Battery Passport Checklist: 10 Steps for 2027

Why You Should Prepare Now

From 18 February 2027, EV batteries, industrial batteries (> 2 kWh), and LMT batteries cannot be placed on the EU market without a valid battery passport. While this may sound like sufficient time, it isn't. Data collection, supply chain coordination, and technical implementation require months of lead time.

Manufacturers who wait until 2027 risk market access blocks, recalls, and fines. Those who start today gain a decisive competitive advantage, both in terms of regulatory readiness and toward customers who increasingly use transparency as a purchasing criterion.

Step 1: Check If Your Batteries Are Affected

Not all batteries fall under the battery passport requirement. The following are covered:

• Electric vehicle batteries (EV): Traction batteries for e-cars, e-motorcycles, quads
• Industrial batteries > 2 kWh: Stationary storage, UPS systems, energy storage systems
• LMT batteries: Batteries for e-bikes, e-scooters, e-wheelchairs, and similar light means of transport

Not affected: Portable batteries (AA, AAA), conventional starter batteries (SLI), and industrial batteries below 2 kWh. If you're unsure whether your product is covered, read our Battery Passport vs. Digital Product Passport comparison.

Step 2: Clarify Responsibilities

The economic operator who places the battery on the EU market is responsible for the battery passport. This can be:

• Manufacturer: If you produce batteries yourself and sell them in the EU
• Importer: If you import batteries from third countries into the EU
• Authorized representative: If a non-EU manufacturer designates you as their representative

Clarify early who in your organization or supply chain has data ownership over the battery passport. For complex supply chains, consider appointing a dedicated battery passport coordinator.

Step 3: Familiarize Yourself with the Data Standard

The DIN DKE SPEC 99100:2025-02 defines the battery passport data structure across seven categories:

1. Identification (manufacturer, GTIN, serial number, manufacturing facility)
2. Materials and composition (chemistry, hazardous substances, critical raw materials)
3. Carbon footprint (total value per kWh, lifecycle phases)
4. Due diligence (supply chain audits, risk assessments)
5. Circularity (disassembly, recycling rates, spare parts)
6. Performance and durability (capacity, cycles, internal resistance, dynamic BMS data)
7. Labeling and conformity (CE, EU declaration of conformity)

Specialized software like DPP Hero already maps the entire DIN SPEC 99100 data structure, all seven categories with mandatory fields and validation. You don't need to read or interpret the specification yourself; instead, you're guided step by step through the data entry process.

Step 4: Conduct a Data Audit

Before selecting a tool, you need to know which data you already have and what's missing. Create a gap analysis:

• Available: Product names, GTIN, rated capacity, voltage: this data usually exists in ERP or PLM systems
• Partially available: Material composition, supplier information: often scattered across departments
• Typically missing: Carbon footprint per kWh, recycling rates, disassembly instructions, due diligence reports

Many manufacturers discover during the data audit that a large part of the required data already exists, but is scattered across spreadsheets, PDFs, and email attachments. Our article From Excel to Battery Passport shows how to consolidate this data.

Step 5: Engage Your Supply Chain

Many battery passport data points, particularly on materials, carbon footprint, and due diligence, don't come from your own company but from suppliers. Start early:

• Identify Tier-1 and Tier-2 suppliers for critical raw materials (cobalt, lithium, nickel)
• Request material declarations and carbon data
• Establish standardized data formats for exchange
• Use tools with supplier share features to involve suppliers directly

The biggest delay in battery passport implementation is typically not the technology, but data procurement from the supply chain. Plan at least 6 to 12 months for this.

Step 5b: work out whether the due diligence duties apply to you at all

Step 5 collects the supply chain data. Whether you have to meet the full due diligence duties of Articles 48 to 52 is decided by a turnover threshold. Article 47 excludes economic operators that “had a net turnover of less than EUR 40 million in the financial year preceding the last financial year and that are not part of a group ... exceeding the limit of EUR 40 million on a consolidated basis”. Also excluded are batteries that were already on the market before being prepared for re-use, repurposed or remanufactured.

