in certain cases;
- not to be filled or displayed as of February 2027.
Identification, manufacturing, chemistry, technical characteristics and conformity documentation are covered from the start. The sustainability data follows separate schedules: the carbon footprint (data points 17-18) and recycled content (data points 20-23) are not to be filled in February 2027, while responsible sourcing (data point 19) is marked as required from August 2027, in line with the postponed due diligence obligations. Data point 44 (instructions for use) is on hold pending the adoption of the Omnibus proposal discussed in section 11. The guidance is non-binding; the Regulation remains the legal reference.
What is still evolving?
Data definitions and precision. Some attributes still need consistent interpretation across manufacturers and platforms. Material composition is the clearest example. The Commission's Battery FAQ (September 2026, first edition) describes a 1% reporting threshold based on a DIN SPEC and a 0.1% threshold from a draft CEN technical specification as "potentially reasonable" approaches. Neither is a legal threshold. The FAQ is clear, however, that a bare chemistry label such as "LFP" is not enough.
Formats and units. The data-point guidance is versioned, and later versions may refine individual definitions, measurement units and reporting formats.
Applicability of particular attributes. Some requirements depend on battery chemistry, design, intended use or the availability of specific supporting information.
What should manufacturers do?
Rather than treating Annex XIII as a fixed list of fields, companies should set up a structured data model that supports:
- versioning of attribute definitions;
- different requirements for different battery categories;
- conditional and future-mandatory fields;
- traceability of data sources;
- extension of the model without rebuilding existing passports.
The goal is a data architecture that absorbs regulatory changes without a new implementation project each time a requirement evolves.
3. Access rights: who can see, download or share passport information?
This is one of the most significant topics still awaiting clarification. Article 77 and Annex XIII distinguish several levels of access: some information is public, some is reserved for notified bodies, market surveillance authorities and the Commission, and some is restricted to persons with a legitimate interest, such as repairers, remanufacturers, second-life operators and recyclers.
What is still missing?
Under Article 77(9), the Commission must adopt an implementing act specifying the persons with a legitimate interest and the extent to which they can download, share, publish and re-use the information. The legal deadline for this act, 18 August 2026, was missed. According to the Battery FAQ (question 1.4), a draft is expected for public feedback on the Commission's "Have Your Say" portal in October or November 2026, with adoption planned for the fourth quarter of 2026.
Why does this matter?
Take a battery recycler. It needs detailed material composition and dismantling information, which may also contain commercially sensitive know-how. The DPP system must distinguish legitimate operational access from unrestricted disclosure.
There is also a technical question: how will the system reliably establish that a requesting user really is an authorised recycler or repairer? The FAQ (question 6.4) states that authentication is decentralised and not operated centrally. The EU registry does not give access to the full passport either (question 6.5). For DPP providers, access control therefore has to stay configurable while the final rules emerge.
What should companies prepare?
A good system supports granular permissions, authenticated users, different data categories and controlled sharing. A rigid model with only two categories, public and private, may prove insufficient.
4. DPP technical standards: is the interoperability framework complete?
A Battery Passport should not live exclusively inside one proprietary application. Article 77(5) requires open standards, interoperability and transferability without vendor lock-in.
Important progress has been made. Commission Implementing Decision (EU) 2026/1736 of 14 July 2026, published in the Official Journal on 15 July, cites six harmonised standards:
| Standard | Main area |
|---|---|
| EN 18216:2026 | Data exchange protocols |
| EN 18219:2026 | Unique identifiers |
| EN 18220:2026 | Data carriers |
| EN 18221:2026 | Data storage, archiving, and persistence |
| EN 18222:2026 | APIs for product passport lifecycle management and searchability |
| EN 18223:2026 | System interoperability |
One detail is easy to miss: these standards are cited under the Ecodesign for Sustainable Products Regulation (ESPR, Regulation (EU) 2024/1781). They give a presumption of conformity with Articles 10 and 11 of the ESPR, not with the Batteries Regulation. They are still the natural technical reference for battery passports, but they do not by themselves prove compliance with Article 77. Two further standards, on access rights and security, are still pending.
What could change?
Standards may be supplemented, updated or clarified as the first large-scale implementations reveal interoperability problems. Companies should check how their DPP provider supports:
- standardised product identifiers;
- machine-readable information exchange;
- standard API interfaces;
- migration and export of data;
- long-term availability;
- changes to the underlying technical specifications.
A passport built only as a proprietary web page, without structured data exchange, is a long-term risk.
5. Will DPP solution providers need to be officially certified?
Terminology easily causes confusion here, because several different kinds of verification exist.
