Batteries

Battery Passport: EU DPP for Batteries

Batteries are the first product group for which passport obligations are already fixed in sector-specific EU law. That makes the battery track fundamentally different from sectors still waiting for later ESPR delegated acts. For covered categories, the key challenge is now operational: manufacturers, importers and distributors need to connect compliance, engineering, sustainability and product-data systems before February 2027, rather than simply monitor future policy signals.

Regulatory note: this page refers to the battery passport under Regulation (EU) 2023/1542, not to a later ESPR delegated act. The battery track is currently the most mature DPP regime at EU level. Note the split between Art. 77 (passport) applying on 18 February 2027 and Art. 48 (supply-chain due diligence), postponed to 18 August 2027 by Regulation (EU) 2025/1561. The passport data model should be ready for due-diligence fields from launch, but values may remain empty until the cross-referenced obligation or material scope applies; the Commission webinar states that the due diligence report has to be included by the latest August 2028.

Confirmed data schema (Annex XIII) DPP per individual battery (serial number)

Battery passports are not a distant ESPR scenario. For covered categories, the core compliance date is already fixed: 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.

2024–2025

Secondary rules on carbon-footprint methodology progress

The carbon-footprint regime moves from high-level legal obligation toward category-specific methodology and implementation work for EV, industrial and LMT batteries. This is the point where companies need cleaner plant, model and supply-chain data.

2025–2026

Carbon and technical documentation requirements become operational

Manufacturers need to align declarations, supporting technical documentation and source evidence with the categories they place on the market. The exact secondary rules are not identical across all covered battery types, so companies should avoid assuming one uniform compliance package.

2025–2026

Systems, identifiers and data governance need to mature

This is the practical preparation window for mapping battery identifiers, technical documentation, lifecycle metrics and supplier evidence into one passport-ready structure. The legal direction is already set, but the internal operating model often is not.

4 Mar 2026

Industrial Accelerator Act proposed

The European Commission proposed the Industrial Accelerator Act, which includes Made-in-EU and low-carbon procurement preferences for batteries, steel, cement and aluminium. While not a DPP act itself, it reinforces traceability and origin certification expectations for battery value chains.

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.

Jun–Jul 2026

DPP Registry implementing act and first registry version

The DG GROW webinar timeline places the Central Registry implementing act in June 2026 and the first DPP Registry version becoming operational in July 2026, starting with batteries. Public onboarding, APIs and broader documentation still follow gradually. Source: DG GROW webinar presentation, 27 May 2026.

Q4 2026

Batteries access-rights implementing act expected

The webinar timeline places the implementing act on legitimate-interest access to restricted battery-passport data (Article 77(9), Annex XIII points 2 and 4) around Q4 2026, after the working document was circulated to the Battery expert group on 29 April 2026. Working principles: limited sharing, no publication. Source: DG GROW webinar presentation, 27 May 2026.

18 Feb 2027

Battery passport obligations apply

Passport requirements apply to EV batteries, industrial batteries above 2 kWh and all LMT batteries (regardless of capacity).

18 Aug 2027

Battery due diligence obligations apply (postponed by Reg. 2025/1561)

Regulation (EU) 2025/1561 postponed Article 48 supply-chain due diligence for cobalt, lithium, natural graphite and nickel from 18 August 2025 to 18 August 2027. Commission guidelines are due by 26 July 2026, aligned with CSDDD.

2027–2030

Passport operations move from launch to auditability

After go-live, the challenge becomes maintaining accurate passport records across design changes, batch changes, imported cells or modules, and downstream service events. For many companies, this is where governance becomes more difficult than initial publication.

2031

Recycled content targets tighten

Mandatory recycled-content thresholds for cobalt, lead, lithium and nickel further increase the need for traceable and auditable battery data.

Official Sources

European Commission, DG GROW

DG GROW DPP webinar presentation, 27 May 2026

The webinar sets out the battery passport timeline (18 February 2027), the DPP registry milestones (June–July 2026) and the access-rights implementing act (Q4 2026).

What must the battery passport contain?

