industry

Battery DPP Deadline: What to Do Before February 2027

Battery passport obligations start on 18 February 2027 for covered battery categories. What manufacturers should prepare now and what is still evolving.

3/6/2026 · 10 min read · InfoDPP

Reviewed on 9 October 2026: the battery passport deadline remains 18 February 2027. The September FAQ clarifies scope, responsibility and updates. The 30 September webinar, whose materials were published on 2 October, sets out further planned implementation steps. These guidance documents do not amend the Regulation. September 2026 battery-passport FAQ · 30 September webinar presentation (PDF)

Why February 2027 Is Different

For most product groups, DPP obligations are still waiting for future ESPR delegated acts. Batteries already have a sector-specific legal basis. Article 77 of Regulation (EU) 2023/1542 requires that from 18 February 2027 each LMT battery, each industrial battery above 2 kWh, and each electric vehicle battery placed on the market or put into service must have an electronic record.

Battery teams therefore need to prepare their identifiers, data structures and update procedures before the deadline, rather than simply monitor future ESPR legislation.

What Article 77 Already Requires

From 18 February 2027, each in-scope battery needs an electronic record in the form of a battery passport.
The passport must be reachable through the QR code referred to in Article 13(6), linked to a unique identifier attributed by the economic operator placing the battery on the market.
The passport must contain battery-model information and battery-specific information for the individual battery, including information resulting from its use, as set out in Annex XIII.

For batteries, the QR code is an explicit legal requirement: Article 77 refers to the code in Article 13(6). But the code alone does not meet the obligation. It must link to the required data, identifiers and access controls.

What the Registry Framework Does and Does Not Add

For a battery passport, Regulation 2026/1778 provides the common registration framework. It requires registration at the model, batch or item level specified by the applicable Union rule; if overlapping rules apply, the most granular level applies. The Registry checks the technical consistency of registration data and creates a unique registration identifier, but that check is not proof that a battery satisfies Article 77 or Annex XIII.

The practical result is a second workstream alongside the battery data model: decide who will be the verified registrant, prepare the necessary eIDAS-based verification, preserve version history and map the correct model/batch/item relationship. It does not make a generic Registry record a substitute for Annex XIII, nor does it transfer responsibility away from the economic operator.

Starting, lighting and ignition (SLI) batteries and portable batteries do not require a passport under Article 77. Article 13(6) does, however, require a QR code with basic information for SLI batteries. The QR code requirement and the passport requirement are separate.

Annex XIII Is Not a Short Checklist

Annex XIII requires a detailed set of data, not just a short product description. It covers manufacturer identity, manufacturing plant, carbon footprint, chemistry and hazardous substances, recycled content and due diligence, performance and durability, compliance evidence, dismantling, and end-of-life handling.

Budget for the QR code, the passport page and the work needed to manage the data. Information about the model, the factory and each battery must remain consistent across product, sustainability, quality and service systems, as well as supplier records.

The 15 August 2026 Guidance: Which Data Points From February 2027

The guidance Digital Batteries Passport: data points by category (second edition, 15 August 2026) presents 71 numbered entries and category-specific applicability. Prepared for the Commission, it expressly states that it reflects its authors’ views, is not the Commission’s official position and does not change legal rights or obligations. It is a practical aid, not a list of 71 universally mandatory statutory fields.

Not every field is due in February 2027. The guidance distinguishes mandatory, optional and conditional entries, duplicates and entries awaiting the application of underlying obligations or secondary legislation. Check the legal basis and battery category for each field.
Instructions for use are a proposed addition. Entry 44 refers to an anticipated Annex XIII point 1(t) and marks it as pending Omnibus adoption. The current consolidated Annex XIII ends its public-information list at point 1(s). This is not an existing passport duty suspended by guidance; other applicable duties to supply instructions remain unaffected.
Categories differ. Annex VII Part A specifies state of certified energy (SOCE) for EV batteries. For LMT batteries and stationary battery energy storage systems, it specifies remaining capacity and the evolution of self-discharge rates, plus remaining power, round-trip efficiency and ohmic resistance where possible. Some parameters also appear separately as model-level and individual-battery data; check the legal basis for each use.
Access levels are not in the guidance. The document maps content and applicability; who may see which field still follows Article 77(2) and the pending access-rights implementing act.
The recycled-content methodology is now in draft. On 12 August 2026 the Commission published for feedback (until 9 September 2026) a draft delegated regulation establishing the methodology for calculating and verifying the recycled content of cobalt, nickel, lithium and lead and the format of its documentation. The declaration duty itself starts on 18 August 2028 or 24 months after that act enters into force, whichever is later, which is why the guidance marks the recycled-content data points as not to be filled in from February 2027.

The September FAQ clarifies that carbon-footprint, recycled-content and due-diligence fields are not yet required in February 2027. Their applicability follows the underlying category-specific obligations. Fields that do not yet apply are absent from the active semantic data model; a later model version can introduce them. This differs from use-derived fields in a new battery, which may initially have no value because the battery has not been used. Initial status and applicable performance values still have to be provided.

