Battery passport: what the EU still has to deliver

As of 24 September 2026. The battery passport becomes mandatory on 18 February 2027, yet several legal acts, standards and functions of the EU registry are still missing. This page lists what is outstanding, each item with its status and source and, where one exists, its legal deadline.

In brief

The obligation itself is settled. From 18 February 2027, batteries for electric vehicles, batteries for light means of transport such as e-bikes, and industrial batteries above 2 kWh need a battery passport when they are placed on the market or put into service in the EU. This is laid down in Article 77(1) of the Battery Regulation.

Much of what the Commission has to deliver for this is still outstanding. Nine statutory deadlines for legal acts have passed without the act appearing in the Official Journal. The oldest is the deadline for the method and format of the carbon footprint declaration for electric vehicle batteries: 18 February 2024. The EU registry is running but does not yet accept battery passports.

Outstanding legal acts

Here, legal acts means the regulations and decisions by which the Commission supplements the Battery Regulation. The first five items are set out with a deadline in the Battery Regulation; the sixth is based on the Ecodesign Regulation. None of these acts has been published in the Official Journal of the EU so far, as a query of its database CELLAR shows. The status of the drafts is shown on the Commission's consultation portal “Have your say”.

  1. Access rights: who has a legitimate interest (Article 77(9)). Deadline: 18 August 2026, passed. No draft has been published yet. The Commission plans adoption in the fourth quarter of 2026. Source: Have your say, initiative 16473.
  2. Labeling: uniform specifications for the label (Article 13(10)). Deadline: 18 August 2025, passed. The draft is dated 15 December 2025; feedback was possible until 26 January 2026. It has not been adopted yet. The labeling requirements under Article 13(1) to (3) apply only 18 months after it enters into force. Source: Have your say, initiative 14456.
  3. Recycled content: calculation and verification (Article 8(1)). Deadline: 18 August 2026, passed. The draft is dated 12 August 2026; feedback was possible until 9 September 2026. According to Have your say, adoption is planned for the third quarter of 2026; according to the WTO notification, for October 2026. Article 8 requires documentation on recycled content from 18 August 2028 at the earliest. Sources: Have your say, initiative 14858, WTO notification G/TBT/N/EU/1233.
  4. Carbon footprint: method, declaration, performance classes and maximum thresholds (Article 7). Deadlines for electric vehicle batteries: method and format of the declaration by 18 February 2024, performance classes by 18 February 2025, maximum thresholds by 18 August 2026. Deadlines for rechargeable industrial batteries without external storage: method and format by 18 February 2025, performance classes by 18 August 2026. All of them have passed. For method and format for electric vehicle batteries, there are only drafts dated 30 April 2024. For the performance classes for electric vehicle batteries and the method for industrial batteries, there is no draft yet; adoption is planned for the fourth quarter of 2026. The carbon footprint declaration for electric vehicle batteries becomes mandatory only twelve months after method and format enter into force (Article 7(1)). Sources: Have your say, initiatives 13877, 13878, 14312 and 14313.
  5. Performance and durability: minimum values for industrial batteries (Article 10(5)). Deadline: 18 February 2026, passed. No act has been published in the Official Journal. The deadline applies to rechargeable industrial batteries above 2 kWh, except those with exclusively external storage. For batteries for light means of transport, it runs until 18 February 2027. Source: Battery Regulation, Article 10(5).
  6. Requirements for digital product passport service providers (Ecodesign Regulation). No legal deadline. There is no act and no list of vetted service providers. Have your say gives the fourth quarter of 2026 for adoption, the Commission's timeline the second and third quarters of 2027. On 4 August 2026, the Commission's helpdesk wrote to us that service providers are not a separate actor under the Battery Regulation. Under Article 77(4), however, the operator placing the battery on the market may give any other operator written authorisation to act on its behalf. Sources: Have your say, initiative 14382, Commission page on the digital product passport.

The EU registry for product passports

The registry is based on Article 13 of the Ecodesign Regulation. The details are set out in Implementing Regulation (EU) 2026/1778. For batteries, Article 77(10) of the Battery Regulation requires the operator placing the battery on the market or putting it into service to upload the unique identifier there. We looked at the test environment ourselves on 24 September 2026, with our own account and without creating anything.

