Digital Product Passport for batteries
The Digital Product Passport for batteries becomes mandatory on 18 February 2027. It covers EV and LMT batteries and industrial batteries above 2 kWh.
Where Transpareo supports you
Whoever places a battery on the market answers for its passport. Transpareo is the DPP platform on which you create it, keep it up to date and publish it. The cards point to the sections that go deeper into each topic. Each battery category has a checklist of its own: for EV batteries, LMT batteries, industrial batteries, stationary storage and portable and starter batteries.
Every battery needs a unique identifier and a QR code that leads to its passport. Transpareo creates both, with or without a GTIN.
An EV battery reports different data than an e-bike battery. The Transpareo battery template follows the Commission guidance and asks per category for what is mandatory there.
The state of health and status of a battery change over the years. Your system reports new values through the API, and Transpareo signs every new state.
Recycled content and test results often sit with your suppliers. With Transpareo Upstream they enter their values themselves, and you review every one.
Some information is public, some only for recyclers, workshops or authorities. In Transpareo you set for every field who may see it.
Neither goes into the passport at the start. The fields are already in the template, and you fill them once the rules are settled.
Every publication carries a signature that any reader checks with the Transpareo Time Machine. You export your passports and product data at any time in open formats.
Today your company makes the entry in the EU registry itself. Transpareo checks every passport before publication and keeps the details for the entry ready.
A battery passport lasts until the battery is recycled, often more than ten years. It keeps its permanent address, and once registered, Transpareo Vault archives it for ten years.
What is coming for battery manufacturers
Batteries are the first product group with a binding Digital Product Passport. From February 2027 every EV, LMT and large industrial battery in the EU needs one. Transpareo is the DPP platform on which battery manufacturers and importers create it today.
Where the law stands
The EU Batteries Regulation replaced the Batteries Directive of 2006. Most of its provisions have applied since 18 February 2024.
Its battery passport applies from 18 February 2027 to three categories. These are batteries for electric vehicles (EV) and for light means of transport (LMT) such as e-bikes and e-scooters. Industrial batteries above 2 kWh complete the list.
The passport is an electronic record. It describes what the battery is and what it is made of. It says how long the battery lasts and how it is safely dismantled and recycled at the end. It is reached through the QR code on the battery.
Four questions, one address: what the battery is, what it is made of, how long it lasts and how it is recycled.
What already applies today
Since 18 August 2024, EV and LMT batteries and stationary storage have kept data on their state of health in the battery management system. Since 18 August 2025 every battery has carried the separate collection symbol. By that day the member states also had to lay down their penalties.
What is still moving
Several dates hang on acts the Commission has not adopted yet. The label with the general information applies only 18 months after the act on its format. That act is still missing. So 18 August 2026 no longer stands as the date for the label.
The carbon footprint and the documentation of recycled content are waiting for their acts too. Who counts as an authorised reader is still open as well. These deadlines start to run only once the acts are in force.
In December 2025 the Commission proposed to simplify the Batteries Regulation on several points. The proposal covers the labelling of substances of concern and the removability of LMT batteries, among other things. It leaves the battery passport and its deadline as they are. The Council fixed its position in June 2026, and the procedure is still running.
The deadline for the battery passport stays 18 February 2027.
What this page covers
This page is your reference work on the digital product passport for batteries. It shows every deadline, the roles with their duties and the required data. Then come the official sources, five checklists and a sample spreadsheet to compare with your data. At the end are the questions battery manufacturers ask us most often. Where a term is underlined with dots, a click opens the wording of the provision.
From the rules to the passport
The picture shows the way from the regulation to the battery passport. The rules are grey, the data you already hold for them teal. The Transpareo passport with its reading tiers is blue.
The three biggest hurdles in practice
- Data from the supply chain: recycled shares, test results and raw-material origin sit with the cell manufacturers, often in several countries. They arrive through data clauses in purchasing contracts, and those take months. With a supplier request in Transpareo the cell maker enters its values itself, and you review every one.
