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Batteries

Battery Passport: EU DPP for Batteries

From 18 February 2027, batteries in the categories covered by Article 77 need an individual passport when placed on the market or put into service. Manufacturers, importers and assemblers should prepare identifiers, applicable data, access controls and lifecycle updates. The September FAQ clarifies that the finished battery determines the scope and responsibility.

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. 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. Ordinary repair updates the existing passport; remanufacturing, repurposing or preparation for reuse after waste status requires a new linked passport.
Legal content defined; implementation details still pending One passport per finished battery (unique identifier)

Reviewed on 9 October 2026: the battery passport deadline remains 18 February 2027.

Regulatory Timeline

17 Aug 2023

EU Battery Regulation enters into force

Regulation (EU) 2023/1542 establishes the battery passport framework and the wider compliance architecture for batteries placed on the EU market.

18 Aug 2024

Performance and durability documentation

Article 10 requires rechargeable industrial batteries >2 kWh, LMT and EV batteries to be accompanied by documented performance and durability values. This is separate from the later passport deadline.

15 Jul 2026

Six DPP EN standards referenced in the Official Journal

Commission Implementing Decision (EU) 2026/1736 published the references of six CEN/CENELEC JTC 24 DPP standards in the Official Journal. They support a presumption of conformity with ESPR Articles 10 and 11 only to the extent covered; they do not themselves amend the battery-specific identification rules in Article 77 of Regulation (EU) 2023/1542. FprEN 18239 and FprEN 18246, together with WI JT024009, remain to be monitored.

20 Jul 2026

DPP Registry opens

The Registry opens with a separate testing environment. Opening the Registry does not itself confirm that every battery-specific registration workflow is available.

12 Aug 2026

Draft delegated act on recycled-content methodology published for feedback

The Commission publishes 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 in batteries and the format of its documentation (Article 8(1) of Regulation (EU) 2023/1542). The declaration duty starts on 18 August 2028 or 24 months after the act enters into force, whichever is later; the passport data points on recycled content follow that date.

15 Aug 2026

Non-binding guidance contains 71 numbered entries

The second edition of the battery data guidance, dated 15 August and announced on 21 August, distinguishes applicability by battery category and underlying requirement. Its 71 entries are not 71 universally mandatory legal fields. Entry 44 anticipates a proposed Annex XIII(1)(t) on printable instructions; that point is absent from the current annex, not an existing duty suspended by Omnibus. The document reflects its authors’ views, not a binding Commission interpretation.

18 Aug 2026

Statutory deadline for the access-rights act

Article 77(9) set this deadline for the implementing act on legitimate-interest access. The September FAQ still describes the act as forthcoming; the passport deadline is unchanged.

September 2026

Battery-passport FAQ

Clarifications on finished batteries, responsible operators, repairs, customs and proportional updates. Guidance does not amend the Regulation.

30 Sep 2026

Third battery-passport webinar

Materials published on 2 October describe a proposed move to EN 18220:2026 and EN 18219:2026 or equivalents. Adoption and publication of the amending act are envisaged in 2027; the proposal does not change current law.

End Oct 2026 (planned)

Semantic specifications and data formats

The September webinar announces technical specifications for the end of October. This is an implementation plan, not a new legal deadline.

Oct–Nov 2026 (planned)

Draft access-rights consultation

The September FAQ envisages public feedback in October or November. The webinar aims for a committee vote in December 2026 or early January 2027. Neither milestone is a confirmed adoption date.

End Dec 2026 (planned)

Registry API integration guidelines

The September webinar announces integration guidelines for the end of December and forthcoming data and service-account guides. These are planned publications.

18 Feb 2027

Battery passport obligations apply

All LMT batteries, industrial batteries >2 kWh and EV batteries need an individual passport when placed on the market or put into service. Not every field is applicable from this date.

18 Aug 2027

Battery due diligence starts

Regulation (EU) 2025/1561 postponed the Article 48 obligations to this date. Check Article 47 applicability and exemptions; this does not postpone the passport obligation.

18 Aug 2028 or later

Recycled-content declaration

For applicable EV, SLI and industrial batteries >2 kWh, Article 8(1) starts on 18 August 2028 or 24 months after the methodology act enters into force, whichever is later. Batteries with exclusively external storage are excluded; LMT has a separate 2033 date.

