A container of e-bike batteries, produced in December 2026, leaves the factory for the EU in March 2027. Does it need a product passport? Yes. What counts is not when a battery was built but when it enters the EU. So the question for your planning is not “when is the deadline?” but “what will still be in my warehouse in February 2027?”
From 18 February 2027 manufacturers may no longer place batteries above 2 kWh on the EU internal market without a Digital Product Passport. That has been in Regulation (EU) 2023/1542 since August 2023 and has not been softened since. Anyone still waiting in 2026 is waiting for details, not for the principle. This article places the deadline in the ESPR timeline, shows which fields are settled and which still float, and what you should do in 2026.
The ESPR timeline at a glance
The battery passport gets its deadline from the Batteries Regulation - it is the forerunner, not a special case. The Ecodesign for Sustainable Products Regulation (EU) 2024/1781 (ESPR) rolls the product passport out to further product groups via delegated acts.
Adoption of a delegated act does not yet make the passport mandatory, the obligations apply at the earliest 18 months after it enters into force.
The roadmap as the Commission keeps it on its central DPP page:
- 20 July 2026 - the DPP Registry starts operating. Every product passport must be registered there (our analysis of the registry regulation).
- Q4 2026 - delegated act for iron and steel. Mandatory from around 2028.
- 18 February 2027 - the battery passport becomes mandatory. The only fixed product deadline so far, straight from the Batteries Regulation.
- Q2 2027 (indicative) - delegated act for construction products under the Construction Products Regulation (CPR). The CPR fixes no date of its own; the duty follows the act.
- Q3-Q4 2027 - delegated acts for textiles, aluminium and tyres. Mandatory from around 2029.
- 2028 - delegated act for furniture. Mandatory from around 2030.
- 2029 - delegated acts for mattresses and recycled content. Mandatory from around 2031.
Not being affected in 2027 is not a free pass, it is a head start. What your industry requires in detail, and when, is in our industries reference, one page per product group. The rest of this article focuses on the group with the fixed deadline: batteries.
What is due in February 2027
The Battery Passport is the first product-specific implementation of an EU-wide DPP. Affected are industrial batteries, vehicle batteries and batteries for e-bikes, e-scooters and e-mopeds (LMT batteries in the regulation, light means of transport), each from 2 kWh. The deadline is 18 February 2027. It applies to placing on the market, that is the first sale or delivery into the EU, not just the sale to end consumers.
Access via a QR code or a chip on the battery. Technical requirements from Article 77: printed or etched, durable, readable over the expected product lifetime. Redirects via a single provider’s service are not a solution - if the provider fails, the DPP fails.
Which fields are settled, which are still in flux
The framework structure is laid down in Annex XIII of the regulation. As of summer 2026 the following is settled:
- General product data: manufacturer, brand name, battery type, chemical system, rated capacity, rated voltage, weight, dimensions
- Origin: production date, place of production, batch or serial number
- Material composition with a focus on cobalt, lead, lithium and nickel, including separately reported recycled-content shares
- Performance and durability data: charge cycles, capacity degradation, internal resistance, state of health
- Recycling and disassembly instructions for certified recyclers
The implementing act under Article 77 paragraph 10 specifies the data model and technical architecture. Original schedule: 18 August 2025. Current status: draft in consultation, final version not yet published. Manufacturers waiting for the “final format” are therefore still waiting - while the 2027 deadline is not being postponed.
Since late July 2026 there is also an official reading aid: the Commission guidance “Digital Batteries Passport - data points by category” (version 1.0, 28 July 2026) classifies all 71 data points of the battery passport: mandatory, optional, only if applicable - or not to be displayed at the start at all. The guidance is explicitly non-binding, but it is the clearest statement yet of which fields actually have to be filled in February 2027.
Explicitly not to be displayed at the start: the carbon footprint declaration including its label, and the responsible-sourcing information - their format will only be set by the upcoming implementing act. What remains open beyond that: thresholds for conflict minerals and the access procedures for market-surveillance authorities. All things that will still be made concrete before application - but more in details, not in principle.
Supply-chain due diligence: the hidden time pressure
The due-diligence obligations from Articles 48 to 53 (conflict minerals, human rights, the environment along the supply chain) were originally to be applied from 18 August 2025. Regulation (EU) 2025/1561 has postponed this application to 18 August 2027. Good news for overloaded compliance teams. Bad news for everyone who assumed the topic was off the table: it is coming in full breadth, just later.
Inside the passport itself the due-diligence entries are deferred for now: the responsible-sourcing information foreseen in Annex XIII is, per the Commission guidance, not to be displayed as of February 2027. The duties themselves still have to be demonstrable to certification bodies and on request by market surveillance.
Four access levels - who sees what
Annex XIII of the Batteries Regulation tiers the passport data into four data categories:
- The public - model-related basic data: composition, capacity, CO2 footprint, usage, safety and recycling instructions.
