Why You Should Create a Battery Passport Now
From 18 February 2027, EV batteries, industrial batteries above 2 kWh, and LMT batteries may no longer be placed on the EU market without a valid digital battery passport. This requirement stems from the EU Battery Regulation (EU 2023/1542).
Practical help with implementation: DIN SPEC 99100 software guides you through all seven data categories as a guided workflow.
The timeline may seem generous, but it is not. Creating a battery passport requires coordinating with suppliers, documenting materials, calculating the carbon footprint, and integrating all data into a standardized format. In practice, manufacturers need 6 to 12 months of lead time.
Starting today secures your market access and allows you to present a complete product dataset to customers right away. For a detailed timeline of all regulatory milestones, see our article on the EU Battery Regulation 2027.
How to Create Your Battery Passport in 7 Steps
DIN SPEC 99100 structures the battery passport into 7 data categories, from product identification to labeling. For a detailed explanation of what each category contains, see our article DIN SPEC 99100 Explained. A compact overview of all mandatory data is also available in What is a Battery Passport?.
Below, we walk you through each of the 7 steps: how to collect the data, where it comes from, and what to watch out for.
Step 1: Product Identification
Product identification forms the foundation of your battery passport. Here you capture the core master data:
- Unique Identifier: each battery receives an individual identifier (e.g., serial number or UUID)
- Manufacturer and Operator Information: name, address, contact details, trade register number
- Manufacturing Location: full address of the production facility
- Manufacturing Date and planned date of putting into service
- Battery Category: EV, industrial, LMT, or stationary
- Weight of the battery in kilograms
- Warranty Period in months
This data typically already exists in your ERP or PLM system. The key step is structuring it in the correct format according to DIN SPEC 99100, not as free-text fields, but as validatable data fields with defined types.
Step 2: Material Composition
In this step, you document the chemical composition of your battery. DIN SPEC 99100 distinguishes between:
- Cathode Materials: e.g., nickel, cobalt, manganese, lithium (with weight percentages)
- Anode Materials: e.g., graphite, silicon
- Electrolyte: type and composition
- Hazardous Substances: REACH and SVHC-relevant substances with CAS numbers
- Critical Raw Materials: according to the EU Critical Raw Materials Act
The biggest challenge: this data does not come from you alone. You need to involve your cell suppliers, who must provide exact material proportions and origin certificates. Allow sufficient time for this, supplier coordination is typically the most time-intensive part of passport creation.
Step 3: Carbon Footprint
The carbon footprint is one of the most publicly visible fields in the battery passport. It is expressed in kg CO2 equivalent per kWh of rated capacity and covers the entire lifecycle: raw material extraction, processing, cell production, transport, and end-of-life.
The calculation follows the Product Environmental Footprint Category Rules (PEFCR) established by the European Commission. Article 7(2) of the EU Battery Regulation additionally provides for carbon footprint performance classes that rank the footprint against other batteries of the same category. The delegated act that is to define these classes has not been adopted, so there is no binding class scale and no obligation to state a class yet.
In practice, this means you either need your own life cycle assessment (LCA) or can rely on industry average values until product-specific data becomes available. For details on how to document the carbon footprint, see our article Carbon Footprint in the Battery Passport.
Step 4: Supply Chain Due Diligence
The EU Battery Regulation requires manufacturers to demonstrate compliance with supply chain due diligence obligations. In the battery passport, this is documented through a reference to the due diligence report.
Specifically, you must demonstrate:
- Compliance with the OECD Due Diligence Guidance for minerals from conflict-affected areas
- A documented risk analysis of your raw material supply chains
- Audit results and action plans for identified risks
- A publicly accessible due diligence report (stored as a URL in the passport)
If you already prepare a report under the German Supply Chain Due Diligence Act (LkSG), you can use it as a foundation. For a detailed explanation of the requirements, see our article Supply Chain Due Diligence.
Step 5: Circularity
In this step, you document how your battery can be recycled and recovered at end of life. DIN SPEC 99100 requires:
- Recycled Content: share of recycled cobalt, lithium, nickel, and lead (minimum quotas apply from 2031)
- Recycling Efficiency: expected recovery rate per material
- Disassembly Information: instructions for safe battery disassembly
- Spare Parts Availability: which components are offered as spare parts
- Safety Instructions: safety notes for transport, storage, and end-of-life handling
The recycling quotas are particularly relevant for manufacturers who must demonstrate minimum values from 2031. For details on quotas and calculation methods, see our article Recycled Content in the Battery Passport.