18 Aug 2031

First minimum recycled-content shares

For applicable EV, SLI and industrial batteries >2 kWh, excluding exclusively external storage: Co 16%, Pb 85%, Li 6%, Ni 6%. The percentages concern each metal, not total battery mass. SLI batteries remain outside passport scope.

Official Sources

Sources reviewed:

European Commission, DG GROW

DG GROW presentation, 7 July 2026

Clarifies that carbon-footprint, recycled-content and due-diligence points apply only after their underlying category requirement starts.

European Commission, DG GROW

DPP Registry user guide v1.03, 16 September 2026

The Registry User Guide v1.03 of 16 September described a battery-registration dependency on the semantic catalogue; that dated statement should not be treated as a live test of Registry availability.

European Commission, DG GROW

Legal basis and current timeline

Commission portal with DPP work schedules and current implementation documents; planned dates are not statutory deadlines.

European Commission, DG GROW

September 2026 battery-passport FAQ

FAQ answers, presentations and data guidance support implementation. They are not binding legislation; announced dates and proposed fields do not amend the Regulation.

What must the battery passport contain?

Each row identifies the information location or type of duty. A label, documentation or process duty does not mean publication in the DPP is required. Supporting passport data do not remove duties under other legislation. See details for conditions and dates.

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. Other technical documentation and waste-treatment information have their own recipients and are not automatically passport fields.

attributes: 71 · data groups: 8

Public Authorised recipients Authorities / bodies Updated data Measurement context

Tiered Data Access (Art. 77)

The public due-diligence report includes a summary of third-party verification. Full audit records are a separate documentation duty and are supplied to authorities on request. Passport conformity-test results are accessible to notified bodies, market surveillance authorities and the Commission. Individual battery-use data follow separate access rights under Article 77(2) and Annex XIII point 4. 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.

BMS means battery management system. Article 14 state-of-health data applies to batteries with a BMS. Its absence does not remove applicable performance, status or use-data obligations. The September FAQ expects updates at least at status changes or decisions on reuse, remanufacturing or recycling, with proportionate additional updates. It does not require universal real-time or wireless transmission.

Article 8: each share is calculated within the metal concerned, not total battery mass. Cobalt, lithium and nickel may come from battery manufacturing waste or post-consumer waste; lead from waste. From 18 August 2031: Co 16%, Pb 85%, Li 6%, Ni 6% for EV, SLI and industrial batteries >2 kWh, excluding batteries with exclusively external storage. From 18 August 2036: Co 26%, Pb 85%, Li 12%, Ni 15%, also for LMT. SLI batteries still do not require a passport.

Source labels indicate where a company may hold the data, for example ERP, a BMS or lifecycle-assessment software. They are integration guidance, not legally mandated systems.

Which batteries and operators are concerned?

The passport concerns the finished, safely functioning battery. Packs sharing essential components may constitute one battery; independently functioning batteries are assessed separately, including for the >2 kWh industrial threshold. Cells and modules awaiting assembly normally do not require separate passports. The party completing and placing the finished battery on the market or putting it into service is responsible; practical tasks may be delegated in writing without transferring that responsibility.

  • EV batteries used in battery-electric and plug-in hybrid vehicles
  • industrial batteries above 2 kWh used in storage, backup and industrial systems
  • all LMT batteries for light means of transport such as e-bikes and e-scooters (regardless of capacity)
  • manufacturers, importers and distributors responsible for placing covered batteries on the EU market under their own name or brand
  • OEM, engineering, quality and compliance teams that must align one battery record across product, testing and regulatory systems
  • companies already collecting carbon, recycled-content, sourcing or performance data, but still holding it in disconnected supplier files, spreadsheets or lab documentation
  • battery pack assemblers, storage-system providers and mobility brands that rely on upstream cell or module data they do not fully control

SLI starter batteries do not require an Article 77 passport. From 18 February 2027 they require the QR code under Article 13(6)(b), linking to applicable information including the declaration of conformity. General labelling under Article 13(1): from 18 August 2026 or 18 months after the implementing act enters into force, whichever is later.

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