The answer in 40 seconds: No, nobody can register a battery passport with the EU today, not even a service provider. On 4 August 2026 the European Commission confirmed to us that the semantic catalogue and the registry APIs are planned for Q4 2026, and that the rules for service providers will only come with a separate legal act, which the Commission expects to be adopted around Q2 2027. The passport obligation itself remains 18 February 2027.
The short answer: nobody can do this today
The question comes up in almost every conversation: do I have to register my battery passports with the EU myself, or will my software provider handle it?
The honest answer in August 2026 is: neither, because it simply is not possible yet. The EU's central DPP registry has been online since 20 July 2026, but the battery product group is locked. The Commission's official user guide states plainly that the semantic catalogue for this product group has not yet been defined and that successful registration is therefore not currently possible.
If a provider promises you today that they already register your passports with the EU, that is not true. It is a useful first test of how carefully a provider reads its sources.
What the European Commission wrote to us on 4 August
Because there is a lot of guesswork on this point, we sent four questions to the Commission's DPP Help Desk on 22 July 2026: when will the API documentation arrive, how does registration on behalf of a manufacturer work technically, how does a company become a verified service provider, and when will battery registration be enabled?
The reply arrived on 4 August 2026. Four points matter for manufacturers:
- Semantic catalogue and APIs: Q4 2026. The semantic catalogue and the registry APIs are planned for the fourth quarter of 2026, together with comprehensive technical documentation. Only after that can anyone register in an automated way.
- There is no list of verified service providers. And there is no procedure to be recognized as one. According to the Commission, neither is in place at this stage.
- The rules will come later. Requirements, criteria and permitted actions for service providers are to be set out in a delegated act, which the Commission expects to be adopted around the second quarter of 2027. In parallel it plans to roll out the corresponding registry functionality.
- The first passports are battery passports. They follow from the Battery Regulation as of February 2027, and that has not changed.
This information comes from a Help Desk reply to our inquiry. It is not a legal act and not legal advice, but it is the most recent official statement on these dates that we are aware of.
The gap almost nobody talks about
One sentence from the reply deserves particular attention. The Commission points out a difference between the Battery Regulation and the Ecodesign Regulation: the digital product passport service provider does not appear as a defined actor in the Battery Regulation at all.
The term “digital product passport service provider” is defined in the Ecodesign Regulation (EU) 2024/1781, and Implementing Regulation (EU) 2026/1778 expressly allows a third party to register on behalf of a verified economic operator. The Battery Regulation (EU) 2023/1542, which makes your passport mandatory from February 2027, does not know this role.
What does that mean in practice? It does not mean that working on behalf of a manufacturer is forbidden. It means the precise roles and rights of a service provider towards the manufacturer and the registry have not been written out yet and will only arrive with the upcoming legal acts. For you as a manufacturer the consequence is simple: responsibility for your passport stays with you, no matter who runs the technology. That Implementing Regulation says as much, stating explicitly that the economic operator remains liable even when a third party registers on their behalf.
The timeline you can plan with
- 6 August 2026: Implementing Regulation (EU) 2026/1778 becomes applicable. It governs the framework, not the battery content.
- Q4 2026: Semantic catalogue and registry APIs, according to the Commission with full documentation. This is when technical integration becomes real.
- 18 February 2027: The battery passport becomes mandatory for the affected battery types. No passport, no placing on the market.
- Around Q2 2027: Expected adoption of the legal act on service providers, with the matching registry functionality to follow.
Note the order: the passport obligation comes before the service provider rules. Your company therefore has to be able to act on its own in February 2027 and cannot rely on someone else being officially allowed to register for you by then.
What you can usefully prepare now
Waiting does not mean doing nothing. These four steps are possible today and pay off later:
- 1. Build your data foundation. In practice the passport rarely fails on technology, it fails on missing data: material composition, supply chain, carbon figures, safety information. That is manual work with suppliers and takes months. Our battery passport overview lists what is required in detail. Start there, not with the interface.
- 2. Understand verification. Only a verified economic operator may register. For companies that means a qualified electronic seal; a personal signature by the managing director is expressly not enough. Verification is valid for at most three years and must then be repeated.