66 attributes · 8 clusters

Battery chemistry (cathode, anode, electrolyte) Public
Detailed composition breakdown (cathode, anode, electrolyte, separator) Interested parties*

Details

Annex XIII point 2 requires more detailed composition data than the public chemistry summary. The restricted view should identify the main battery components and active materials needed by operators with a legitimate interest.
Spare-part / replacement-component references Conditional Interested parties*

Conditional

Required where the battery design includes replaceable spare parts or equivalent service components. Annex XIII expects part numbers and relevant contact details for those items.
Critical raw materials present (cobalt, lithium, nickel, natural graphite, manganese) Public

Details

Mass in kg per material. All critical raw materials present above the de minimis threshold must be reported. The list of critical raw materials follows Annex II of Regulation (EU) 2024/1252 (Critical Raw Materials Act).
Hazardous substances present (other than mercury, cadmium, lead) Public

Details

The public passport should disclose hazardous substances present in the battery other than mercury, cadmium and lead, as specified in Annex XIII. This field should not be reduced automatically to REACH Article 33 threshold logic alone.
Recycled content: cobalt share (%) Public

Details

Percentage of recycled cobalt in active material by mass. Minimum thresholds per Art. 8: 16% from 18 August 2031, 26% from 18 August 2036. Calculated using post-consumer recycled content methodology per Commission delegated act.
Recycled content: lithium share (%) Public

Details

Percentage of recycled lithium in active material by mass. Minimum thresholds per Art. 8: 6% from 18 August 2031, 12% from 18 August 2036.
Recycled content: nickel share (%) Public

Details

Percentage of recycled nickel in active material by mass. Minimum thresholds per Art. 8: 6% from 18 August 2031, 15% from 18 August 2036.
Recycled content: lead share (%) Public

Details

Percentage of recycled lead by mass. Minimum threshold: 85% (carried over from existing Directive 2006/66/EC requirements). This is a recycled-content minimum for the lead used in the battery. It is unrelated to the separate 0.004% lead-content labelling threshold under Art. 13(4) in the conformity cluster.
Renewable content share (if applicable) Conditional Public

Conditional

Only required if the battery contains bio-based or renewable materials in its composition. Not required for purely mineral-based chemistries.

Due diligence policy information Conditional Public

Conditional

Required once the operator and battery materials fall within Art. 48–52 due-diligence scope. Until then, the passport can keep the field as a placeholder.

Details

A description of the due diligence policy applied by the economic operator, including the human rights, environmental and governance risks addressed within the battery supply chain. Must reference Art. 48–52 of Regulation (EU) 2023/1542 and applicable OECD Due Diligence Guidance. The passport starts on 18 February 2027, but Art. 48 applies from 18 August 2027; the Commission webinar clarifies that cross-referenced fields may remain empty where the underlying obligation or material scope does not apply.
Third-party supply chain audit report (summary) Conditional Interested parties*

Conditional

Required once due-diligence verification/reporting obligations apply; the Commission webinar states that the due diligence report must be included by the latest August 2028.

Details

Restricted endpoint should return only the legally required summary/evidence view. Full supplier names, geographies and risk assessments belong in the authority view under the Data Shadowing pattern once the report is due.
Responsible sourcing information Conditional Interested parties*

Conditional

Applies where cobalt, lithium, nickel or natural graphite due-diligence scope is triggered.

Details

Information on measures taken to ensure responsible sourcing of raw materials, including procedures for identifying, assessing and mitigating risks in the supply chain for cobalt, lithium, nickel and natural graphite.
Third-party assurances and laboratory certifications Conditional Authorities

Conditional

Required when third-party verification or certification evidence is part of the applicable due-diligence route.
Full due diligence report (supplier names, audit details) Conditional Authorities

Conditional

The passport system should support the report structure, but the DG GROW webinar places inclusion of the due diligence report by the latest August 2028 rather than as full public passport content on 18 February 2027.

Details

Contains commercially sensitive data including supplier identities, pricing, sourcing geographies and risk-mitigation measures. Accessible only to notified bodies and market surveillance authorities via authenticated, role-verified access token per Art. 77 once the reporting obligation applies.

Rated capacity (Ah) Public

Details

Initial rated capacity in ampere-hours (Ah), measured at beginning of life under manufacturer-defined reference conditions: temperature 25 ± 2°C, C-rate as specified (typically C/3 for EV, C/5 for industrial), with defined cut-off voltages for charge and discharge. For EV batteries: test per IEC 62660-1. For stationary/industrial: per IEC 61427-2. Test must use new, fully formed cells after manufacturer-specified conditioning cycles.
Voltage limits (minimum / nominal / maximum, V), with temperature ranges where relevant Public