- Persons with a legitimate interest - deeper model data such as detailed material composition, spare-part numbers as well as disassembly and safety information (for repair, refurbishment, recycling, for example).
- Notified bodies, market-surveillance authorities and the Commission - test reports that prove conformity with the regulation.
- Individual-battery data for persons with a legitimate interest - values for the specific battery: performance and durability parameters, state of health, status (original, reused, repurposed, remanufactured, waste) and usage data.
In practice this means: the same QR code delivers different views depending on who calls it up. This is usually done with access keys for the systems that call it up, not with login pages for end users.
What you should concretely do in 2026
There are three sensible steps. All of them are feasible independently of the final implementing act.
First: data audit. Which of the fields from Annex XIII do you already have - just spread across ERP, PLM, the Excel files of your engineers and the PDF data sheets of suppliers? The answer is almost never “none”. It is “70 per cent there, only in ten different systems”.
Second: secure upstream data flows contractually. The recycled-content shares for cobalt and nickel are known only to your cell suppliers. You do not get this data by asking nicely, but through contracts that oblige suppliers to transmit defined fields. A deadline of 2027 seems long - for negotiating purchasing framework agreements with Asian cell manufacturers it is tight.
Third: pilot with 5 to 10 models. Build real DPPs for a few actual battery models. Strategy PDFs and workshops only reveal gaps in the data model once you try to implement them.
Consequence of a missing DPP
The Batteries Regulation prescribes penalties, framed as “effective, proportionate and dissuasive”. The concrete amount is set by the member states. A batch that is inspected on 19 February 2027 and has no DPP stays put in the customs-free warehouse. For EV batteries those are six-figure amounts per container.
More relevant than the individual fine is the placing-on-the-market ban.
Everything the regulation asks of battery manufacturers, with the timeline, the roles, the required data, the official documents and a checklist per battery type, is in our reference on the Digital Product Passport for batteries.
Questions on this article
Does the deadline apply to batteries we produced beforehand?
What counts is placing on the market, not the production date. A battery placed on the EU market from 18 February 2027 needs the passport, one placed before it does not (Art. 77 of Regulation (EU) 2023/1542). Stock built in 2026 and shipped in 2027 therefore carries the duty. Work out now which batches will still be in the warehouse in February 2027 - that belongs to the deadline, not to the clean-up after it.
Does the passport duty reach importers too?
Yes. The duty attaches to placing on the market, so whoever brings a battery into the EU from a third country carries it and has to make sure the passport exists and is correct (Art. 77(4)). In practice either your manufacturer supplies the passport or you create it - and to create it you need the manufacturer’s data. That belongs in the purchasing contract, not at customs. All the roles and their duties are in the reference on the Digital Product Passport for batteries.
Which batteries need no passport?
Portable batteries and SLI starter batteries need none, and for industrial batteries the passport duty starts above 2 kWh. That does not make these groups duty-free - from 18 February 2027 they carry a QR code as well, leading to the labelling, the declaration of conformity and the disposal information (Art. 13(6)), and labelling and removability duties apply to them too. The passport threshold is not the compliance threshold.
Can we wait for the implementing act?
The act specifies the data model and the technical architecture (Art. 77(10)); it does not move 18 February 2027. What it still moves is format, not substance - Annex XIII names the fields, and the Commission guidance of 28 July 2026 classifies all 71 data points as mandatory, optional, only where applicable, or not to be displayed at the start. What genuinely takes months does not depend on the act anyway - recycled shares from your cell suppliers, data clauses in purchasing contracts, a clean master-data hierarchy. Start with the data.
Do we have to register the passport in the EU register, and can a provider do it for us?
Yes, and you do it yourself. The central register has been operating since 20 July 2026, with Implementing Regulation (EU) 2026/1778 setting out how it works, and only the economic operator placing the battery on the market may register it (Art. 77(10) of the Batteries Regulation). A service provider cannot do it for you at present; the Commission has said it is examining whether that changes. Transpareo prepares what the entry asks for - product identifier, operator identifier, passport address and fingerprint - so the entry is short once the register’s interface is settled. Background in our analysis of the register regulation.
Does the carbon footprint have to be in the passport in February 2027?
Not at the start. Per the Commission guidance, the carbon-footprint declaration including its label and the responsible-sourcing information are not to be displayed at the deadline, because the acts setting their format are missing. The duties arrive later and in stages, the due-diligence obligations of Articles 48 to 53 from 18 August 2027 under Regulation (EU) 2025/1561. Leave the fields in your data model empty rather than out of it - then a later act is an addition and not a migration.
What happens to a batch without a passport?
The member states set the level of the penalty, which the regulation requires to be effective, proportionate and dissuasive. More expensive than the fine is the placing-on-the-market ban - a batch inspected on 19 February 2027 without a passport stays put in the customs warehouse, which for EV batteries is six-figure amounts per container. That risk sits on the shipment, not on the compliance budget.