- One list per category: which data points are mandatory depends on the battery category. An EV battery reports different values than an e-bike battery. An industrial battery carries much of it only “where applicable”. The Transpareo battery template knows the list of every category.
- Values that change: state of health, charge cycles and status change over the battery’s life. They belong to the individual battery and are for authorised readers only. Your system reports them through the API, and Transpareo signs every new state.
More on this: Battery passport: what is mandatory from February 2027 and ESPR timeline 2027: what battery manufacturers need to know now.
Regulatory timeline for batteries
The key dates of the rules that apply to batteries or are still to come, in order. Dates that hang on acts not yet adopted are marked as such.
- 17 August 2023Batteries Regulation in force
Regulation (EU) 2023/1542 replaces the Batteries Directive of 2006. Most of its provisions have applied since 18 February 2024.
- 18 August 2024State-of-health data in the battery management system
Stationary storage, LMT and EV batteries keep up-to-date data on state of health and expected lifetime in their battery management system. This data later feeds the changing values of the passport.
- 20 July 2026EU DPP registry operational
The central registry for product passports goes live. Implementing Regulation (EU) 2026/1778 governs it, and economic operators get a test environment. Whoever places a battery on the market uploads its identifier there.
- 18 February 2027Battery passport becomes mandatory
Every LMT and EV battery and every industrial battery above 2 kWh placed on the market needs its passport. From this day every battery carries a QR code. For these three categories it leads to the passport.
- 18 August 2027Supply-chain due diligence
The duties on raw-material origin, human rights and the environment apply. Regulation (EU) 2025/1561 postponed them by two years. They reach companies with a net turnover of EUR 40 million or more.
- 2028 at the earliestLabel with general information and capacity
Every battery carries a label with general information. LMT, starter and rechargeable portable batteries also state their capacity. The duty applies 18 months after the implementing act on the format, which the Commission has not adopted yet.
- Late 2028 at the earliestDocument recycled content
EV, starter and industrial batteries above 2 kWh state the recovered shares of cobalt, lithium, nickel and lead. The duty applies 24 months after the delegated act on the method at the earliest. That act was due by 18 August 2026 and has not been adopted.
- 18 August 2031Minimum recycled shares
Active materials contain at least 16 % cobalt, 85 % lead, 6 % lithium and 6 % nickel from recovery. From 18 August 2036 the shares rise to 26 %, 85 %, 12 % and 15 %.
- After the actCarbon footprint in three stages
First comes the declaration, then the performance class, finally a maximum threshold. Each stage applies per battery category 12 to 18 months after its act. The Commission has not adopted these acts yet.
Who is affected?
Duties for batteries: what falls on each economic operator on the way to the market.
Creates the passport before the battery is placed on the market and assigns the unique identifier. Over the whole battery life it keeps the information accurate, complete and up to date. Under a written authorisation a supplier or a service provider may keep the passport on its behalf; the responsibility stays with the manufacturer. In Transpareo you keep a product and all its passports in one place for this.
Whoever brings a battery into the EU from a third country places it on the market and carries the passport duty. If the manufacturer supplies no passport, the importer creates it. For that it needs the data of the manufacturer and its cell suppliers. With a supplier request in Transpareo they enter their values themselves.
Checks before selling that the battery carries the CE marking, the label and the QR code. Maintains no passport data of its own and keeps the passport reachable for its customers. For distance sales to consumers from outside the EU, the new Union Customs Code applies from 21 September 2027. The importer is then the seller or the online marketplace, depending on the arrangements. That importer makes sure the battery meets the product rules.
Whoever remanufactures or repurposes a battery and places it on the market again takes over the passport duty. The battery gets a new passport, linked to the old one.
What goes in the DPP for batteries?
Data fields for batteries: the key ones the relevant EU regulation requires.
Capacity, voltage, power, expected charge cycles and internal resistance. Some values belong to the individual battery and change over time, such as the state of health. Transpareo signs every new state your system reports.
