Battery DPP: Complete Guide to the EU 2027 Regulation

What is EU Battery Regulation 2023/1542?

EU Regulation 2023/1542, in force since August 2023, replaces the 2006 Battery Directive. It establishes a comprehensive framework covering the entire battery lifecycle: design, manufacturing, distribution, collection, recycling, and recovery.

Its ambition is to align the sector with the European Green Deal: reduce the carbon footprint of batteries, secure the supply of critical raw materials, and position Europe as a leader in circular economy for batteries.

The centrepiece of this framework is the Battery Digital Product Passport (DPP) — a transparency instrument that makes the entire battery value chain readable, from mine to recycler.

Which batteries are covered by the DPP?

Scope is defined by category, with a capacity threshold that applies to one category only:

Two points are frequently reported the wrong way round. The 2 kWh threshold applies to industrial batteries only: an e-bike or e-scooter battery is covered regardless of capacity. And portable batteries, like SLI batteries, are outside the passport altogether.

One shortcut to avoid: outside the passport does not mean outside labelling duties. From 18 February 2027, all batteries placed on the market must carry a QR code, under Article 13 and Annex VI Part C. That code leads to a passport only for the three categories at the top of the table.

Batteries incorporated into equipment connected with the protection of Member States' essential security interests, arms, munitions and war material, or designed to be sent into space, are outside the scope of the regulation and therefore outside the passport (Article 1).

What data must the Battery DPP contain?

The regulation defines a precise set of data points, grouped into key categories:

General information and identification

• Unique battery identifier
• Manufacturer, brand, model, serial number
• Date and place of manufacture
• Mass, nominal voltage, nominal capacity

Performance and durability data

• State of health (SoH) and state of charge (SoC) for electronically managed batteries
• Number of full charge cycles
• Power capacity and available energy
• Internal resistance

Materials and substances

• Chemical composition (cobalt, lithium, nickel, lead, manganese…)
• Substances of concern present in the battery
• Share of recycled raw materials (cobalt, lithium, nickel, lead)

Carbon footprint

• Lifecycle carbon footprint (in kg CO₂e/kWh)
• Calculation method used
• Declaration of conformity to the carbon intensity class

Responsible supply chain

• Due diligence policy
• Suppliers of critical raw materials
• Responsible sourcing certifications

End-of-life information

• Instructions for disassembly and battery removal
• Accessible collection points
• Recycling and treatment procedures

The QR code, cornerstone of the Battery DPP

From 18 February 2027, every battery placed on the market must carry a QR code as described in Annex VI Part C, whose technical guidance points to the ISO/IEC 18004 standard. The GS1 Digital Link format is a common and compatible implementation, but the regulation does not impose it: what is required is that the code leads to the required information and stays machine-readable.

For the three categories covered by the passport, the code gives access to information organised in three levels:

• Public access: identification, technical characteristics, end-of-life information.
• Access for persons with a legitimate interest: detailed composition, performance data, dismantling and repair information.
• Authority access: test results and conformity evidence.

The digital product passport registry, established under the ecodesign regulation and implemented by Commission Implementing Regulation (EU) 2026/1778, has been operational since 20 July 2026. The system remains decentralised: the responsible operator hosts the data, the registry holds the identifiers.

How to prepare for Battery DPP compliance?

Compliance requires coordination across multiple business functions: supply chain, quality, R&D, legal, and IT. Here are the key steps:

Step 1: Map your batteries and define the exact scope

List all your battery products, their categories, and capacities. Determine which ones are subject to the DPP and from which date.

Step 2: Assess your existing data

Compare what you already have (technical sheets, chemical analyses, carbon assessments) against the full list of required fields. This exercise typically reveals significant gaps around carbon footprint and raw material traceability.

Step 3: Collect missing data

For carbon footprint, you will need a lifecycle assessment (LCA) or an environmental product declaration (EPD) conforming to the battery product category rules (PCR). For recycled raw materials, start engaging your suppliers now — lead times can be long.

Step 4: Choose suitable DPP software

Use a platform like DPPify that handles battery-specific fields, the public page accessible by QR code, and the differentiated access levels required by the regulation. This avoids the need to build a bespoke technical infrastructure.

Step 5: Test and audit before market placement

Before selling your batteries in Europe, verify that the QR code is functional, that all data is accessible at the right levels, and that your declaration of conformity is in order.

Penalties for non-compliance

The Battery Regulation delegates sanction rules to member states. In practice, national market surveillance authorities and customs are the primary enforcement bodies. Consequences can include:

• Product withdrawal from the market
• Administrative fines proportional to turnover
• Temporary ban on market placement

Conclusion

The Battery DPP is the first large-scale live test of the Digital Product Passport in Europe. Its entry into force on 18 February 2027 makes it a priority project for every actor in the battery sector. The earlier you start — data collection, software selection, testing — the less pressure you will face as the deadline approaches.

DPPify supports battery manufacturers and distributors through their compliance journey, from the initial data audit to publishing a compliant QR code.

For the detail of the 71 data points published by the Commission on 21 August 2026, and to see which of them genuinely apply on that date, see Battery passport: the 71 data points required, and those that are not yet.

Sources

• Regulation (EU) 2023/1542 — Articles 1, 13, 77, Annexes VI and XIII, EUR-Lex
• Commission Implementing Regulation (EU) 2026/1778 of 16 July 2026 — arrangements for the DPP registry, EUR-Lex
• Digital product passport, batteries — European Commission, implementation timeline

Published on 7 June 2026, revised on 10 October 2026: scope corrected (portable and SLI batteries are outside the passport), Article 13 QR code requirement for all batteries, code format and access levels clarified, registry status updated.