From 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.
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. The key to reading the years: 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 - delegated act for construction products under the Construction Products Regulation (CPR).
- 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. 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, EV batteries and LMT batteries (Light Means of Transport - e-bikes, e-scooters, e-mopeds), each from 2 kWh. The deadline is 18 February 2027. It applies to placing on the market, not just sale to end consumers.
Access via a QR code or other data-carrier on the battery. Technical requirements from Article 77: printed or etched, durable, readable over the expected product lifetime. Redirects via a proprietary provider 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.
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 implemented via API keys or signed tokens - not via 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. More relevant than the individual fine is the placing-on-the-market ban: 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.