The answer in 40 seconds: Suppliers do not have to create a battery passport of their own. But a large share of the mandatory data comes from the supply chain: material composition, carbon footprint, recycled content, sourcing and the technical parameters of the cells. The passport obligation starts on 18 February 2027; customers will request the data before that.
Why Suppliers Are Affected
From 18 February 2027, every electric vehicle battery, every LMT battery (e-bikes and e-scooters, regardless of capacity) and every industrial battery above 2 kWh placed on the EU market needs a battery passport (Article 77(1) of the EU Battery Regulation (EU) 2023/1542). Responsible is the manufacturer or importer placing it on the market: they must ensure the information is accurate, complete and up to date (Article 77(4)) and upload the identifier to the EU registry for the digital product passport (Article 77(10)).
Often overlooked: a vehicle manufacturer does not know the composition of the installed cells in detail. Where the cobalt comes from, what carbon footprint the cathode has and how much recycled material the anode contains is known only to the supplier. Exactly that is what Annex XIII requires as passport content. One manufacturer summed it up for us: the real work is collecting the data from suppliers.
So the task for suppliers is not “create a passport” but deliver structured data, in the format the customer needs. That sounds simpler than it is: the information is extensive, granular and must be verifiable.
What Data Battery Passport Suppliers Must Deliver
Annex XIII of the Battery Regulation lists the mandatory passport content. Five blocks of it typically come from the supply chain:
Material composition: chemistry, hazardous substances (other than mercury, cadmium and lead) and critical raw materials above 0.1 % by weight (Annex XIII point 1(b), Annex VI Part A points 8 and 10). This information is public in the passport. DPP Hero captures name, mass, component and CAS number (the international substance identifier) for each material.
Responsible sourcing: information from the due diligence report (Annex XIII point 1(d), Article 52(3)). The supply chain due diligence obligations apply from 18 August 2027 (Article 48, postponed by Regulation (EU) 2025/1561).
Recycled content (share of recovered raw materials): From 18 August 2028 or 24 months after the still outstanding delegated act, a supplementary Commission rule (the later date applies), industrial batteries above 2 kWh, electric vehicle and SLI batteries containing cobalt, lead, lithium or nickel need documentation showing, per model, year and plant, the share recovered from battery manufacturing waste and from post-consumer waste (Article 8(1)). From 18 August 2031, minimum shares apply: 16 % cobalt, 85 % lead, 6 % lithium and 6 % nickel (Article 8(2)). The passport shows this information publicly (Annex XIII point 1(e)).
Carbon footprint: The carbon footprint declaration is drawn up per battery model and manufacturing plant, in kg CO₂ equivalent per kWh of the total energy provided over the service life, broken down by life cycle stage (Article 7(1)). Cell manufacturers supply the values of their production. The method is set by the Commission in a delegated act; for electric vehicle batteries it was due by 18 February 2024 and is still missing (as of 16 October 2026).
Technical parameters: rated capacity in Ah, voltages, power capability, lifetime in cycles with the reference test, and the internal resistance of cell and pack (Annex XIII point 1(g) to (p)).
Data Requirements by Supplier Type
Requirements depend on the position in the value chain:
| Supplier Type | Core Data | Key Considerations |
|---|---|---|
| Cell manufacturer | Cell chemistry, material composition, CO₂ values of production, rated capacity, voltages, internal resistance, cycle life | Largest data scope; must involve its own upstream suppliers |
| Raw material supplier | Origin and due diligence documentation, recycled content, purity grades | Cobalt, lithium, nickel and lead are covered by Article 8; due diligence from 18 August 2027 |
| Electronics supplier (battery management) | Part numbers, contact details for spare parts, hazardous substances in assemblies | Passport content with restricted access (Annex XIII point 2(b)) |
| Housing and mechanical supplier | Material composition, weight, dismantling information (exploded diagram, disassembly sequence, tools) | Dismantling information is mandatory content (Annex XIII point 2(c)) |
If this data is missing, your customer's passport is incomplete and they may not place the battery on the market. They are liable for that, not you (Article 77(1) and (4)). That is why manufacturers will secure data delivery contractually.
How Manufacturers Request Data
The regulation addresses the manufacturer or importer placing the battery on the market. They may authorise others in writing (Article 77(4)) but remain responsible. The data obligation therefore ends up as a clause in the supply contract: which data points, which format, by when.
There is a template for the format. The DIN SPEC 99100 describes the data structure of the battery passport in seven categories, and for the technical interface there is the standard EN 18222 (DIN EN 18222:2026-09). Suppliers who keep their data along this structure deliver to any customer without re-sorting; Excel lists cannot be checked automatically against the mandatory fields.
Large suppliers with their own IT often go through data spaces. The automotive industry's data network Catena-X has issued an invitation to a battery passport scenario as an industry test; in February 2026 BMW and CATL announced pilot projects for data exchange via Catena-X.