- 3. Do not buy the seal too early. What a qualified seal costs differs widely by provider, term and format, so ask for a written quote instead of budgeting a rule of thumb. Important: the validity period starts at issuance, not at first use. Buying today burns months during which registration is blocked anyway. Instead, ask your provider now how long the application and identity check take, and time the purchase so the validity covers early 2027 onwards. Which providers are admissible at all is public information in the EU trusted list.
- 4. Assign responsibility. Decide internally who maintains the passport and who will trigger the later registration. Even if a service provider supplies the technology, you need a responsible person with access to your organization's EU Login. If you are comparing tools, our pages on battery passport software and digital product passport software set out what such a system has to cover.
How the passport is structured and which other deadlines apply is covered in when the battery passport becomes mandatory. The structure of the registry itself is explained in the EU battery passport registry, and what changed in July 2026 is in the EU DPP registry is live.
What you can hand over and what stays with you
Even with the act on DPP service providers still missing, it is already clear what a third party may do for you. The Battery Regulation settles that in two places.
The work transfers, the responsibility does not
Article 77(4) first names who is responsible: “The economic operator placing the battery on the market shall ensure that the information in the battery passport is accurate, complete and up to date.” Then comes the sentence that allows a division of labor: “It may give written authorisation to any other operator to act on its behalf.”
Two things matter here. First the form: written, not a hallway agreement. Second the limit: what transfers is the authority to act, not the responsibility for the result. If a service provider, a vehicle manufacturer or a remanufacturer maintains the condition data, you remain liable for it being right.
There is one exception, in paragraph 7: where a battery is prepared for re-use or repurposing, repurposed or remanufactured, the duty moves to whoever then places the changed battery on the market. A new passport comes into being, linked to the original one.
What a service provider may not do with your data
Article 78(c) provides that the passport data sits with the responsible economic operator or with operators acting on its behalf. Point (d) draws the line for those operators: they are “not authorised to sell, re-use or process such data, in whole or in part, beyond what is necessary for the provision of the relevant storage or processing services”. Point (e) requires the passport to remain available even if the responsible economic operator ceases to exist.
For product passports under the Ecodesign Regulation, Article 10(4) additionally requires a backup copy with an independent third-party provider; for the battery passport that explicit duty is not in the Battery Regulation, but you still owe the availability.
For a contract discussion that means: get the written authorisation, settle what happens to the data when the contract ends, and ask for a complete export before you sign.
Where the passport data sits, and what the registry sees of it
A common misconception: that the EU registry is a store for battery passports. It is not. It keeps a directory of identifiers, commodity code and a hash, not the passport content itself.
The content stays decentralised with the economic operator who owes the passport, or on the platform they use for it. That is exactly why the choice of provider is not a formality: they hold the data you must keep retrievable across the battery lifetime, and a switch only works if you can export it in full.
For your selection this means two things: ask in which format the data comes out, and who controls the address the printed QR code points to.
The third question for a provider is about access tiers. Annex XIII names four groups of information: publicly accessible model information (point 1), model information for persons with a legitimate interest and the Commission only (point 2), information for notified bodies, market surveillance authorities and the Commission only (point 3), and data on the individual battery for persons with a legitimate interest only (point 4). Article 78(f) requires that not only access but also entering, modifying and updating is restricted accordingly, and Article 78(b) requires access to stay free of charge. So ask concretely: does the system separate these tiers technically, who is allowed to write, and what happens to a field whose tier the implementing act moves tomorrow? Which entry sits on which tier is covered in Battery passport data and access rights.
Selling into several markets: registration outside the EU
EU registration is not the only one that can apply to you. If the same battery also goes to Great Britain, the United States or China, you meet separate systems there that have nothing to do with the battery passport and do not replace it.
- United Kingdom: whoever first places batteries on the UK market counts as the producer under the Waste Batteries and Accumulators Regulations 2009. You must record the tonnage and chemistry of what you place on the market and report it annually. Place more than one tonne of portable batteries a year and you must join a Battery Compliance Scheme, which handles registration for you. This is a waste and take-back duty, not a data passport.
