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 · 8 min read · InfoDPP

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.

That changes the practical question for battery teams. This is no longer about watching the ESPR pipeline from a distance. It is about making identifier logic, data architecture, and update workflows work before the legal date arrives.

What Article 77 Already Fixes

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.

In the battery regime, QR code is not just editorial shorthand. Article 77 expressly points to the QR code referred to in Article 13(6). The real simplification would be to reduce the whole obligation to the code alone, without the data model, identifier logic, and access rules behind it.

Scope still needs care. SLI batteries are not subject to the Article 77 passport, even though Article 13(5) still requires a QR code with basic information. Portable consumer batteries are also not automatically in scope just because they are batteries.

Annex XIII Is Not a Short Checklist

Annex XIII is a multi-layer data obligation, not a short product card. In practice it becomes a data model spanning 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.

If a company scopes the project as a QR code plus landing page, it will understate the workload. The hard part is not publishing a page. The hard part is keeping model-level, plant-level, and individual-battery records consistent across product, sustainability, quality, service, and supplier systems.

Not Everyone Sees The Same Data

Article 77 splits access rights into three layers:

public information for the general public
restricted information for persons with a legitimate interest, such as repairers, remanufacturers, second-life operators, and recyclers
authority-only or notified-body access for the most sensitive records, including test-report layers

The Commission still has to specify the legitimate-interest access regime through implementing acts by 18 August 2026. So the architecture cannot stop at a public page. It needs role-based access and a governance model for sharing, reuse, and updates.

Why BMS Data Changes The Project

Battery passports are not static declarations. The legal model expects information specific to the individual battery, including information resulting from its use. That is why teams should already plan how State of Health, cycle counts, remaining capacity, negative events, and status changes after repurposing or remanufacturing will feed the passport process.

A once-published PDF or marketing microsite is not enough. For batteries, the passport is closer to a lifecycle record that has to survive service, second-life use, and end-of-life handling.

Due Diligence Track — Delayed 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 Commission’s due diligence guidelines, originally due 18 February 2025, are now expected by 26 July 2026, aligned with CSDDD guidance under Directive (EU) 2024/1760.

When Article 77 activates on 18 February 2027, due diligence for cobalt, lithium, natural graphite and nickel supply chains will still be six months away from application. Annex XIII fields that reference due diligence evidence will therefore start their life before the underlying obligation is enforceable. 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
Forgetting that repurposed or remanufactured batteries need status changes and a linked passport chain

Official Sources

Need a structured pilot before 2027? Start free on OriginPass.eu and test a battery passport workflow before the deadline pressure hits.

← Back to Blog