Step 6: Performance and Durability
Performance data provides insight into the technical quality of your battery and is a key decision criterion for buyers. The following values are captured:
- Rated Capacity in Ah and Rated Energy in Wh
- Rated Voltage and permitted voltage range
- Maximum Power (original and current value for used batteries)
- Expected Cycle Life under reference conditions
- Capacity Threshold for energy throughput (Cycle Life Reference Test)
- Self-Discharge Rate and Internal Resistance
- State of Health (SoH): for used batteries, the current condition
For new batteries, these values are based on your test protocols and datasheets. For used or remanufactured batteries, current measured values must additionally be recorded.
Step 7: Labeling and Publication
In the final step, you bring together all regulatory labeling requirements and documents:
- Separate Collection Symbol (crossed-out wheelie bin)
- Hazardous Substance Symbols for cadmium (Cd) or lead (Pb), if applicable
- Carbon Footprint Label with performance class
- Extinguishing Agent for fire emergencies
- EU Declaration of Conformity: as a URL to the official document
- Test Reports: references to completed tests and certifications
For details on what belongs on the physical label, from QR code and CE marking to hazardous substance symbols, see our battery passport labeling guide.
After completing all 7 steps, your battery passport is complete and ready for publication. The passport is made accessible via a QR code on the battery and must remain available for the entire lifetime of the battery.
Before publishing, take a look at the access tiers. Annex XIII separates four groups: public model information, information for persons with a legitimate interest and the Commission, information for notified bodies and market surveillance authorities, and the data on the individual battery. Article 78(f) requires access, entering, modifying and updating to be restricted accordingly. Noticing only after publication that an entry sits on the wrong tier means correcting a passport that is already retrievable.
The step after that: registration in the EU registry
Publishing creates the passport but does not register it. Implementing Regulation (EU) 2026/1778 sets up a central Commission registry in which economic operators must register their passports; it has applied since 6 August 2026. The registry does not store passport content but a directory of identifiers, commodity code and a hash.
The step cannot be carried out yet, however. The Commission's semantic catalogue is missing, which defines every data point consistently and is the precondition for battery passports to be registered at all. A sandbox environment has been available since 20 July 2026; the productive route for batteries has not.
For your planning this means: budget for the registration step, but do not wait for it. Anyone whose data is already cleanly structured can register as soon as the route opens; anyone who starts only then loses the time twice.
Step 0: Work out which of your batteries are covered at all
Before you capture a single field, settle the scope. Article 77(1) names three groups needing a passport from 18 February 2027: LMT batteries, industrial batteries with a capacity above 2 kWh, and electric vehicle batteries. The 2 kWh threshold applies there exclusively to industrial batteries; EV and LMT batteries are covered without any capacity limit.
Go through your range and record per item: battery type, capacity, planned placing on the market. Whatever falls outside the three groups needs no passport, but does need a QR code to the mandatory information under Article 13 from the same date. This single table saves you the most work later, because it makes the difference between passport duty and labeling duty visible.
Who is responsible internally, and who is liable
Legally it is the economic operator placing the battery on the market (Article 77(4)). As an importer that is you, because your third-country manufacturer cannot be. And take care with own brands: under Article 44 an importer or distributor counts as the producer as soon as they place the battery on the market under their own name or trade mark, modify it in a way affecting compliance, or change its intended use.
In practice the passport needs data from at least four corners: purchasing supplies supplier and material details, engineering the technical figures, quality the test results, IT the integration. Name one person who owns the passport, otherwise it drifts between departments. You may delegate the authority to act on your behalf, but only in writing.
Measure the gaps first, then capture data
The Commission guidance of 28 July 2026 lists 71 data points, of which 36 to 53 are mandatory depending on battery type. Put that list next to your existing systems and mark each field: available, partly available, missing entirely. Only this comparison shows whether your bottleneck is IT or the supply chain, and those are completely different projects. In practice the master data usually exists somewhere, while material composition and supplier details have to be gathered anew.
