Which products need a passport and when
The EU Battery Regulation 2023/1542 mandates a battery passport for LMT batteries, electric-vehicle batteries and industrial batteries with a capacity greater than 2 kWh from 18 February 2027 — the only product category with a deadline written directly into a regulation.
The ESPR Regulation 2024/1781 provides the framework for further product groups. Article 9 makes the passport mandatory only where a product-group delegated act requires one. That act defines data fields, access rights, update rights, availability period and whether the passport applies at model, batch or item level.
What flows into the signed credential
ESPR Article 9 requires passport data to be accurate, complete and up to date. Article 10 connects the data carrier on the product, packaging or accompanying documentation to a persistent unique product identifier. The exact placement, identifier level and availability period come from the relevant delegated act; the Battery Passport also carries the Battery Regulation's 10-year availability requirement.
- Persistent identifiers: Product identifier under ESPR Article 10 plus economic-operator and facility identifiers from the applicable data model — GTIN, GLN or other ISO/IEC 15459-compatible identifiers as the stable anchor.
- Regulatory mandatory fields: Battery Regulation: carbon footprint, recycled content, performance parameters, due-diligence evidence. ESPR: product-group fields from the applicable delegated act.
- Conformity evidence: Test reports, certificates and supplier documents SHA-256 anchored — hash referenced in the credential, tampering detectable.
- Cryptographic signature: W3C Verifiable Credential 2.0 with an EdDSA Data Integrity proof — tamper-evident and independently verifiable against public verification material.
Issuance pipeline: from data entry to verifiable QR code
Nulara covers the full workflow: capture product data and validate against the applicable schema, surface gaps before the passport is published, sign the credential after approval and publish it via a stable URL.
The issued passport is a signed JSON-LD credential. The data carrier on the product, packaging or accompanying documentation routes users to a readable viewer and authorized inspection systems to the machine-readable credential. URLs need to remain stable for the period required by the applicable legal act.
Primary sources and further reading
These sources define the legal requirements for the Digital Product Passport and Battery Passport.
Read next in Nulara
- Digital Product Passport - Regulatory and technical framework for the DPP under ESPR 2024/1781.
- Battery Passport - 18 February 2027 deadline, data categories and role-based access for battery manufacturers.
- ESPR - Framework regulation, delegated acts and product-group timeline.
Primary sources
- EUR-Lex: Regulation (EU) 2024/1781, Articles 9-11 — Digital Product Passport - Requirements for data content, persistent identifiers, data carriers, access rights, updates and availability.
- EUR-Lex: Regulation (EU) 2023/1542, Article 77 — Battery Passport - Legal basis for the battery passport from 18 February 2027 with mandatory QR code and role-based data access.
- European Commission: Ecodesign for Sustainable Products Regulation - Official context for ESPR objectives, the DPP concept and the delegated-act process.
- W3C: Verifiable Credentials Data Model 2.0 - Technical standard for signed, machine-readable credentials.
- W3C: Data Integrity EdDSA Cryptosuites v1.0 - Cryptographic EdDSA proofs for verifiable JSON-LD credentials.
Frequently asked questions
- Which products require a mandatory EU product passport from 2027?
- LMT batteries, electric-vehicle batteries and industrial batteries with a capacity greater than 2 kWh are legally required from 18 February 2027 (Battery Regulation 2023/1542, Article 77). For ESPR product groups such as textiles, steel and electronics, delegated acts set the deadlines and mandatory fields.
- What does the 10-year data availability obligation mean in practice?
- For ESPR product groups, the relevant delegated act defines how long product-passport data must remain available. For the Battery Passport, the Battery Regulation requires at least 10 years of availability after placing on the market. Nulara therefore separates availability periods, key rotation and old verification material so published credentials remain verifiable.
- Can Nulara issue both Battery Passports and ESPR product passports?
- Yes. Both regimes overlap technically around product identifiers, machine-readable data carriers, data publication, access levels and evidence. The mandatory fields differ, so Nulara keeps Battery Passport schemas and ESPR product-group schemas separate.
