Why You Should Create a Battery Passport Now
From February 18, 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).
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. Additionally, a performance class (A to E) must be indicated, ranking the footprint against other batteries of the same category.
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
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.
Common Mistakes to Avoid
From practical experience, these are the typical pitfalls manufacturers encounter when creating their first battery passport:
- 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.
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 3 to 6 months.
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.