Battery DPP: the mandatory Digital Product Passport from February 2027
The Digital Product Passport for batteries is the most advanced DPP regulation. EU Battery Regulation 2023/1542 mandates digital passports for industrial batteries and EV batteries from February 2027 — with a delegated act already adopted. This guide explains what that means in practice.
Deadline: February 2027Delegated act adopted
The EU Battery Regulation 2023/1542 is the only sector with an already-adopted DPP delegated act. Manufacturers and importers of industrial batteries (> 2 kWh) and EV batteries must be compliant by February 2027.
Why the battery DPP is the most advanced regulation
Unlike textiles or electronics, the battery sector has a complete and already-adopted DPP regulatory framework. The EU Battery Regulation (EU 2023/1542) — separate from ESPR but parallel — mandates Digital Product Passports with a published delegated act and a firm enforcement date: February 2027.
This regulatory head start reflects the strategic importance of batteries for Europe's energy transition. The Commission needed to secure the critical raw material supply chain (cobalt, lithium, nickel, manganese) and impose strict carbon traceability before the mass rollout of electric vehicles.
As a result, the Battery Passport is today's reference point for what all other sectors will eventually need to do. Understanding its requirements means anticipating the future DPP obligations for electronics, textiles and industry.
Battery Passport regulatory timeline
The battery regulation has a precise, non-negotiable timetable:
| Category | Enforcement date | Status |
|---|---|---|
| Industrial batteries > 2 kWh | February 2027 | Delegated act adopted |
| EV batteries (electric vehicles) | February 2027 | Delegated act adopted |
| LMT batteries (light motorised transport) | August 2027 | In preparation |
| Portable batteries (off-device) | 2028 (estimated) | Under discussion |
| Stricter carbon thresholds | 2030 | kg CO₂/kWh caps required |
Which data goes into a battery DPP?
The Battery Passport is the most data-intensive DPP. The delegated act defines a precise list of mandatory fields, split into six families:
Manufacturer, model, serial number, GTIN, manufacturing date, factory GLN, mass, cell technology (Li-ion, NMC, LFP…), intended application.
Nominal capacity (kWh), rated power (kW), nominal voltage, state of health (SoH), state of charge (SoC), cycle count, guaranteed lifespan, temperature ranges.
Total carbon footprint (kg CO₂e/kWh), broken down by phase: raw material extraction, cell manufacturing, transport, use, end-of-life. Carbon class A/B/C/D (thresholds to be set).
% recycled cobalt, lithium, nickel, manganese; geographic origin of critical materials; supply chain due diligence (OECD compliance); responsible sourcing certifications.
Tier 1 supplier identification (cells, anode, cathode, electrolyte); countries of extraction for critical materials; country of assembly; batch numbers.
Disassembly instructions, recyclability codes, approved collector contact details, % reusable components, refurbishing procedure.
One particularly demanding requirement: traceability of critical materials (cobalt, lithium) back to the extraction mine, with compliance with the OECD Due Diligence Guidance. This has no equivalent in other DPP sectors.
How to prepare for the Battery Passport in 5 steps
With a firm deadline of February 2027, battery manufacturers and importers have less than 12 months to achieve compliance. Here is the roadmap.
- 1
Identify the batteries in scope
List your industrial battery references > 2 kWh and your EV batteries. For each reference, collect: cell technology, capacity, cell manufacturer, country of assembly. Verify whether your LMT batteries fall within the 2027 scope.
- 2
Collect data from cell suppliers
Contact your cell suppliers (CATL, LG Energy, Panasonic, BYD…) to obtain: cathode chemical composition, cobalt and lithium origin, OECD due diligence documents, cell manufacturing carbon footprint.
- 3
Calculate the full carbon footprint
The footprint must cover material extraction, cell manufacturing, pack assembly, transport and end-of-life. Specialised battery LCA tools (GaBi, SimaPro with ecoinvent data) enable this calculation. Allow 2-3 months.
- 4
Generate and publish the Battery Passports
Import your data into a battery-regulation-compliant DPP platform like DPPify. Each battery gets a JSON-LD passport, a public page and a GS1 Digital Link QR code. The passport is linked to the individual serial number of each battery unit.
- 5
Integrate into your manufacturing process
The Battery Passport must be updated throughout the battery's life: during refurbishing, if cells are replaced, or when state of health (SoH) changes. Embed updates into your production management system.
DPPify for battery manufacturers and integrators
DPPify natively supports the requirements of Battery Regulation 2023/1542. Our battery template covers all mandatory fields from the delegated act: performance data, carbon footprint, critical material traceability, end-of-life information.
Every Battery Passport generated by DPPify includes a GS1 Digital Link QR code linked to the individual serial number, a cryptographically signed UNTP Verifiable Credential, and a multilingual public page accessible to the buyer, regulator and recycler.
- Battery Passport template pre-configured per the 2023/1542 delegated act
- Individual serial number linking — each battery unit has its own unique passport
- Real-time SoH and SoC updates via API — a living passport across the full lifespan
- Critical material traceability (cobalt, lithium) with due diligence document import
- Signed UNTP Verifiable Credentials — your data is cryptographically verifiable by customs and buyers
Frequently asked questions about the battery DPP
Does the battery DPP cover portable batteries (smartphones, tools)?
Not immediately. The February 2027 obligation covers industrial batteries > 2 kWh and EV batteries. Portable and LMT batteries will follow, probably between 2027 and 2029. Check the delegated act specific to your category.
Is EU Battery Regulation 2023/1542 different from ESPR?
Yes. The battery regulation is a separate sector-specific regulation, adopted in 2023 before ESPR. It mandates DPP obligations similar in structure but with battery-specific data (SoH, SoC, cell chemistry, critical materials). ESPR is the general framework; the battery regulation is the battery-sector rule.
Is one passport required per individual battery or per model?
For industrial and EV batteries, one passport is required per individual unit, linked to the serial number. Model-level data (chemistry, nominal capacity) is shared, but state of health (SoH) and production traceability are specific to each unit.
Our cells come from an Asian supplier. How do we get the traceability data?
This is the main operational challenge. You must require from your cell supplier: critical material origin data and OECD due diligence documents. If the supplier cannot provide them, that is a compliance risk. Embed these requirements in your purchase contracts.
What happens to the Battery Passport when a battery is refurbished?
The Battery Passport must be updated during refurbishing: new SoH assessment, updated performance data, identification of the remanufacturer. The passport thus tracks the battery's full history across its entire lifespan.
Are battery importers subject to the same obligations as manufacturers?
Yes. Any economic operator placing a battery on the European market is responsible for DPP compliance — whether manufacturer, importer or own-brand distributor. Importers of Asian batteries must require DPP data from their suppliers.