The Battery Passport from 2027: What to Know
Batteries are the first product for which a Digital Product Passport becomes a real obligation. That makes the battery sector the natural "case zero" for the DPP in the Union. If you make, import or place batteries on the market, this deadline concerns you directly.
The legal basis
The battery passport obligation does not come directly from ESPR but from a separate instrument — Regulation (EU) 2023/1542 on batteries. It is a distinct legal act, yet it fits the same logic of the Digital Product Passport.
It is worth remembering this: the battery passport and the general DPP mechanism under ESPR are related but separate regulatory tracks. Batteries simply run ahead of the rest.
When it applies
The key date is 18 February 2027. From that day the battery passport becomes required for the covered categories. It is one of the most certain dates in the whole DPP landscape, because it is written into a regulation already adopted.
For companies this means a concrete, not-distant horizon. In practice, preparation — especially on the data side — is worth starting well before the final months.
A passport at the item level
A defining feature of the battery passport is its granularity. It is required at the level of the individual item, not just the model or batch.
This means each covered battery has its own unique identifier and its own data record. That is a more demanding approach than a model passport and requires a solid system for assigning and maintaining identifiers. We cover the differences between levels in Model, batch, item.
Which batteries it covers
The obligation does not cover every battery without exception, but the categories specified in the regulation. The scope is defined in the rules, and that is what decides whether a given product is subject to a passport.
So the first step should be to determine whether your products fall into the covered categories. It is a legal-technical decision worth taking early and documenting.
What data it holds
The battery passport gathers structured information about the product. Although the exact scope follows from the rules, it can be understood in a few layers:
- the battery's identity and identifiers,
- composition and materials used,
- environmental and life-cycle information,
- data relevant to handling the battery at end of use.
It is this record — not the carrier or code — that is the essence of the passport. More on this principle in DPP vs QR code.
The battery passport and ESPR
If batteries have their own regulation, why connect them to ESPR? Because the same approach — identifier, carrier, digital record — will repeat in later sectors covered by ESPR.
Batteries are therefore a preview of a broader trend. Lessons from their rollout will be useful for companies in other industries that join in later waves. We lay out the full picture in the ESPR timeline.
Do not confuse it with CBAM or other rules
Several separate regulations appear around batteries and should not be confused. CBAM, the carbon border adjustment mechanism, is a distinct instrument with a different purpose than the battery passport.
Likewise other rules — such as PPWR on packaging — run in parallel but are not the same as the battery passport. It is worth keeping these obligations apart so you do not build data for the "wrong" rule.
Layered access to data
As with other passports, not all battery data is public. Some information is public, and some is reserved for surveillance authorities or authorised parties.
Responsibility for the accuracy of the data rests with the economic operator — the manufacturer or importer placing the battery on the market. A platform provider does the technical work but does not take on that legal responsibility.
What to do now
Less time remains until February 2027 than it seems. Sensible first steps are:
- determining which products fall into the covered categories,
- gathering data on composition, materials and life cycle,
- designing an identifier system at the level of the individual item,
- choosing a platform to build, publish and maintain passports.
The earlier you start, the less risky it is to meet the deadline.
Why batteries first
Batteries came first for a reason. They have their own, earlier-adopted regulation, which is the first to introduce a full product passport at the level of the individual item.
For the market as a whole this means the battery sector is 'clearing the path'. The organisational and technical solutions worked out for batteries will become a reference point for the next sectors covered by ESPR.
The supply-chain challenge
The hardest part of the battery passport is often not the technology but the data. Information on composition, materials or the origin of raw materials usually comes from many suppliers at different stages of the chain.
Bringing it together into a consistent, credible record takes time and cooperation. So it is worth writing data requirements into supplier relationships now, rather than obtaining them under deadline pressure.
Registration in the EU registry
The battery passport also involves registering identifiers in the EU DPP registry, which is to launch from mid-2026. The registry works as an index — it stores identifiers and metadata, not the full passport data.
The data itself stays decentralised, with the company or its service provider. It is worth accounting for this split of roles when planning your own architecture.
Key takeaways
- The battery passport stems from Regulation (EU) 2023/1542 and applies from 18 February 2027.
- It is required at the level of the individual item, not just the model.
- It covers the categories specified in the regulation — first check whether it applies to your products.
- It is a separate instrument from ESPR and from CBAM — these rules should not be confused.
- The manufacturer or importer owns the accuracy of the data; preparation is worth starting now.
See how CyfroPass lets you build and publish a Digital Product Passport without writing code. Visit cyfropass.pl and start with your first product.