  1. The registry has been running since 20 July 2026. There is also a test environment. The Implementing Regulation has applied since 6 August 2026. Sources: Commission announcement of 20 July 2026, Commission page on the registry with links to the registry and the test environment.
  2. Battery passports cannot be registered yet. The Commission's user guide states: “Successful registration of DPPs for batteries is not currently available, as the semantic catalogue for this product group has not yet been defined.” It gives no date for the semantic catalogue. Source: Registry user guide, version 1.03 of 16 September 2026, chapter 6.2.1.
  3. An API has been announced but not described. The announcement of 20 July mentions registration via an API; the user guide only describes the online form and file upload. According to the helpdesk's reply to DPP Hero of 4 August 2026, the semantic catalogue and the APIs are due in the fourth quarter of 2026.
  4. The product identifier is a web address. Every passport needs a unique product identifier (UPI). It is a web address following the standards of the European standardization committee CEN/CENELEC JTC 24, at most 2000 characters long, and leads to the passport data. Source: Registry user guide, version 1.03, chapter 6.
  5. Sign-up currently requires a qualified signature or a qualified seal. According to the user guide, companies sign up with a qualified electronic seal and sole proprietors with a qualified electronic signature. Both are issued by a qualified trust service provider. Article 4 of the Implementing Regulation also names other electronic means; user guide 1.03 offers only the seal and the signature. In the test environment, verification works the same way: “The verification process used in the Test environment is the same as in Production.” Without a verified organization, the registry shows only the sign-up form and the Help Center. Sources: Registry user guide, version 1.03, chapters 4 and 8; Implementing Regulation (EU) 2026/1778, Article 4; our own inspection on 24 September 2026.
  6. Identifiers for economic operators have been announced. The registry's Help Center (version 1.0.12) lists the registration of “Unique Operator Identifiers (UOI)” as a topic of the user guide. User guide 1.03 does not cover it yet. Our own inspection on 24 September 2026.

Standards

Harmonised standards are European standards whose references the Commission publishes in the Official Journal. Anyone who complies with them is presumed to meet the corresponding requirements. Such standards already exist for the digital product passport. No standard specifically for the battery passport has been harmonised under the Battery Regulation so far.

  1. Six standards on the digital product passport, based on the Ecodesign Regulation. Implementing Decision (EU) 2026/1736 of 14 July 2026 lists EN 18216, EN 18219, EN 18220, EN 18221, EN 18222 and EN 18223. The presumption applies to Articles 10 and 11 of the Ecodesign Regulation. The decision creates no presumption for the Battery Regulation.
  2. First harmonised standard under the Battery Regulation. Implementing Decision (EU) 2026/2048 of 14 September 2026 lists EN 18060:2025 on the performance and durability of modules and batteries for electric vehicles. It does not include a standard specifically for the battery passport.
  3. Two further standards published, not yet harmonised. On 16 September 2026, CEN published EN 18239 on access rights, information security and confidentiality, and EN 18246 on authentication, reliability and integrity. The Commission has announced a decision on them. Sources: CEN/CLC/JTC 24 list of standards, Commission timeline.
  4. DIN EN 18222 published. The German edition DIN EN 18222:2026-09 has been published. Source: DIN Media.

Commission guidance

The Commission guidance on the data points of the battery passport is not binding: by its own account, it does not represent the official position of the Commission. Version 2.0 of 15 August 2026 defers fields. The carbon footprint declaration and the carbon footprint label remain empty until the act on the format is available. The recycled content shares (data points 20 to 23) also remain empty. Article 8 requires them for electric vehicle batteries and industrial batteries only from 18 August 2028 or 24 months after the act on the calculation method, whichever is later. For batteries for light means of transport, this applies only from 18 August 2033. Version 2.0 marks 46 data points as “Mandatory” for electric vehicle batteries, 49 for batteries for light means of transport and 32 for industrial batteries.

The registry user guide is available in version 1.03 of 16 September 2026. It describes sign-up and registration, but not yet a semantic catalogue for batteries.