The date is 18 August 2027: Article 48 originally applied from 18 August 2025, and Regulation (EU) 2025/1561 moved it by two years. Above the threshold, plan for the policy, the verification by a notified body and the annual report under Article 52(3). Below it, you can skip that block, but you still need the due diligence report as a passport field once your supplier delivers it.

Step 6: Calculate Your Carbon Footprint

The carbon footprint is one of the most demanding data requirements. The fixed dates in Article 7 of the EU Battery Regulation have passed (18 February 2025 for EV batteries, 18 February 2026 for industrial batteries over 2 kWh), but the declaration only applies twelve or eighteen months after the delegated methodology act and the implementing format act, whichever date is later. Neither act has been adopted (as of 20 August 2026), so the duty has not been triggered yet. Prepare the figures now:

• Calculate the carbon footprint per kWh across the full lifecycle
• Cover four phases: raw material acquisition, production, distribution, end-of-life
• Perform calculations according to EU-defined methodologies

For details on calculation methods and thresholds, see our article Carbon Footprint in the Battery Passport. If you lack in-house LCA expertise, consider engaging a specialized consultant.

Step 7: Choose a Suitable Tool

A battery passport cannot be effectively managed in Excel: the complexity of the data structure, update obligations, and technical requirements (QR codes, machine-readable formats) demand a specialized software solution.

When selecting a tool, look for:

• DIN SPEC 99100 data structure: Are all 7 categories and mandatory fields covered?
• Export formats: JSON export for machine processing, PDF for documentation
• QR code generation: Automatic creation with link to hosted product page
• Supplier integration: Share links or access for supply chain partners
• Access rights: Distinction between public, authority, and restricted data

Tools like DPP Hero provide the DIN SPEC 99100 data structure out of the box; you can start entering data immediately without months of setup.

Step 8: Plan the QR Code and Data Carrier

Every affected battery must carry a machine-readable data carrier, in practice, a QR code linking to the digital battery passport. The recommended standard is GS1 Digital Link. Keep in mind:

• The QR code must be permanently and legibly attached to the battery or housing
• It links to a hosted product page with the passport data, not to a centralized EU database
• Each individual battery receives its own QR code with a unique serial number
• The hosting solution must remain accessible throughout the battery's entire lifespan

Coordinate early with your production and packaging teams to integrate the QR code into existing labeling processes.

Step 8b: check the labeling that does not hang on the passport

The QR code from step 8 is not the only labeling duty, and two of them have their own dates. A 2027 checklist should carry both, because the preparation happens in the same production process.

• Separate collection symbol: already applies. Since 18 August 2025 all batteries carry the symbol under Article 13(4) together with Annex VI Part B. It has to take up at least 3 percent of the largest side, no more than 5 by 5 cm; cylindrical cells have their own rule. Check that your running production meets this before you think about 2027.
• General labeling: date set, duty not yet. Article 13(1) to (3) require the information under Annex VI Part A plus capacity and minimum average duration “from 18 August 2026 or 18 months after the date of entry into force of the implementing act referred to in paragraph 10, whichever is the latest”. That act has not appeared, so the duty is not triggered, but it will arrive with 18 months of lead time once it does. Keep the space on the label free.

Step 9: Run a Pilot Test

Before the mandate takes effect, create a pilot battery passport for a real product. This test run helps you:

• Identify data gaps early
• Validate the internal process from data collection to QR code
• Familiarize suppliers with the data delivery process
• Verify data quality and completeness

Ideally, start your pilot at least 6 months before the deadline, meaning no later than August 2026.