Verification of the economic operator
The EU DPP registry, established by Article 13 of the ESPR, was launched on 20 July 2026. Commission Implementing Regulation (EU) 2026/1778, adopted on 16 July and in force since 6 August 2026, sets out how it works, including eIDAS-based verification of economic operators: legal persons verify with a qualified electronic seal or a qualified electronic attestation of attributes, and the verified status lasts at most three years. Article 77(10) of the Batteries Regulation requires the battery's unique identifier to be uploaded to this registry.
Verification establishes who the operator is. It does not certify the quality of every passport that operator issues. See what the EU DPP registry validates for the details.
Technical testing of the DPP solution
Software providers can test their implementations with tools such as BatteryPass-Ready, a project funded by the German Federal Ministry for Economic Affairs and Energy (BMWE) and led by Fraunhofer IPK. Its free test and validation environment has been live since 24 June 2026. These tests are useful because they check defined aspects of data structure, interfaces and interoperability. But BatteryPass-Ready is not an EU body and does not issue certifications; passing its tests is not an official EU certification. We look at this more closely in battery passport compliance testing with BatteryPass-Ready.
Future rules for DPP service providers
The ESPR introduces the concept of digital product passport service providers, and the Commission is preparing a delegated act under the ESPR on them, expected in 2027 (the Commission's timeline points to the second or third quarter of 2027). It may cover hosting, persistence, security, backup, service continuity and provider verification. The Batteries Regulation itself, as the FAQ (question 10.3) puts it, "does not define or regulate 'solution providers'".
Being a verified economic operator, passing a technical test and any future recognition as a DPP service provider are three different things.
What should battery manufacturers ask their DPP provider?
- Evidence of conformity with the applicable published technical standards.
- Results of interoperability and data-validation testing.
- How the system handles access restrictions.
- How data is stored, secured and kept available over the long term.
- A clear contractual mechanism for data portability and service termination.
- A commitment to adapt the platform when further binding technical rules apply.
This matters because the responsible economic operator cannot outsource its regulatory responsibility together with the DPP infrastructure.
6. Dynamic data: how often must the passport be updated?
A Battery Passport is not necessarily a static document. Some information describes the battery at manufacture; other information changes during its life, such as state of health where applicable, remaining capacity and performance indicators, battery status and lifecycle events, or information linked to repurposing and remanufacturing.
What is already known?
According to the Battery FAQ, dynamic data requirements apply from February 2027, insofar as the relevant information requirements apply. That does not mean every battery must stream data continuously. In the FAQ's words: "At a minimum, dynamic data must be updated when a change in the battery's status occurs or is being considered." More frequent updates may be appropriate for some applications. An offline e-bike battery, for example, can reasonably have its dynamic data updated during servicing. Some data generated in use will simply not exist yet when a new battery is first placed on the market.
What remains an operational challenge?
Manufacturers still have to decide which systems provide dynamic data, who may update the passport, how changes are validated and recorded, and what happens when the battery is disconnected or changes owner. The right answer differs between an EV traction battery, a stationary storage system and a simple industrial battery.
What could evolve?
Passports could become more closely connected to battery management systems, diagnostic tools and maintenance platforms, enabling automated updates, richer lifecycle histories and better second-life assessments. But a possible technical solution is not a universal legal requirement. Support dynamic information where it is needed, without imposing unnecessary complexity on every battery.
7. What happens when a battery is repaired, repurposed or remanufactured?
The passport is meant to follow the battery through its life, and Article 77 already covers several situations. When a battery is prepared for re-use, prepared for repurposing, repurposed or remanufactured, a new passport is required and must be linked to the original one or ones, and responsibility passes to the operator that places the battery on the market or puts it into service. A simple repair does not automatically require a new passport. When the battery becomes waste, responsibilities change again, and once it has been recycled the passport ceases to exist (Art. 77(8)).
What remains challenging?
The legal principles are clear; implementation gets harder when several companies are involved:
- How does the second-life operator obtain the original battery information?
- How does it establish and record its responsibility?
- How do original and new passports stay linked?
- What happens when the original manufacturer has ceased operations?
- How is the history of relevant changes preserved?
These cases call for careful handling of data access, lifecycle management and transfers of responsibility, and for long-term data availability. The certified backup provider question is part of the same picture. Over time, Battery Passports are likely to play an ever larger role in resale, remanufacturing, second life and recycling.
8. Carbon footprint: a major wave of new information requirements
Article 7 introduces progressively stricter carbon-footprint requirements for rechargeable batteries in three steps:
- Declaration: manufacturers declare the life-cycle carbon footprint per battery model, using the EU calculation methodology.
- Performance classes: batteries are then classified by their carbon footprint, giving a common basis for comparison.
- Maximum thresholds: later, batteries must stay below a maximum life-cycle carbon footprint. This moves from transparency to an actual performance limit.
When will these requirements apply?
