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This article reflects the current status and incorporates the European Commission’s latest Battery Passport FAQs and implementation guidance. Last updated: October 2026.
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.
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 relevant trigger is when a battery is placed on the EU market or put into service, not when it was manufactured. This follows the product-law concept of placing on the market explained in the European Commission’s Blue Guide on the implementation of EU product rules. A battery manufactured before 18 February 2027 may therefore still require a Battery Passport if it is first placed on the EU market or put into service on or after that date.
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.
In August 2026, the European Commission published version 2.0 of its guidance on Battery Passport data points by category. The document maps 71 data points for electric vehicles, light means of transport and industrial batteries above 2 kWh, clarifying which are mandatory, optional, applicable only in certain cases, or not required to be completed or displayed as of February 2027.
The latest revision also clarifies that responsible-sourcing information becomes applicable from August 2027, while recycled-content data points apply in line with Article 8 of the Battery Regulation and the relevant delegated act. It also confirms that two duplicated data points do not need to be completed separately. The guidance does not create additional legal requirements and may be updated further.
Depending on the battery category and stakeholder access rights, information may include:
The Battery Passport is not only a consumer-facing tool. It supports information access for different stakeholders, including economic operators, authorities, and end-of-life operators.
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:
The responsible economic operator may give another operator written authorisation to create, host or update the Battery Passport on its behalf. There is no legal requirement under the Batteries Regulation to appoint a DPP service provider or a separate third party to host a backup copy. The Batteries Regulation does not define DPP service providers as a distinct regulated actor, so the use of a commercial provider is optional and governed by the agreement between the parties.
Registration is different from creation, hosting and updating. The Battery Passport must be registered in the EU DPP Registry by the economic operator that places the battery on the EU market or puts it into service. This registration step cannot be transferred to a provider, and written authorisation does not transfer the operator’s legal responsibility for compliance or for the passport data.
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. The Registry records registration information and metadata, while the full Battery Passport is hosted by the responsible economic operator or by another operator acting under written authorisation. The Registry itself does not provide access to the full passport.
Battery Passports also differ from DPPs governed by the ESPR in one important customs detail: although the Battery Passport must be registered in the EU DPP Registry, its unique registration identifier is not required in the electronic customs declaration.
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 building blocks currently being discussed for future Digital Product Passports are already moving into implementation.
Product-level identifiers, data carriers, access-right management, registries, and interoperability frameworks are no longer theoretical concepts. They 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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