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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

Editorial update, 16 July 2026: Decision (EU) 2026/1736 published the references to six DPP standards for the ESPR, but it does not itself amend Article 77(3) of the Batteries Regulation. That provision still names the ISO/IEC 15459 series and provides for a separate delegated act that may replace or add standards for the battery QR code and identifier. Scope of the Decision →

Editorial update, 22 July 2026: the production DPP Registry, separate testing environment and implementation resources are now available. The Commission describes registration as available through a secure interface or API. Battery-specific tests still depend on the applicable semantic catalogue, while testing requires a separate EU Login and valid organisation verification. This launch does not change the battery-passport deadline of 18 February 2027 or replace the Annex XIII requirements; Regulation (EU) 2026/1778 enters into force on 6 August.

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.

July 2026 signal: the 18 February 2027 deadline has not changed, but the implementation path is getting more concrete:

six JTC 24 DPP standards were published as EN standards in May 2026; FprEN 18239 and FprEN 18246 remain in progress, and WI JT024009 should also be monitored

the production Registry, separate test environment and implementation resources have been available since 20 July; the Commission describes registration as available through a secure interface or API, while battery-specific tests still depend on the applicable semantic catalogue

DG GROW’s 27 May 2026 webinar confirms the registry and secondary-legislation checkpoint for battery readiness

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.

What the Registry Framework Adds: and Does Not Add

For a battery passport, Regulation 2026/1778 provides the horizontal registration layer. 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.

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.

What the May 2026 Webinar Clarified for Batteries

DG GROW’s 27 May 2026 webinar added several operational details that are easy to miss in the legal text alone:

One responsible operator, no separate “DPP service provider” role. Responsibility for the battery passport sits with the economic operator placing the battery on the market, normally the EU manufacturer or importer, who may give written authorisation to another actor to act on its behalf. Unlike the horizontal ESPR model, batteries do not use a distinct DPP-service-provider actor.
The passport follows the battery into its second life, then ends. When a battery is remanufactured or repurposed, a new passport is created and a new operator takes responsibility. Once it becomes waste, responsibility passes to the producer (or its producer-responsibility organisation / appointed waste operator), and the passport ceases to exist after the battery has been recycled.
Restricted-data access is narrower than an open database. The implementing act on legitimate-interest access (Article 77(9), covering Annex XIII points 2 and 4) was circulated to the Battery expert group on 29 April 2026. The Batteries Regulation sets an 18 August 2026 deadline for it, and the webinar timeline now shows adoption tracking to around Q4 2026. The working principles are limited sharing and no publication of restricted data, with extra care for commercially sensitive fields.
The QR/identifier standards are being renumbered. The standards referenced in Article 77(3) are being updated to EN 18220 (data carrier) and EN 18219 (unique identifier) through a delegated act this year; the currently referenced standards stay valid in the meantime (“or equivalent”).

The Commission also plans a public semantic rulebook based on the webinar content to make Annex XIII interpretation more consistent, a reference rather than a new obligation, alongside the Battery Pass project, DIN DKE SPEC 99100 and the CEN/TC 301 draft technical specification.

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.

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