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The Ecodesign for Sustainable Products Regulation (ESPR) entered into force on 18 July 2024, establishing the legal framework for Digital Product Passports across a wide range of product groups.
Most sectors are still waiting for product-specific delegated acts. Batteries are already further ahead.
The EU Battery Regulation introduced the first mandatory Digital Product Passport, making the Battery Passport the first concrete implementation case in the European Union.
Unlike most Digital Product Passports, the Battery Passport is no longer a regulatory proposal but an operational framework with defined implementation requirements.
For organisations preparing for future DPP requirements, the Battery Passport provides one of the clearest examples available today of how Digital Product Passports may work in practice.
The Battery Passport originates from the Battery Regulation (EU) 2023/1542, which establishes sustainability, performance, labelling, due diligence, and information requirements for batteries placed on the European market.
As part of this framework, certain battery categories must be linked to a digital record containing product-specific information throughout their lifecycle.
Unlike many future ESPR Digital Product Passports, the Battery Passport is already defined through the Battery Regulation.
Its scope, implementation timeline, and core information requirements have already been established, making it the first operational example of a Digital Product Passport in the European Union.
The Battery Passport becomes mandatory from 18 February 2027.
The requirement applies to:
These products must be linked to a digital record that can be accessed through a data carrier and made available according to the requirements of the Battery Regulation.
The Battery Passport contains structured product information defined by Annex XIII of the Battery Regulation. These requirements cover technical, environmental and lifecycle information, with different data requirements applying to different battery categories.
Depending on the battery category and stakeholder access rights, information may include:
However, not every data requirement becomes applicable when Battery Passports become mandatory in February 2027. During its recent webinar, The European Commission has clarified that several information categories included in Annex XIII - such as carbon footprint, recycled content and due diligence information - will only become applicable once the corresponding regulatory requirements enter into force for the relevant battery category.
It was also highlighted that, for some requirements, the passport will contain the resulting information rather than the underlying datasets. For example, once applicable, it may display the carbon footprint declaration, carbon footprint class, recycled content figures and due diligence information, rather than the underlying documentation or datasets used to substantiate them.
The European Commission also announced that, by the end of the month, detailed guidance for each battery category will be published, explaining the information expected for every Battery Passport data point defined in the Regulation.
The Battery Passport shows how a Digital Product Passport can operate as a connected digital system, introducing an architecture that closely resembles the Digital Product Passport system currently being developed under ESPR.
At a high level:
While technical activities such as passport creation or registration may be delegated to a Digital Product Passport service provider, responsibility for the information contained in the Battery Passport remains with the responsible economic operator.
One important characteristic is that the Battery Passport is linked to an individual battery. This makes it an item-level implementation, unlike other product groups where the future granularity level may still be defined through delegated acts.
The Battery Passport does not define how every future Digital Product Passport will work.
Each ESPR product group will have its own requirements. However, the Battery Passport already shows several core building blocks that are likely to shape future DPP implementation.
The Battery Passport confirms the central role of unique identifiers.
A Digital Product Passport is not simply a webpage or a document. It is connected to a specific product through an identifier and a data carrier.
Not all passport information is available to every user.
The Battery Passport already introduces the need to manage access depending on the stakeholder accessing the information. This is relevant for future DPPs, where consumer information, authority access, and commercially sensitive data may need to be handled differently.
Digital Product Passports rely on supporting infrastructure.
Identifiers, registries, web portals, interoperability standards, and access mechanisms are part of the system. The passport is not an isolated digital record.
The Battery Passport also shows that registration becomes part of the compliance process itself. Before a battery is placed on the EU market, its passport must already be registered and discoverable through the supporting digital infrastructure.
The supporting infrastructure also illustrates that Digital Product Passports are not stored in a single central database. Instead, the Registry enables passport registration and discovery, while passport information remains with the responsible economic operator or its chosen DPP service provider.
Read our guide to the EU Digital Product Passport Registry to understand how the Registry, registration process and supporting infrastructure work in practice.
Some battery information may need to be updated over time.
This shows how DPP implementation can involve ongoing data management, not only one-time publication at the moment a product is placed on the market.
The European Commission also clarified that dynamic information does not necessarily require continuous updates. Information should be updated whenever the battery changes status, for example following repurposing, remanufacturing or when it becomes waste, and more frequently only where proportionate to the intended use of the information.
The battery’s lifecycle also affects the passport itself. Where a battery is repurposed or remanufactured, a new Battery Passport must be created by the responsible economic operator. By contrast, repairing a battery does not automatically require a new passport. Once a battery reaches the recycling stage, the Battery Passport is no longer maintained.
The Battery Passport also demonstrates that Digital Product Passports become part of the regulatory infrastructure surrounding products. Registration, discovery and common semantic structures are no longer theoretical concepts but operational requirements supporting product compliance across the European market.
This common technical framework also enables product information to be exchanged and interpreted consistently across different systems and stakeholders.
The Battery Passport demonstrates that many of the technical and organisational elements required for future Digital Product Passports are already moving into implementation.
Product-level identifiers, data carriers, access-right management, registries, and interoperability frameworks are already part of the first mandatory Digital Product Passport introduced by the European Union.
For organisations preparing for future DPP requirements, the Battery Passport provides the clearest example currently available of how Digital Product Passports may operate in practice.
Renoon continuously monitors Digital Product Passport developments across sectors and helps organisations understand how emerging DPP requirements translate into product data, system architecture, and implementation decisions.
Get in touch to discuss how future Digital Product Passport requirements may apply to your products and operations.
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