Each date in Article 7 is "the later of" a fixed date or a set period after the relevant delegated or implementing act enters into force. The date in the Regulation is therefore not necessarily the date that applies in practice.
| Battery category | Declaration, Art. 7(1) | Performance class, Art. 7(2) | Maximum threshold, Art. 7(3) |
|---|---|---|---|
| EV batteries | 18 Feb 2025 or act + 12 months | 18 Aug 2026 or act + 18 months | 18 Feb 2028 or act + 18 months |
| Rechargeable industrial batteries (except exclusively external storage) | 18 Feb 2026 or act + 18 months | 18 Aug 2027 or act + 18 months | 18 Feb 2029 or act + 18 months |
| LMT batteries | 18 Aug 2028 or act + 18 months | 18 Feb 2030 or act + 18 months | 18 Aug 2031 or act + 18 months |
| Industrial batteries with exclusively external storage | 18 Aug 2030 or act + 18 months | 18 Feb 2032 or act + 18 months | 18 Aug 2033 or act + 18 months |
In each cell, whichever date is later applies. Under the data-point guidance, no carbon-footprint data is to be filled in the passport from February 2027.
Why does this matter for DPP architecture?
The first passport mostly draws on product master data. A carbon-footprint declaration depends on much more: material composition and quantities, suppliers and production sites, the energy mix, manufacturing processes, the recognised calculation methodology and supporting documentation. That raises the importance of supplier data integration (see missing battery data from suppliers) and creates new versioning needs when a model is built in several plants or production conditions change.
The Battery Passport will increasingly depend on verified sustainability information, not just identification and technical specifications.
9. Recycled content: new indicators and potentially stricter targets
Article 8 covers cobalt, lead, lithium and nickel recovered from waste, and introduces documentation requirements first and minimum shares later. The scope is industrial batteries above 2 kWh except those with exclusively external storage, EV batteries and SLI (starter) batteries, with LMT batteries added later.
| Milestone | Requirement |
|---|---|
| 18 Aug 2028, or 24 months after the delegated act, whichever is later | Recycled-content documentation for the batteries in scope (industrial > 2 kWh except exclusively external storage, EV, SLI) |
| 18 Aug 2031 | First minimum recycled-content shares for the same batteries, LMT excluded |
| 18 Aug 2033 | Recycled-content documentation for LMT batteries |
| 18 Aug 2036 | Higher minimum shares, now including LMT batteries |
| Material | Minimum from 2031 | Minimum from 2036 |
|---|---|---|
| Cobalt | 16% | 26% |
| Lead | 85% | 85% |
| Lithium | 6% | 12% |
| Nickel | 6% | 15% |
These figures are subject to the exact scope, calculation rules and any amendment the Regulation provides for.
Could these targets change?
Yes. Under Article 8(5), the Commission must assess by 31 December 2028 whether the targets remain appropriate in light of the availability of recovered materials, and may amend them by delegated act by 18 August 2029 if justified. For DPP systems, recycled-content reporting should therefore not be hard-coded around today's figures; the platform should support revised targets, methodologies and additional indicators.
Note one distinction: SLI batteries face recycled-content obligations although they do not need a full Battery Passport. The scope of a sustainability obligation and the scope of the passport are not always the same.
10. Could batteries below 2 kWh eventually need a full Battery Passport?
This is a longer-term question for makers of smaller industrial, portable and starter batteries. Today, industrial batteries of 2 kWh or less are outside the Article 77 passport requirement unless they fall into another covered category, and portable and SLI batteries are outside it too. However, under Article 13(6) all batteries must carry a QR code from 18 February 2027, giving access to the information applicable to their category. Digital information requirements therefore exist even where a full passport does not; we explain them in no battery passport needed? The digital battery data behind the QR code.
Could the scope expand later?
It is possible, but no general extension has been adopted. Two mechanisms are worth watching:
- The review of the Regulation. Under Article 94, the Commission must review the Regulation by 30 June 2031, explicitly including the battery passport measures (Art. 94(2)(f)). This could lead to proposals, possibly on scope, but the review itself extends nothing.
- The carbon-footprint assessment. Under Article 7(4), the Commission must assess by 31 December 2030 whether to extend the carbon-footprint requirements to portable batteries and the maximum threshold to rechargeable industrial batteries of 2 kWh or less. That is not an obligation to extend the full passport to these batteries.
What is the likely direction?
Broader use of structured digital battery data looks plausible: digital identification is becoming relevant across categories, and structured product, manufacturing and environmental data supports recycling, reporting and traceability. Still, a passport for all batteries remains a possible policy development, not an announced obligation. Manufacturers outside today's scope should follow the developments without assuming a full passport will follow automatically.
11. Other developments that could reshape Battery Passports after 2027
A pending Omnibus proposal
The Commission's Omnibus VIII proposal, COM(2025) 981 of 10 December 2025, would also amend the Batteries Regulation. Among other things, it would replace the information on "hazardous substances" with information on substances of very high concern above 0.1%, which affects passport data. It has not been adopted, which is why the data-point guidance keeps point 44 on hold.
