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 in Articles 47–49 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 specifies the mandatory data fields, organised into six categories:
- 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 — percentages of recycled cobalt, lithium, nickel, and lead, with pre-consumer and post-consumer breakdowns
- Performance and durability — rated capacity, expected cycle life, energy round-trip efficiency, internal resistance, and state of health parameters
- Hazardous substances — REACH SVHC declarations with CAS numbers, concentration ranges, and safe use instructions
- 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 obligation applies to all economic operators as defined under the regulation — manufacturers, importers, and distributors. If you place a battery on the EU market, you share responsibility for ensuring a compliant passport accompanies it. For batteries manufactured outside the EU, the importer becomes the responsible party if the manufacturer has not created a 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 until and unless the Commission publishes a formal proposal to amend it. Industry has raised concerns about readiness given the parallel postponement of due-diligence obligations; however, those postponements do not extend to the passport itself.
What happens if you are not ready
Batteries placed on the EU market after 18 February 2027 without a compliant passport will be considered non-compliant. Market surveillance authorities in each EU Member State have the power to order product withdrawal, block imports at customs, and impose financial penalties. The severity of penalties varies by Member State, but the market access restriction alone — the inability to legally sell the product in the EU — represents 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 a registry-ready architecture for the EU Central Registry once its implementing act is published
- 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).
