Why You Should Prepare Now
From February 18, 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:
- Identification (manufacturer, GTIN, serial number, manufacturing facility)
- Materials and composition (chemistry, hazardous substances, critical raw materials)
- Carbon footprint (total value per kWh, lifecycle phases)
- Due diligence (supply chain audits, risk assessments)
- Circularity (disassembly, recycling rates, spare parts)
- Performance and durability (capacity, cycles, internal resistance, dynamic BMS data)
- 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 40–60% of 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 6–12 months for this.
Step 6: Calculate Your Carbon Footprint
The carbon footprint is one of the most demanding data requirements. Since August 2025, carbon footprint declarations for EV and industrial batteries are already mandatory. You must:
- 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. 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 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
- February 18, 2027: Mandate takes effect
For a detailed overview of all regulatory deadlines, see our article EU Battery Regulation 2027: Timeline and Obligations.
Frequently Asked Questions
How long does battery passport implementation take?
Depending on company size and data maturity, expect 6–12 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 February 18, 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 — only for specialized tasks like LCA calculation (carbon footprint) might external expertise be helpful.
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.