Batteries & Accumulators.

Battery passport mandatory from 18 February 2027

The EU Battery Regulation (EU) 2023/1542 has been in force since 17 August 2023 and introduces the battery passport as a mandatory Digital Product Passport. From 18 February 2027, the battery passport is mandatory for all EV batteries, LMT batteries (light means of transport, e.g. e-bikes) and industrial batteries above 2 kWh. Portable consumer batteries are not in the Article 77 battery passport scope; from 18 February 2027 they must instead provide QR-code access to the product information applicable to their category. The carbon footprint declaration for EV batteries is the first sustainability evidence step under Article 7; it applies from 18 February 2025 or 12 months after the relevant delegated and implementing acts enter into force, whichever is later.

Each covered battery receives a unique identifier, through which a QR code provides access to the digital passport. The passport is divided into a publicly accessible part and a restricted part for authorised market participants (authorities, recyclers, workshops). All DPP deadlines at a glance →

Core data in the battery passport

• Carbon footprint — Specific CO₂ footprint in kg CO₂e/kWh, broken down by raw material extraction, cell production and recycling; performance classes and maximum thresholds follow the relevant implementing and delegated acts.
• State of Health (SoH) — Use-dependent data on state of health and expected lifetime, where applicable to the battery category — important for second-life assessment and legitimate-interest access.
• Recycled content — Documentation of recycled content for materials including cobalt, lithium, nickel and lead: for EV, SLI and industrial batteries >2 kWh from 18 August 2028 or 24 months after the delegated act, for LMT batteries from 18 August 2033; minimum shares follow from 18 August 2031 or later.
• Due diligence report — Supply chain risk management for battery raw materials such as cobalt, lithium, nickel and natural graphite where the Battery Regulation's economic thresholds apply.
• Technical specification — Capacity (kWh), nominal voltage, number of charge cycles, temperature range, power output.
• Identification — Unique battery ID, manufacturer, manufacturing date, country of origin, model designation.

EU DPP registry and access rights

Article 77 links the battery passport to the upload of the unique identifier into the EU DPP registry under the ESPR. The passport itself remains a decentralised data system: data is stored by the responsible economic operator or authorised service providers and must be open, interoperable, machine-readable, structured and searchable. Consumers see the public layer; notified bodies, market surveillance, the Commission and legitimate-interest actors such as recyclers, repairers and second-life operators receive only their respective access layers.

For automotive manufacturers and battery cell producers, BMS and production data should be connected so that SoH, lifetime, model and evidence data remain up to date and exportable. Direct API integration with a DPP platform is a natural implementation pattern, but it is not the literal wording of the Regulation.

Associations and standards

• European Commission Batteries — Official overview of the Battery Regulation, circular economy objectives and downstream legal acts
• RECHARGE — European Association for Advanced Rechargeable Batteries — battery passport implementation guidance
• EUR-Lex Battery Regulation — Primary source for Regulation (EU) 2023/1542 including battery passport, QR code and recycled-content rules
• GS1 Digital Link — Open identifier and 2D-code standard for product-related online information
• JRC battery carbon footprint — Methodology and consultation status for carbon-footprint rules for EV, industrial and LMT batteries
• ZVEI — Electrical industry — positioning on carbon footprint methodology and DPP interoperability
• VDA — Battery Passport Ready Initiative for the German automotive industry
• Global Battery Alliance — Battery Passport Ecosystem — open standard for battery lifecycle data

German production hubs

Battery and battery-material value creation in Germany is distributed across several production, research and supplier regions. For battery passport programmes, the important overlap is where data on battery model, individual battery, cell chemistry, production and supply chain evidence is created:

• Salzgitter — Battery-cell and industrialisation activities around PowerCo/VW; relevant for model, production and supplier evidence
• Erfurt / Thuringia — Battery ecosystem with manufacturing, research and supplier activity; concrete DPP duties depend on product role and battery class
• Kaiserslautern — Research, testing and industrial battery technology context; relevant for performance, lifetime and SoH evidence
• Schwarzheide / Heidelberg — Battery materials and supplier evidence; material data feeds the battery passport, while the passport duty applies to covered batteries placed on the market

Frequently asked questions

Which batteries require a battery passport from 2027?

From 18 February 2027, EV batteries, LMT batteries and industrial batteries with a capacity above 2 kWh require a battery passport. Portable consumer batteries such as smartphone or laptop batteries are not part of the Article 77 battery passport scope.

What is the carbon footprint obligation for batteries?

For EV batteries, the carbon footprint declaration applies from 18 February 2025 or later if the relevant delegated or implementing acts enter into force later. Performance classes follow for EV batteries from 18 August 2026; binding maximum thresholds apply no earlier than 18 February 2028.

How does the BMS relate to DPP data obligations?

The battery management system (BMS) must capture and make SoH and lifetime data accessible where the battery category is covered. The Regulation requires open, interoperable, machine-readable and structured data; direct API integration between a BMS and a DPP platform is a common implementation pattern, not an explicit legal requirement.

Do the requirements also apply to imported batteries?

Yes, for the covered battery classes the requirements apply regardless of country of manufacture. Importers and authorised representatives must ensure that EV, LMT and industrial batteries above 2 kWh meet battery passport requirements when placed on the EU market.