What the EU has already delivered

For context: these legal acts and documents on the Battery Regulation are already in place. They concern manufacturers, importers or distributors. Acts addressed only to recyclers or to the member states are not listed here. We queried them in CELLAR on 24 September 2026.

  1. Ecodesign Regulation (EU) 2024/1781, 13 June 2024. Framework for the digital product passport; it also amends the Battery Regulation (EUR-Lex).
  2. Commission Notice on removability and replaceability, 10 January 2025. Guidelines for portable batteries and batteries for light means of transport (EUR-Lex).
  3. Regulation (EU) 2025/1561, 18 July 2025. Postpones the due diligence obligations under Article 48 to 18 August 2027 (EUR-Lex).
  4. Regulation (EU) 2026/1738, 8 July 2026. End-of-Life Vehicles Regulation; among other things, it amends the Battery Regulation (EUR-Lex).
  5. Implementing Decision (EU) 2026/2048, 14 September 2026. First harmonised standard under the Battery Regulation: EN 18060:2025 (EUR-Lex).
  6. Delegated Regulation C(2026) 5031, 14 July 2026. Exemptions from the removability and replaceability of portable batteries under Article 11; adopted by the Commission, not yet published in the Official Journal (Commission register of documents).

How we check, how to cite us

Every statement rests on a primary source. These are the Official Journal of the EU with its database CELLAR, the “Have your say” consultation pages and notifications to the WTO. They also include pages and documents of the Commission, the lists of standards of CEN and DIN Media, the German Federal Ministry for Digital Transformation and Government Modernisation and the registry itself. Some statements rest on a written reply from the Commission's helpdesk to DPP Hero; this is noted in each case.

We checked all statements against these sources on 24 September 2026. A second reviewer independently re-checked each of them. If anything changes, we add it with a date. The next event is the Commission webinar on 30 September 2026.

You are welcome to cite this overview. Suggested citation: “DPP Hero, Battery passport: what the EU still has to deliver, as of 24 September 2026, dpphero.com/en/battery-passport-implementation-status”.

Further reading

Our battery passport overview explains the basics, and the page on the digital product passport covers the framework for all product groups. What the registry requires of manufacturers is set out in the article on the EU battery passport registry; the timeline of the Ecodesign Regulation is shown in the article on the ESPR timeline. Technical terms are explained in the glossary.

Frequently asked questions

Does the battery passport obligation apply from 18 February 2027 even though legal acts are missing?

Yes, under the regulation as it stands today. Article 77(1) of the Battery Regulation sets 18 February 2027 without any condition. What is missing concerns individual contents. For example, the Commission's non-binding guidance defers the carbon footprint information until the act on the format is available. Article 8 requires the recycled content shares from 18 August 2028 at the earliest.

Can I already register battery passports in the EU registry?

No. According to the Commission's user guide, version 1.03 of 16 September 2026, the semantic catalogue for batteries needed for this is still missing. The user guide gives no date; on 4 August 2026, the Commission's helpdesk told us the fourth quarter of 2026.

What do I need to sign up for the EU registry?

An EU Login account. For the registry, EU Login requires a second factor, such as a passkey; that was the case when we signed in on 24 September 2026. In addition, you currently need a qualified electronic seal as a company, or a qualified electronic signature as a sole proprietor. With it, your legal representative signs or seals a declaration that the Commission has sealed beforehand. No software provider can take this step off your hands.

Is the qualified signature available free of charge?

In future, yes, at least for private purposes. The eIDAS Regulation requires every member state to offer all citizens a free qualified signature via the European Digital Identity Wallet. Member states may limit this for professional purposes. In Germany, the wallet “d-you” is due to launch in early 2027, according to the Federal Ministry for Digital Transformation and Government Modernisation; it is to support qualified signatures later.

May I cite this overview?

Yes, please do, stating the “as of” date and linking to this page. You will find a suggested citation in the section “How we check, how to cite us”.

Prepare your battery passports now

The obligation applies from 18 February 2027, even though the EU has not delivered everything yet. Create your battery passports now and add details as soon as the EU specifies them. Getting started is free.

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