- United States: there is no federal battery registration, only rules per state. California sets the benchmark: the Responsible Battery Recycling Act of 2022 requires producers, individually or through a stewardship organization, to fund a take-back program. The department publishes a list of compliant producers and their brands, and once a program is approved, retailers, importers and distributors may only sell batteries from listed producers. From 1 January 2027 recycling efficiency rates of 60 percent for rechargeable and 70 percent for primary batteries apply there.
- China: since 1 April 2026 the interim measures issued by MIIT and five other bodies govern the recycling and utilization of traction batteries. Every traction battery receives a digital identity, and a national traceability platform collects data on production, installation, sale, retirement and recycling. The idea resembles the passport, but the duties and data fields are its own.
For other target markets the rule is: check the current position before you export, and do not rely on summaries. In practice this means keeping the data clean and machine-readable once, then serving it differently per market. Maintain it only in the shape one portal demands and you will build the same work again for the next one.
Three questions to test any provider
Because the legal situation is unfinished, a lot is being promised right now. These three questions separate solid statements from marketing:
- “Do you already register my passports with the EU?” Any answer other than a clear no is wrong. Battery registration is locked.
- “Are you a verified DPP service provider?” Nobody can be one at the moment, because neither the list nor the procedure exists. A provider claiming this has not read the source.
- “Is your system certified?” There is no seal and no certificate for the battery passport, not even for the relevant standards. The honest formulation is that a system is built to the standards, with evidence in detail.
We hold ourselves to the same rule: with DPP Hero you can create, check, publish and export your battery passports today. We will build the connection to the EU registry once the Commission has published the interface, and not a day earlier, because until then nobody knows what it looks like. If you want to start on the data now, create a free account and build your first passport.
Frequently asked questions
Can my software provider register the battery passport for me?
Not today, because battery registration in the EU registry is locked. Legally, registration on behalf of a manufacturer is foreseen; practically, both the recognition of service providers and the technical interface are still missing. According to the Commission, both will come later.
When can I register my battery passports?
According to the European Commission's reply of 4 August 2026, the semantic catalogue and the APIs are planned for Q4 2026. The Commission does not give an exact date. The passport obligation itself starts on 18 February 2027.
Do I have to verify my company with the EU myself?
Yes. Verification is tied to your organization and runs through a qualified electronic seal. A service provider can guide you through it, but cannot provide the proof on your behalf.
Is it worth buying the seal now?
Usually not. Validity starts at issuance, and months would pass unused before registration is even enabled. It is more sensible to ask your provider about processing times now and to time the purchase so that validity covers early 2027 onwards.
What happens if I have no passport on 18 February 2027?
Then the affected batteries may not be placed on the market. The obligation applies to the manufacturer or importer, not to the software provider.
What a notified body checks, and what it does not
Alongside the service provider for passport data sits a second role that should not be confused with it. Under Article 17 the notified body carries out the conformity assessment procedure for the battery. And under Article 48(2) in conjunction with Article 51 it verifies the supply chain due diligence policy; without that verification the policy is not complete.
What the notified body does not do: it does not confirm the content of your battery passport. Responsibility for its correctness, completeness and currency stays with the economic operator placing the battery on the market, under Article 77(4). A notified body certificate is therefore not a passport seal, and anyone selling it as one is promising something that does not exist.
For choosing a service provider that means: do not ask for a passport certification that does not exist, ask how they support you in your own responsibility. So: how do corrections reach the passport? Who can trigger changes? And what happens to the data if you switch providers?
Sources
- Battery Regulation (EU) 2023/1542, Article 77 and Annex XIII govern the battery passport
- Implementing Regulation (EU) 2026/1778 on the registry, applicable from 6 August 2026
- The Commission's DPP registry with user guide and test environment
Status: 4 August 2026. Based on the official sources (Battery Regulation (EU) 2023/1542, ESPR (EU) 2024/1781, Implementing Regulation (EU) 2026/1778, the Commission's registry user guide) and on a reply from the European Commission's DPP Help Desk of 4 August 2026 to our inquiry. Dates the Commission describes as planning are not a commitment. This is not legal advice.
