If you make EV, light-means-of-transport, or industrial batteries, you have a fixed deadline: your first compliant EU Battery Passport must exist by 18 February 2027. The hard part is not the date, it is the data the passport demands.
This guide walks through how to create a digital product passport from scratch, without drowning in spreadsheets or guessing at the law. We will cover what a DPP actually is, the data you have to gather, the steps to build and publish one, and how to keep it maintainable as more EU regulations come into force. The goal is a passport that holds up to scrutiny, not a box-ticking exercise you have to redo in a year.
What a Digital Product Passport Actually Is
A Digital Product Passport (DPP) is a structured, machine-readable record of a product’s identity, composition, compliance status, and lifecycle data, made accessible through a data carrier such as a QR code on the product. It is not a PDF brochure. It is a queryable dataset that regulators, recyclers, verifiers, and customers can read in a consistent format.
The first DPP most manufacturers will build is the EU Battery Passport, established under Regulation (EU) 2023/1542. Its passport obligations sit under Article 77, and it applies from 18 February 2027 to three in-scope categories:
- All EV (traction) batteries, regardless of capacity
- Light-means-of-transport (LMT) batteries, defined in Article 3 as sealed batteries weighing 25 kg or less that are designed to power wheeled vehicles such as e-bikes and e-scooters
- Industrial batteries with a capacity above 2 kWh
The Battery Regulation is the first of many DPP regimes, with the Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781, extending the model to more product groups through delegated acts on their own timelines. (Our ESPR explainer tracks the detail.) So while batteries come first, learning to create a passport now is an investment in every regulation that follows. You can see the full landscape on our regulatory overview.
How to Create a Digital Product Passport in Three Steps
At a high level, the workflow is the same for every product: map the required data, build and validate the record, then publish it behind a QR code and keep it current. The three steps below walk through each in turn, starting with the part that takes longest.
Step 1: Map the Data Your Passport Requires
Everything starts with the data model. For the EU Battery Passport, the required content is set out in Annex XIII of the Regulation. This is the single most important reference for your first build, and reading it early prevents expensive rework.
The core data categories
Annex XIII groups the required information into areas that include:
- Battery identification: manufacturer, model, batch or serial reference, and date of manufacture
- Composition and materials: chemistry, critical raw materials, and substances of concern
- Carbon footprint: calculated using the methodology in Annex II of the Regulation
- Performance and durability: rated capacity, expected lifetime, and state-of-health parameters
- Supply-chain due diligence and end-of-life handling information
A practical tip: split these fields by who owns the answer. Identity and performance data usually live with your engineering team. Material composition and carbon-footprint inputs often sit with suppliers several tiers down. Mapping ownership now tells you where the real bottleneck will be, which is almost always the supplier data. There is a way to push that work back to suppliers directly, which we cover in Step 3.
Why the supplier data is the hard part
Much of Annex XIII cannot be answered by you alone. Cathode supplier declarations, recycled-content certificates, and carbon-footprint inputs arrive as PDFs, emails, and lab reports in inconsistent formats. This is where first-time DPP projects most often stall, because supplier data arrives late and in inconsistent formats.
Traceable’s AI document intelligence reads these uploaded documents and extracts the relevant compliance fields. Because the AI auto-fills a large share of structured Annex XIII fields from the source documents, the operator reviews and confirms values instead of typing them in, turning what is often hours of manual entry into minutes. Actual savings vary by product and document quality. If supplier data is your bottleneck, the Battery Passport pilot is built around exactly that problem.
Step 2: Create the Digital Product Passport and Generate the QR Code
Once you know the fields, you assemble the passport itself. A structured platform guides this far better than a blank spreadsheet, because the schema and validation are built in.
Assemble and check for gaps
Working through a guided wizard, you enter or confirm each field, with supplier data pulled in where available. As you go, a compliance gap score shows which mandatory fields are still missing or structurally invalid against the Annex XIII schema. This is structure and completeness validation, confirming the passport has the right fields in the right shape. It is not a certification of authenticity, and no honest tool should claim otherwise.
Generate the data carrier
Every physical battery needs a data carrier linking back to its passport. The Regulation requires a QR code on the battery (the labelling obligation sits under Article 13), while electronic accessibility of the passport itself falls under Article 77. The expected format is a GS1 Digital Link, which encodes the product identifier in a resolvable web URL. This is the industry-standard encoding the platform uses, not a format the Regulation itself mandates. Traceable generates this QR code for you once the passport validates, so the carrier and the underlying record stay in sync. For a closer look at how a passport goes from assembly to publication, see how it works.
Register where required
Under ESPR, a central EU DPP Registry is established under Article 13 of the ESPR (Regulation (EU) 2024/1781), which the Commission is to set up by 19 July 2026. Product-specific registration duties arrive through the delegated act for each product group. Our EU Central Registry guide tracks how this develops so you register correctly when your category’s rules apply.
Step 3: Publish, Share, and Keep It Current
Creating the passport is the start, not the finish. A DPP is a living record that must stay accurate across the product’s life.
- Publish the passport so the QR code resolves to a live, accessible page for regulators and the public.
- Share selectively through a supplier portal, so upstream partners update their own fields directly (this is what resolves the Step 1 bottleneck), and a verifier access layer lets auditors review the record in a controlled way.
- Maintain the data as inputs change, as state-of-health figures are re-measured, recycled-content figures are recertified, or a substance-of-concern declaration is updated over a battery’s life.
Two responsibilities are worth flagging for first-timers. A common and costly assumption is that your supplier or importer will produce the passport for you. They will not, at least not all of it. The legal duty to place a compliant battery on the EU market sits with a named economic operator, and much of the Annex XIII data (carbon footprint, due diligence, performance) has to be assembled by whoever owns the product record. If you make or sell the battery, assume the passport is yours until a contract says otherwise. If you are a non-EU manufacturer, note that the importer placing your battery on the EU market carries duties under Article 4 of the Regulation, so coordinate early on who owns the passport.
On penalties: Article 89 requires member states to set rules that are effective, proportionate, and dissuasive, with the actual amounts defined at national level. The point is simply that non-compliance is enforceable, not optional.
One engine across every EU regulation means the work you do for batteries is not throwaway. When your next product group falls under ESPR, you extend the same record instead of starting a new compliance project, and a new tool, from zero. You can explore a working example through the Battery Passport pilot.
Conclusion: Start Small, Build It Right
Creating your first digital product passport comes down to three moves: map the Annex XIII data and identify your supplier gaps, assemble and validate the record, then generate the GS1 Digital Link QR code and keep the passport current. Do it on a structured platform and the second passport takes a fraction of the effort of the first.
The deadline is 18 February 2027, but the part that takes longest, getting carbon-footprint and material data back from suppliers several tiers down, is exactly the part you do not control. That is why teams that start the data-collection workflow a year ahead are the ones not scrambling. The fastest way to learn the workflow is on your own data, not under pressure.
Book a demo and we will help you build a sample passport with your own product, end to end. Prefer to try it yourself first? You can start on the free tier and build a sample passport at your own pace before committing budget.
