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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.
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 is designed to provide structured information about a battery throughout its lifecycle.
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:
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.
The Battery Passport also shows that Digital Product Passports depend 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.
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 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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