For small and medium-sized suppliers a data space is usually too big. Here an access through which the supplier enters their own section is enough: in DPP Hero the share link.
DPP Hero's Share-Link Feature
DPP Hero is battery passport software based on DIN SPEC 99100 with which manufacturers and importers create passports in seven steps (see the guide). For suppliers there is the share link, available from the Business plan.
Here is how it works: The manufacturer generates a time-limited link for one data section, for example only material composition, and sends it to the supplier. The supplier opens it in the browser and enters their data directly, without an account, without installation and without access to the manufacturer's other data.
The supplier needs neither a DPP Hero account nor a license. The manufacturer determines which data section the supplier can view and edit; the fields follow the DIN SPEC 99100, so the supplier does not need to know the data model. The entries land directly in the manufacturer's passport.
With a view to the costs of the battery passport, this is the cheapest option for suppliers: the effort is limited to data entry. Anyone who places batteries on the market themselves can test the process on one product with a free account; the plans are on the pricing page.
Timeline and Deadlines
Several dates depend on Commission acts that are still missing; then the later date applies. As of 16 October 2026, checked in the register of the Publications Office of the EU:
| Date | Requirement | Relevance for Suppliers |
|---|---|---|
| 18 February 2027 | Battery passport for electric vehicle, LMT and industrial batteries above 2 kWh (Article 77(1)) | All suppliers must be able to deliver their data |
| 18 August 2027 | Supply chain due diligence (Article 48) | Raw material suppliers deliver origin and risk documentation |
| 18 August 2028 or 24 months after the delegated act | Recycled content documentation (Article 8(1)) | Cell manufacturers and raw material suppliers document recycled shares |
| 18 August 2031 | Minimum shares: 16 % cobalt, 85 % lead, 6 % lithium, 6 % nickel (Article 8(2)) | Suppliers with too little recycled content drop out of the selection |
| open (Article 7) | Carbon footprint declaration for electric vehicle batteries: 18 February 2025 or twelve months after the method and format acts; performance class: 18 August 2026 or 18 months after; in each case the later date, both acts still missing | Cell manufacturers prepare CO₂ data per plant |
For suppliers this means: do not wait for 2027. Manufacturers pass on their requirements beforehand. Those who can deliver early stay in the supplier pool.
7 Steps to Prepare as a Battery Passport Supplier
If you supply battery components or raw materials, prioritize these steps:
- Take a data inventory: which of the Annex XIII data do you already capture today? Typical gaps are CO₂ values per plant, origin of raw materials and recycled content.
- Define who captures, maintains and approves which data.
- Read DIN SPEC 99100 and EN 18222: which fields are mandatory, which formats are expected?
- Collect CO₂ data per plant. The method will come in a delegated act; you will need the production data behind it in any case.
- Document your supply chain with origin documentation for your raw materials and risk assessments from your upstream suppliers.
- Check whether your business software (ERP, PLM) can export the data and whether a share link is enough or it takes a data space.
- Clarify with your customers which data is expected, when and in which format.
FAQ
Do suppliers need to create their own battery passport?
No. The passport is created by the manufacturer or importer placing the battery on the market (Article 77(1)). Suppliers deliver the data on their components and materials: via an agreed format, a share link or a data space.
What happens if I, as a supplier, do not deliver data?
The regulation sanctions the operator placing the battery on the market, not you. Without your data their passport is incomplete and they may not place the battery on the market. For you the consequences are contractual: follow-up demands, penalties or loss of the order.
Is my data publicly visible in the battery passport?
Partly. Material composition, carbon footprint, recycled content and sourcing information are public (Annex XIII point 1). The detailed composition of cathode, anode and electrolyte, part numbers, spare part contacts and dismantling information are visible only to persons with a legitimate interest and the Commission (point 2). Test reports are visible only to notified bodies (designated testing bodies), market surveillance authorities and the Commission (point 3).
How does DPP Hero support suppliers specifically?
Through the share link: your customer sends you a link to exactly the data section you contribute. You enter your values in the browser, without an account, without software and without learning the data model.
How do I protect formulations and supplier relationships?
The detailed composition and the supplier contacts are open only to persons with a legitimate interest. Who that is will be set by the Commission in an implementing act that was due by 18 August 2026 and is still missing (Article 77(9)). Clarify the required level of aggregation with your customer and cover the rest with a non-disclosure agreement.
Sources
- Battery Regulation (EU) 2023/1542: Articles 7, 8, 48, 52 and 77 and Annexes VI and XIII
- Regulation (EU) 2025/1561: postponement of the due diligence obligations to 18 August 2027
- Catena-X: invitation to the battery passport scenario
- Battery-News, 27 February 2026: BMW and CATL agree pilot projects for battery data exchange
As of 16 October 2026, checked against the text of the Battery Regulation (EU) 2023/1542 and the register of acts based on it at the Publications Office of the EU. Not legal advice.