Step 10: Create Your Internal Timeline

Based on the previous steps, we recommend the following timeframe:

• Immediately (Q1/Q2 2026): Check scope, clarify responsibilities, read DIN SPEC
• Q2 2026: Conduct data audit, create gap analysis
• Q2/Q3 2026: Engage suppliers, calculate carbon footprint
• Q3 2026: Select and set up tool, enter initial data
• Q4 2026: Create pilot battery passport, test QR code integration
• Q1 2027: Buffer for corrections and optimizations
• 18 February 2027: Mandate takes effect

For a detailed overview of all regulatory deadlines, see our article EU Battery Regulation 2027: Timeline and Obligations.

Step 11: Keep the material duties that run in parallel in view

The passport is not the only deadline in the calendar. From 18 August 2031, Article 8(2) requires minimum shares of recovered material in industrial batteries above 2 kWh, electric vehicle batteries and starter batteries: 16 percent cobalt, 85 percent lead, 6 percent lithium and 6 percent nickel. Paragraph 3 raises those figures on 18 August 2036. Proof runs through the technical documentation under Annex VIII, per battery model, per year and per manufacturing plant.

Keep those separate from the rates that apply to recycling companies: Annex XII Part B sets recycling efficiencies, Part C the recovery of individual metals. What matters to you as a manufacturer is availability: without enough secondary material on the market, the recycled content shares cannot be met. If you sign supply contracts that run past 2031, fix the recycled share in them today.

Step 12: Prepare for verification and audit before the appointment

Passport data is not self-declaration. Annex VIII requires technical documentation from which the values follow, traceably per model, year and manufacturing plant. In practice that means three things: every figure needs a source, every source a date, and every change a trace of who made it and when.

So decide early in which format you keep evidence for verification and how you hand it as a test report to a notified body. A folder of PDFs without version status is worthless when an audit arrives. What works is a filing scheme per battery model holding the raw supplier data, the calculations on top of it, and the published passport state, each with a date.

Step 13: Plan the passport as a living record

Publication does not finish the passport. For stationary storage, LMT and electric vehicle batteries, Article 14(1) has required current condition data in the battery management system since 18 August 2024; it enters the passport through Annex XIII and changes over the battery lifetime. On top of that come status changes: a battery goes into re-use, is repurposed, or reaches end of life.

Before your first passport, therefore settle who updates the data later and where it comes from. The Regulation limits access, entry, modification and updating to the rights under Annex XIII and the act on Article 77(9). Assign these roles only after placing on the market and you end up with a passport nobody maintains.

Step 14: Budget for serialization as the real effort driver

The largest volume effect sits in a single sentence. From 18 February 2027, Article 77(1) requires a separate electronic record for every LMT battery, every industrial battery above 2 kWh and every electric vehicle battery placed on the market. Article 77(2) explicitly separates the battery model data from the data on the individual battery.

Ship 10,000 units a year and you need 10,000 passports, not one per model. You capture the model data once; serial number and QR code belong to each unit. Work out early where the serial numbers come from, whether they are already unique in your ERP, and how they reach passport creation: through a file, through the interface, or by hand. By hand does not scale.

Frequently Asked Questions

How long does battery passport implementation take?

Depending on company size and data maturity, expect 6 to 12 months. The biggest time drains are supply chain coordination and carbon footprint calculation. The purely technical setup in a specialized tool often takes only a few days.

What does battery passport implementation cost?

Costs vary widely: specialized SaaS tools like DPP Hero offer entry plans starting at €49/month. Large enterprise projects with blockchain integration, IoT connectivity, and ERP connectors can be significantly more expensive. For most SMEs, a SaaS approach is the most cost-effective solution.

Do existing batteries need a battery passport retroactively?

No. The mandate only applies to batteries first placed on the EU market from 18 February 2027. Batteries already on the market are not affected.

Can I create the battery passport myself, or do I need a service provider?

With a suitable software tool, you can create the battery passport yourself. You don't need an external service provider for data entry. External expertise may only be helpful for specialized tasks such as LCA calculation (carbon footprint).

What happens if I miss the deadline?

Batteries without a valid battery passport may no longer be sold in the EU. Violations can lead to market surveillance measures, sales bans, recalls, and fines. Specific sanctions are determined by EU member states.