Digital Product Passport for batteries

Yes. The duty attaches to placing on the market, not to manufacturing. Whoever brings a battery into the EU from a third country places it on the market and has to make sure the passport exists and its information is correct (Art. 77(4)). In practice - either your manufacturer supplies the passport, or you create it and need the manufacturer’s data to do so. Settle that in the contract before the first shipment of 2027 sits at customs.

LMT batteries (e-bikes, e-scooters, e-mopeds), EV batteries and industrial batteries above 2 kWh need the passport. Portable batteries and SLI starter batteries need none, but 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)). Labelling and removability duties apply to these groups too, and SLI batteries report their recycled content as well, just without a passport. The carbon-footprint duties of Art. 7 do not reach them; by 31 December 2030 the Commission assesses whether to extend them to portable batteries (Art. 7(4)).

The deadline has 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, but not for the data - recycled shares and test results sit with the cell manufacturers, and data clauses in purchasing contracts take months. Start with the data; the passport itself is set up in Transpareo within days.

No. The regulation requires a unique identifier under the ISO/IEC 15459 series (Art. 77(3)), not a particular number. If you have a GTIN, the identifier in Transpareo becomes a GS1 Digital Link that other systems resolve too. Without a GTIN the passport carries a unique Transpareo identifier, and the QR code leads to the passport just the same.

Not at the deadline. According to the Commission guidance of July 2026, the carbon-footprint declaration and label are not to be displayed at the start, because the delegated act with the calculation method is still missing. The duty arrives in stages - first the declaration, then the performance class, finally a maximum threshold, each 12 to 18 months after the act (Art. 7). The fields for it are already in place 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.

Annex XIII grades the data in four tiers. Public are model data such as composition, capacity, safety and recycling information. Persons with a legitimate interest, such as repair and recycling businesses, see disassembly, detailed composition and spare parts. Authorities and notified bodies receive the test reports. Individual-battery data such as state of health and status are again for authorised readers only. The same QR code shows a different view depending on who reads it. In Transpareo, visibility is a property of every data field - the public tier appears without any login, the others through logged access.

Until the battery has been recycled; only then does the passport cease to exist (Art. 77(8)). For an EV battery that is easily fifteen years, second life included. The duty therefore outlives any contract with a service provider. So ask every provider what happens to your passports after a cancellation - with Transpareo, published passports stay reachable through a permanent address, and our provider checklist names the further questions.

You place the battery on the market again and take over the passport duty. The battery gets a new passport, linked to the passport of the original battery, and a new label with the changed status (Art. 77(7), Art. 13(9)). The carbon-footprint declaration and the recycled-content shares do not apply to such batteries (Art. 7(5), Art. 8(4)).

Yes, and you do it yourself. Product passports are registered in the central EU DPP register, operational since 20 July 2026, with Implementing Regulation (EU) 2026/1778 setting out how it works. Only the economic operator placing the battery on the market or putting it into service may register it (Art. 77(10) of the Batteries Regulation, inserted by Art. 78 of the ESPR); a service provider cannot do it for you, because the authorisation route of the implementing regulation applies only where Union law provides for it, and the Batteries Regulation does not. Registration happens before the battery is placed on the market and returns a unique registration identifier; the register holds identifiers and a fingerprint, the data stays in the passport. Transpareo prepares what the entry asks for - product identifier, operator identifier, passport address and fingerprint - so you complete the entry yourself in the register once its interface is settled. In its reply to our enquiry the Commission stated that it is examining whether service providers may register in future. On the register - our analysis of the register regulation.

The regulation leaves the fines to the member states but requires effective, proportionate and dissuasive penalties. Usually more expensive than the fine is the ban on placing on the market - a shipment without a passport may not enter the market from the deadline, and for EV batteries that leaves six-figure amounts per container standing still.