Chemistry, critical raw materials and hazardous substances are public in the passport. Only authorised readers see the detailed composition of cathode, anode and electrolyte. The recycled shares of cobalt, lithium, nickel and lead sit beside them as fields of their own. You fill them once their act applies.
Raw-material origin, human rights and the environment along the supply chain. The duties apply from 18 August 2027. The passport does not display this information at the start.
Safety information, disassembly steps, spare parts and collection details per region. Recycling and repair businesses need this information to work safely. In Transpareo they see only the fields you release to them.
Downloads
The checklists for batteries as PDFs to print and tick off, and the sample spreadsheet of the Transpareo import to compare with your own product data - all without an account.
The checklist for EV batteries follows the regulation text: every data point is binding law.
The checklist for LMT batteries follows the regulation text: every data point is binding law.
The checklist for industrial batteries above 2 kWh follows the regulation text: every data point is binding law.
The checklist for stationary storage systems follows the regulation text: every data point is binding law.
The checklist for portable and starter batteries follows the regulation text: every data point is binding law.
Sample row for batteries, filled in and with every column the import expects.
111 columns, sample values included
Transpareo for batteries
Transpareo provides the DPP software for battery manufacturers and importers. The battery template maps the data points of the Batteries Regulation, per category as the Commission guidance classifies them. Each field has its own visibility, from public to authorities only.
Data comes in through the web interface, by Excel import or through the API. Your system reports values such as the state of health through the API as they change. Cell makers enter their information themselves through a supplier request. The sample spreadsheet above shows the columns of a battery passport.
Transpareo translates safety and disposal information into 40 languages, and you review the translation. Before publication Transpareo checks every passport against the rules for batteries. Every publication is signed, and any reader checks it with the Transpareo Time Machine in their own browser. You export your data at any time as JSON-LD, CSV, Excel spreadsheet or SQL.
Frequently asked questions about the DPP for batteries
Does the passport duty apply to importers too?
Yes. The duty falls on whoever places the battery on the market. Whoever brings a battery into the EU from a third country does exactly that. They have to make sure the information in the passport is correct. Either your manufacturer supplies the passport, or you create it yourself. For that you need the manufacturer’s data. With a written authorisation your manufacturer, a supplier or a service provider may also keep the passport for you; the responsibility stays with you. Settle it in the contract before the first shipment of 2027 sits at customs. With a supplier request in Transpareo, the manufacturer enters its data straight into your passport.
Which batteries need a passport, and which do not?
LMT batteries need the passport, that is batteries for e-bikes, e-scooters and e-mopeds. So do EV batteries and industrial batteries above 2 kWh. Portable batteries and starter batteries need none. From 18 February 2027, though, they too carry a QR code. It leads to the labelling, the declaration of conformity and the disposal information. For starter batteries it also shows the recycled content. Portable batteries also carry removability duties. Neither group declares a carbon footprint. By the end of 2030 the Commission assesses whether that changes for portable batteries.
What happens if I only start in 2027?
There is no transition period. A battery placed on the market from 18 February 2027 needs the passport, one placed before does not. Whoever starts in January 2027 has time for the technology and little time for the data. Recycled shares and test results sit with the cell manufacturers. Data clauses in purchasing contracts take months. So start with the data. Once it is at hand, you publish the passport in Transpareo in a few minutes.
Do I need a GTIN?
No. The regulation requires a unique identifier under the ISO/IEC 15459 standards. Which number you use for it is up to you. If you have a GTIN, Transpareo turns it into a GS1 Digital Link. The systems of your trade partners resolve it too. Without a GTIN, Transpareo issues a unique identifier of its own. Either way the QR code leads to the passport.
Does the carbon footprint already have to be in the passport?
Not at the deadline. The Commission guidance of 15 August 2026 classifies the declaration and the label as not to be displayed at the start. The delegated act with the calculation method is still missing. The duty arrives in three stages. First comes the declaration per model and plant, then the performance class, finally a maximum threshold. Each stage applies 12 to 18 months after its act. The fields for it are already in the Transpareo battery template. You fill them once the method is set and publish a new version. More on the methods in the post Carbon footprint in the DPP.