Due diligence
Regulation (EU) 2025/1561 postponed the due diligence obligations to 18 August 2027 (Art. 48(1)) and the deadline for the Commission's guidelines to 26 July 2026. Responsible-sourcing information therefore enters the passport later than the core data.
Stronger supply-chain traceability
Future requirements will raise the value of linking battery-level data with data from cell producers, material suppliers and plants. Not every supply-chain record belongs in the passport, but manufacturers will need reliable access to the source data behind their declarations.
Integration with other Digital Product Passports
As the DPP framework expands to more sectors, battery data may need to connect to records for vehicles, industrial equipment and other products. Article 78 already makes interoperability part of the passport's technical design. The opportunity is to connect information across systems without duplicating it. Our overview of EU DPP regulations by industry shows where this is heading.
Richer lifecycle information
Second-life markets may push for richer data on usage history, degradation, maintenance and condition, helping businesses assess residual value and pick the right reuse or recovery route.
New battery technologies
New chemistries, materials and processes may need different data structures or indicators. Article 77(2) empowers the Commission to amend Annex XIII by delegated act in light of technical and scientific progress, so the list of passport data is not frozen.
More automated compliance checks
The registry, standardised data models and interoperability standards lay a foundation for more automated validation, spotting missing or inconsistent data and supporting market surveillance. Automated technical validation, however, does not prove that every underlying declaration is accurate.
12. How should companies prepare while the rules are still evolving?
The open questions are no reason to wait. The core obligation is in place and 18 February 2027 remains the legal date. The better approach is to separate what must be implemented now from what can be prepared for later activation.
A practical readiness strategy
- Implement the confirmed requirements first. Build the initial passport around the mandatory data for your batteries and the existing legal and technical requirements.
- Prepare for future sustainability indicators. Identify where carbon-footprint, recycled-content and due diligence data will come from, even before it is required in the passport.
- Choose a flexible data model. Avoid implementations that need custom development whenever an attribute, unit, rule or battery category changes.
- Keep access rights configurable, ready for the implementing act on legitimate-interest access.
- Design for the battery lifecycle: updates, new passport versions, changes of responsibility and links between original and successor passports.
- Check your DPP provider's interoperability: applicable standards, structured data exchange and the ability to adapt.
- Monitor the Commission's roadmap: access rights, service-provider rules, standards, the Omnibus and new environmental reporting obligations.
The aim is not to predict every regulatory decision. It is to reduce the cost and disruption of adapting when those decisions arrive.
13. How GoodsTag helps companies build future-ready Battery Passports
At GoodsTag, we see Battery Passport implementation as more than a one-time compliance exercise. February 2027 is the start of a longer transition towards structured, interoperable, lifecycle-oriented battery information.
The GoodsTag Digital Product Passport platform connects physical products to structured digital information, supports standardised product identification and provides a foundation for managing evolving DPP requirements. With a focus on open standards, interoperability and flexible product data management, it helps companies meet the requirements already defined while staying able to address future ones.
The GoodsTag Battery DPP solution has passed the BatteryPass-Ready test scenarios it ran, which is additional evidence of its technical readiness within the tested scope. BatteryPass-Ready itself describes its results as indicative feedback, not a certification. It does not replace product-level regulatory compliance or any future formal service-provider assessment, but it shows the value of checking DPP implementations against recognised test frameworks.
For battery manufacturers the objective is simple: comply with today's requirements without rebuilding your Battery Passport infrastructure when tomorrow's requirements arrive.
Whether you make EV, LMT, industrial or other batteries affected by the Regulation, GoodsTag can help you evaluate your Digital Battery Passport strategy and implementation. Contact GoodsTag to discuss your Battery DPP requirements.
Sources
- Regulation (EU) 2023/1542 on batteries and waste batteries, consolidated version of 13 August 2026, Articles 7, 8, 13, 48, 77, 78 and 94; Annex XIII
- Regulation (EU) 2025/1561, postponement of the battery due diligence obligations
- Regulation (EU) 2024/1781 (Ecodesign for Sustainable Products Regulation), digital product passport framework and registry
- Commission Implementing Decision (EU) 2026/1736, harmonised DPP standards
- Commission Implementing Regulation (EU) 2026/1778, EU DPP registry
- European Commission: EU Digital Product Passport FAQ - batteries
- European Commission: Digital product passport for batteries, including the data points by category guidance
- European Commission: Digital product passport
- Commission proposal COM(2025) 981 (Omnibus VIII)
Last regulatory review: 10 October 2026. Future dates, proposed changes and technical developments must be checked against the legal acts adopted afterwards. Commission guidance is informative and does not replace binding legislation. This article is not legal advice.