What the supplier sends back, and how you check it
The work on a battery passport rarely sits in the software; it sits in getting the data. And the awkward part does not start with asking, it starts with the answer: Article 77(4) requires the economic operator placing the battery on the market to make sure the information is accurate, complete and up to date. That check is owed by you, not by your supplier. Article 78(g) adds that authenticity, reliability and integrity of the data must be ensured.
Turn that into a fixed routine rather than a mail thread. Four points are enough to start:
- Check completeness automatically. Every mandatory field that comes back empty gets flagged before a human looks at it. A passport system that only complains at publication time reports too late.
- Check the plant reference. For the carbon footprint, Annex II point 5 requires the activity data for anode, cathode, electrolyte, separator and cell casing to relate to a specific model made in a specific production plant. Default values are not allowed, and data from several plants building the same model may not be mixed. So always ask which plant a figure comes from.
- Check for contradictions. Units, orders of magnitude, totals: a recycled content above one hundred percent, a mass in grams instead of kilograms, or a composition that does not add up is caught faster by a simple rule than by any read-through.
- Document the sign-off. Record who approved which figure, when, and on what evidence. That is the difference between a verified entry and a forwarded one.
As for source systems: master data comes from PIM or ERP, bills of material and design data from PLM, the carbon figures from your own life cycle assessment. Connect those paths once and you pay for the integration once; stay on spreadsheets and you pay again for every model and every regulatory change. So budget this like a data integration project, not like a software license, and measure it on the first model before you plan the whole range.
Start with one model, not the whole range
Take one battery model, run it all the way through to a published passport with QR code, and measure how long each step actually takes. After that you know what the rollout across your range will cost, and you have a template. The opposite approach, taking every model halfway at once, reliably ends shortly before the deadline with nothing but incomplete drafts.
Common Mistakes to Avoid
These are the pitfalls that typically arise when a battery passport is created for the first time:
- Talking to suppliers too late: Material composition and origin certificates must come from your cell suppliers. Start coordination at least 6 months before your planned publication date.
- Capturing data in free-text fields: DIN SPEC 99100 defines exact data types and value ranges. Free text cannot be validated and will fail during verification. To understand why spreadsheets fall short, see From Excel to Battery Passport.
- Postponing the carbon footprint: The PEFCR-based calculation is complex and requires data from the entire value chain. Start early.
- Ignoring recycling quotas: Minimum recycled content quotas take effect from 2031, but you lay the documentation foundation now.
- Doing only the bare minimum: A complete battery passport with all optional fields is a competitive advantage over manufacturers who deliver only the minimum.
The identifier per unit: which standard applies
Before you create the first passport you need a numbering scheme. Article 77(3) sets out what it must follow: “The QR code and the unique identifier shall comply with ISO/IEC standards 15459-1:2014, 15459-2:2015, 15459-3:2014, 15459-4:2014, 15459-5:2014 and 15459-6:2014 or equivalent standards.”
The key point is not technical but numerical: the identifier applies per unit, not per model. Every single battery gets its own. Plan your first draft around one identifier per type and you will have to break the scheme later, retroactively for everything shipped in the meantime. So size the number range for the volumes of the coming years.
Frequently Asked Questions
How long does it take to create a battery passport?
The actual data entry takes a few hours once all information is available. The overall process, including supplier coordination, CO2 calculation and internal review, typically takes 6 to 12 months. How long exactly depends on your supply chain, not on the software: the figure is driven by how quickly suppliers deliver material data and carbon footprint data in the required depth.
Does every individual battery need its own passport?
Yes. The EU Battery Regulation requires an individual battery passport per battery (or per battery module for certain categories). Each passport receives a unique identifier and its own QR code.
What happens if my battery passport is incomplete?
Batteries without a valid or complete battery passport may no longer be placed on the EU market from February 2027. This can result in market access bans and fines under national law.
Can I update a battery passport after publication?
Yes, the battery passport is designed as a living document. Certain fields such as State of Health or battery status are updated throughout the lifecycle, for example during refurbishment or second-life use.
What software do I need for the battery passport?
You need software that maps the DIN SPEC 99100 data structure, validates mandatory fields, and exports the passport as a standards-compliant dataset. DPP Hero maps all 7 steps as a guided workflow, from product identification to publication. For an overview of how to prepare, see our Battery Passport Checklist 2027.