Details

Annex XIII (1)(h) requires minimum, nominal and maximum voltage to be reported. Temperature ranges are reported alongside these values only where relevant, i.e. where voltage behaviour is temperature-dependent in the battery’s operating envelope. Minimum voltage is the lowest voltage at which the battery may be safely discharged, nominal voltage is the characteristic voltage under standard load, and maximum voltage is the upper limit for safe charging.
Power limits (original power / peak power, W), with temperature ranges where relevant Public

Details

Annex XIII (1)(i) requires the original power capacity and the power limits to be reported. Temperature ranges are reported alongside these values only where relevant. Continuous (rated) power and short-duration peak power at beginning of life under reference conditions. For EV: measured per IEC 62660-2.
Expected battery lifetime (cycles and/or years) Public

Details

The number of complete charge-discharge cycles and/or calendar years the battery is expected to remain above its end-of-life capacity threshold. Test parameters: depth of discharge (DoD), typically 80% for EV; charge/discharge C-rate as specified by manufacturer; temperature 25 ± 2°C. End-of-life defined as capacity falling below the exhaustion threshold (typically 80% of rated capacity). For EV: test profile per IEC 62660-1 or manufacturer-defined representative cycle. For stationary: per IEC 61427-2.
Capacity threshold for exhaustion (%) Conditional Public

Conditional

Annex XIII (1)(k) restricts this passport field to electric-vehicle batteries only. It is not a passport requirement for LMT, SLI, portable, stationary or industrial batteries.

Details

For EV batteries: the percentage of initial rated capacity below which the battery is considered to have reached end of life. Typically set at 80%, though the manufacturer may specify a different value if justified.
Initial round-trip energy efficiency (%) Public

Details

Ratio of energy discharged to energy charged in one complete cycle at beginning of life. Measured under reference conditions: 25 ± 2°C, at manufacturer-specified C-rate, between defined voltage limits. For EV batteries: per IEC 62660-1 energy efficiency procedure. Higher values indicate less energy lost as heat.
Internal resistance, initial value (milliohms) Public

Details

Measured at beginning of life at 50% State of Charge (SoC), temperature 25 ± 2°C. Method: DC internal resistance (DCIR): ratio of voltage change to current change during a defined current pulse (typically 10s), or AC impedance at 1 kHz (ACIR). Both pack-level and cell-level values must be reported where applicable.
Operating temperature range (°C) Public
Storage temperature range (°C) Public
Commercial warranty period for calendar life Public

Details

Commercial calendar-life warranty offered for the battery model. If no commercial warranty beyond statutory guarantees is offered, the passport should make that absence explicit.
C-rate of the relevant cycle-life test Public

Details

Charge/discharge rate used in the reference cycle-life test linked to the expected lifetime parameter, so the published durability value can be interpreted consistently.

Public Interested parties* Authorities BMS data Measurement context

Tiered Data Access (Art. 77)

Battery passport data is not equally visible to all parties. Under Art. 77 of Regulation (EU) 2023/1542, the same data attribute may return different content depending on who requests it. The general public sees summary information, while market surveillance authorities can access full reports including commercially sensitive details.

Attribute	Public	Authorities
Due diligence report	Summary statement and policy URL	Full audit report with supplier names, prices and sourcing details
Test reports	Conformity declaration reference	Complete test results with laboratory data
Negative events log	Not visible	Full incident log for authorities and legitimate-interest operators

* "Interested parties" (Art. 77) covers persons with a legitimate interest, including independent repairers, remanufacturers, second-life operators and recyclers. The legal deadline for access-rights implementing acts is 18 August 2026; the DG GROW webinar timeline points to Q4 2026 adoption, so both dates should be tracked.

** BMS = Battery Management System. Dynamic attributes are updated over the battery lifecycle via on-board telemetry (OTA) or at service events.

*** Each recycled-content percentage denotes the share of recycled feedstock within that specific material (e.g. "16% cobalt" means 16% of the cobalt used is post-consumer recycled cobalt). These are independent ratios per substance, not shares of total battery mass, so they do not sum to 100%.

**** Source labels (e.g. ERP, BMS, LCA) indicate which enterprise system typically holds each data cluster. They are architectural guidance for IT integration, not regulatory requirements.

Which Batteries Are Covered?

Under Regulation (EU) 2023/1542, the battery passport is relevant in particular for:

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

Note: Traditional automotive starter batteries (SLI batteries) are exempt from the Art. 77 digital passport. They must still carry a QR code with basic information (declaration of conformity, collection info, capacity) per Art. 13(5) of the Regulation.

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