Under Regulation (EU) 2023/1542 (the EU Battery Regulation), the Digital Battery Passport obligation in Article 77 applies from 18 February 2027. The date of application is set in the regulation itself; as of June 2026, no Commission proposal or delegated act has been published to postpone this date. By contrast, the due-diligence obligations that Article 48(1) applies, in Article 48(2) and (3) and Articles 49, 50 and 52, were postponed from 18 August 2025 to 18 August 2027 by Regulation (EU) 2025/1561; operators should not extrapolate that postponement to the passport. From 18 February 2027, every EV battery, LMT battery, and industrial battery with a capacity above 2 kWh placed on the EU single market must carry a compliant, machine-readable battery passport.
What the passport must contain
Annex XIII of the regulation lists the information the passport must contain, to the extent applicable to the battery category (Article 77(2)), in four numbered points, each with its own access rule: point 1 is public; point 2 is for persons with a legitimate interest and the Commission; point 3 is for notified bodies, market surveillance authorities and the Commission; point 4, the data on the individual battery, is for persons with a legitimate interest. Not every item applies on 18 February 2027: the Commission guidance Digital Batteries Passport data points by category (Version 2.0, 15 August 2026) marks the carbon footprint, recycled content and responsible sourcing data points as not to be filled at that date. By topic, the information covers:
- General information: manufacturer identity, battery model, chemistry type, rated capacity, voltage, weight, and manufacturing date and location
- Carbon footprint: declared carbon footprint per kWh over the battery lifecycle, calculated using the EU Product Environmental Footprint methodology
- Recycled content: the percentage shares of cobalt, lithium and nickel in active materials recovered from battery manufacturing waste or post-consumer waste, and of lead in the battery recovered from waste, as documented under Article 8(1) (Annex XIII, point 1(e))
- Performance and durability: rated capacity, expected cycle life, energy round-trip efficiency, internal resistance, and state of health parameters
- Hazardous substances: the hazardous substances present in the battery, other than mercury, cadmium or lead, as part of its material composition (Annex XIII, point 1(b)); a hazardous substance is one classified as hazardous under Article 3 of Regulation (EC) No 1272/2008 (Article 3(1), point (52)). Commission proposal COM(2025) 981 would change the label list in Annex VI, Part A, to substances of very high concern at or above 0.1 % weight by weight; as of 26 September 2026 it is not law
- Supply chain due diligence: raw material sourcing policies, third-party audit status, and responsible sourcing documentation aligned with OECD Due Diligence Guidance
Who is affected
The passport obligation falls on the economic operator that places the battery on the market: it attributes the unique identifier and must ensure the passport information is accurate, complete and up to date (Article 77(3) and (4)). For a battery from a third country that is usually the importer, the person established in the Union who places it on the market (Article 3(1), point (64)). That operator may give written authorisation to another operator to act on its behalf (Article 77(4)). Distributors do not create the passport, but before making a battery available they must verify that it is marked and labelled in accordance with Article 13 (Article 42(2), point (b)), which from 18 February 2027 includes the QR code giving access to the passport.
Could the date still change?
As of the latest publication review (June 2026), the 18 February 2027 date of application stands in the consolidated text of Regulation (EU) 2023/1542. Operators should plan on this date. A Commission proposal alone would not change it: only an amending regulation adopted by the European Parliament and the Council can, as Regulation (EU) 2025/1561 did for the due diligence obligations, and that postponement does not extend to the passport.
What happens if you are not ready
From 18 February 2027, an EV battery, LMT battery or industrial battery with a capacity above 2 kWh placed on the market or put into service without a battery passport does not comply with Article 77(1). Market surveillance authorities can require the economic operator to take corrective action, including preventing the battery being made available, withdrawing it or recalling it (Regulation (EU) 2019/1020, Article 16(2) and (3); for batteries presenting a risk, Article 79 of Regulation (EU) 2023/1542). The authorities that control products entering the Union market must suspend release for free circulation where a product is not marked or labelled as Union law requires, and must refuse release where market surveillance authorities conclude it does not comply (Regulation (EU) 2019/1020, Articles 26 and 28). Member States set the penalties (Article 93), so their severity varies, but losing the ability to sell the product in the EU can be the most significant commercial risk.
Recommended actions
- Conduct a gap analysis of your current product data against Annex XIII requirements
- Engage suppliers for upstream data (raw material origin, carbon footprint, recycled content certificates)
- Select a DPP platform that supports battery passport creation, GS1 Digital Link QR codes, and registration in the EU DPP registry under Implementing Regulation (EU) 2026/1778, published on 17 July 2026; as of 26 September 2026 the Commission’s User Guide states that battery passports cannot yet be registered
- Create and publish your first battery passport as a pilot, using your highest-volume product
- Establish a quarterly review cadence to ensure data remains current
Primary sources: Regulation (EU) 2023/1542 (EUR-Lex); Regulation (EU) 2025/1561, due-diligence postponement (EUR-Lex).