Who can access the data

Article 77(2) and Annex XIII distinguish the following access rights:

the public can access point 1
notified bodies, market surveillance authorities and the Commission can access points 2 and 3
persons with a legitimate interest can access points 2 and 4 under the applicable access rules

The forthcoming implementing act will specify which users have a legitimate interest and what they may download, share, publish or reuse. A general prohibition on publishing every restricted field should not be presented as an adopted rule. The September FAQ also distinguishes these permissions from authentication: the passport operator manages access in a decentralised system; the Registry does not host the full passport.

Updates do not require a continuous data stream

According to the September FAQ, dynamic information is expected from February 2027, with updates at least when the battery status changes or when a decision is taken on reuse, remanufacturing or recycling. More frequent updates should be proportionate to the use case. Neither real-time updates nor wireless transmission are universally required; service visits can provide an appropriate update point for some batteries.

The state-of-health information referred to in Article 14 and Annex XIII(4)(b) is required for batteries with a battery management system (BMS). Without a BMS, applicable performance values and status must still be provided when the battery is placed on the market and when its status changes. The lack of a BMS does not create a blanket exemption from use-related information under Annex XIII(4)(d).

What the September FAQ clarifies

The passport covers the finished battery. Cells and modules intended for later assembly generally do not need separate passports. If packs need a common BMS or other shared components and together form a finished battery, the passport covers that whole battery. For separate, independently functioning industrial batteries, the threshold of more than 2 kWh applies to each battery individually. The number of passports therefore depends on how the packs are built and how they work.
Responsibility for assembly and imports. An EU company completing the battery is responsible when it places the battery on the market or puts it into service. For an imported product containing a finished battery, the importer is normally responsible. Data preparation and updates can be assigned in writing to another operator, including one outside the EU. The responsible operator keeps its legal obligations.
Ordinary repair does not require a new passport. Relevant information is updated in the existing passport. Remanufacturing, repurposing, or preparation for reuse after the battery becomes waste requires a new passport linked to the original. The passport ceases to exist after recycling. When the battery becomes waste, responsibility passes to the producer, producer responsibility organisation or appointed waste-management operator.
Creation and registration are separate steps. Registration remains necessary, but the battery-passport registration identifier is not required in the electronic customs declaration under the battery-specific regime. This customs rule differs from ESPR.

The 30 September webinar: planned next steps

The presentation gives the following indicative milestones:

End of October 2026: technical specifications for semantics and data formats.
October or November 2026: according to the September FAQ, the draft act on access rights is expected to open for public feedback in one of these months. The webinar presentation indicates a planned committee vote in December 2026 or early January 2027. The adoption date is not yet confirmed.
End of December 2026: Registry API integration guidelines. The presentation also announces forthcoming updated data and service-account guides.

Article 77(3) currently refers to the ISO/IEC 15459 series or equivalent standards. The webinar also describes a draft delegated act that would update Article 77(3) to EN 18220:2026 for QR codes and EN 18219:2026 for unique identifiers, or equivalent standards. It reports that the draft was opened for feedback on 29 September and envisages adoption and publication in 2027. A draft does not change the currently applicable identification rules. The Registry User Guide v1.03 of 16 September stated that battery registration requires a semantic catalogue. It describes the situation on that date and does not establish whether registration is available today.

Due diligence obligations postponed to 18 August 2027

Article 77 (the passport) and Article 48 (battery due diligence) are separate obligation streams. Regulation (EU) 2025/1561, adopted on 18 July 2025, amended Article 48(1) and pushed the due diligence application date from 18 August 2025 to 18 August 2027. The legal deadline for the Commission’s battery due diligence guidelines remains 26 July 2026. Although that date was aligned with the CSDDD timetable when the amendment was adopted, Directive (EU) 2026/470 subsequently moved the main CSDDD guidance deadline to 26 July 2027, so the two timetables are no longer aligned.

When Article 77 starts to apply on 18 February 2027, due diligence for cobalt, lithium, natural graphite and nickel supply chains will still be six months away from application. DG GROW clarified on 7 July 2026 that carbon-footprint, recycled-content and due-diligence data enter a passport only for batteries placed on the market after the relevant underlying requirement starts to apply to that battery category. Before then the data point is not applicable; a system may model it early, but must not present it as legally required passport content. For a full breakdown, see Battery Due Diligence Delay under Regulation (EU) 2025/1561.

What To Do In 2026

map all battery lines against the Article 77 scope and document where SLI, portable, and other excluded categories sit
define the unique-identifier strategy for each in-scope battery and test the QR-to-record path early
build one field inventory that connects carbon footprint, recycled content, due diligence, technical documentation, and BMS outputs
decide who is allowed to update the passport after service, repurposing, remanufacturing, or other status changes
pilot both the public view and the restricted-access layer instead of testing only the consumer-facing page

If you need the wider context first, read What is a DPP? and our step-by-step DPP guide.

Biggest Mistakes to Avoid

Treating batteries as just another future ESPR watchlist topic
Assuming a model page is enough for every in-scope battery
Publishing the QR code before access rights, source evidence, and change governance are defined
Keeping BMS and service data outside the passport workflow
Confusing an ordinary repair with a lifecycle operation requiring a new passport

Official Sources

Start with one product: create its digital product passport on OriginPass.eu.

← Back to Blog