Who sees which data in the passport?
The regulation grades access to the passport. Model data such as composition, capacity, safety and recycling information is public. Repair and recycling businesses with a legitimate interest see disassembly, detailed composition and spare parts. Authorities and notified bodies receive the test reports. Data on the individual battery, such as state of health and status, is for authorised readers only. Who exactly counts as authorised is for an implementing act to set. It was due by 18 August 2026 and has not been adopted. In Transpareo you set the visibility of every field. The public tier appears without any login.
How long does the passport have to stay available?
Until the battery has been recycled. Only then does the battery passport cease to exist. For an EV battery that is easily fifteen years, second life included. The duty therefore outlasts many a contract with a service provider. So settle before signing what happens to your passports after a cancellation. With Transpareo, published passports stay reachable at a permanent address. Our provider checklist names more questions to put to any provider.
What changes for a remanufactured or repurposed battery?
You place the battery on the market again and so take over the passport duty. The battery gets a new passport, linked to the old one. It also gets a new label with the changed status. The carbon-footprint declaration and the recycled-content duties do not apply to such batteries. When a new passport in Transpareo replaces one of your own, the two point to each other.
Do I have to register the passport in the EU registry?
Yes. Whoever places the battery on the market uploads its identifier to the EU registry. The registry has run since 20 July 2026. It holds the identifiers, and the data stays in the passport. Before the first entry your company proves its identity, for example with a qualified electronic seal. Today your company makes the entry itself. The registry offers service providers no access yet. The Commission says it is examining whether that changes. Transpareo checks every passport before publication and prepares the details the entry needs. More in our analysis of the registry regulation.
What does a missing passport cost?
The member states set the fines. The regulation requires effective, proportionate and dissuasive penalties. Usually the standstill costs more than the fine. From the deadline, a battery without a passport may not be placed on the market. A shipment without one then waits in the warehouse until its passport is ready.
Official documents
Legal sources for batteries to read for yourself: what each document is and when you need it.
- Regulation (EU) 2023/1542 concerning batteries and waste batteriesThe regulation itself. It requires the passport, sets out its content and governs the QR code. Every question this page leaves open is answered here.
- Commission guidance "Digital Batteries Passport - data points by category"Classifies all 71 data points per battery category, as mandatory, optional, only where applicable or not to be displayed at the start. It is explicitly non-binding and the most important reading aid for the deadline.
- Regulation (EU) 2025/1561Postpones the supply-chain due-diligence duties to 18 August 2027. Read it when you schedule your compliance planning.
- Regulation (EU) 2024/1781 (ESPR)The framework regulation for the product passport in the other industries. It matters for batteries because the EU DPP registry rests on it. It adds the registration duty to the Batteries Regulation.
- Implementing Decision (EU) 2026/1736 on the harmonised DPP standardsNames six standards for the product passport, EN 18216 and EN 18219 to EN 18223. Whoever complies with them enjoys the presumption of conformity for identifier, data carrier, storage and interfaces.
- DPP page of the European CommissionThe official roadmap for the product passport with the state of the acts and the registry. Date changes appear here first.
- Commission page on the Batteries RegulationOverview, questions and answers and the ongoing acts under the Batteries Regulation. The Directorate-General for Environment maintains it.
Further reading on our blog
The EU Commission has classified all 71 battery passport entries for the first time: mandatory, optional or not yet. What 18 February 2027 asks for.
From 18 February 2027 e-bike and vehicle batteries and industrial batteries above 2 kWh need a passport. What battery manufacturers know, and what the implementing act leaves open.
A pragmatic guide to the carbon footprint methods the ESPR accepts. It compares life-cycle assessment, environmental declarations and system boundaries.
The EU register for Digital Product Passports became law on 16 July 2026. What it asks of you, and what we prepare for you.
Ready for your battery passports?
Set up your passports for batteries today. By the time the obligation takes effect, you have long been up and running.