From 18 February 2027, every electric-vehicle and industrial battery above 2 kWh needs a battery passport. But the passport alone is not enough: in parallel, the EU is building a central digital registry that stores the unique identifiers of all digital product passports — including battery passports. Through this registry, market surveillance authorities and customs can find a battery again by its identifier. The legal basis for the passport is Art. 77 of the EU Battery Regulation (Regulation (EU) 2023/1542); the central registry comes from the horizontal Ecodesign framework (ESPR, Regulation (EU) 2024/1781). This article explains what the EU Battery Passport Registry is, how it differs from the passport, which deadlines apply in 2026/2027 and what obligations manufacturers face.
What is the EU Battery Passport Registry?
The EU Battery Passport Registry is a central database that the European Commission is building as part of the digital product passport system. It does not store the full content of every battery passport, but the unique identifiers through which a passport can be found — comparable to a central directory that points to every individual passport.
The actual battery passport under Art. 77 remains decentralized: the data sits with the economic operator that places the battery on the market and is accessible via the QR code on the battery. The registry is the overarching infrastructure that brings these distributed passports together for authorities and customs. It mainly serves three purposes:
- Findability: authorities can uniquely identify a battery by its identifier and open the associated passport.
- Customs control: when importing into the EU, customs can check whether an identifier is registered for a battery subject to import requirements.
- Market surveillance: national authorities access the stored references through the registry to carry out conformity checks.
According to the current state of play, the first version of the registry for batteries is expected to be operational by mid-2026. That does not mean every onboarding process for manufacturers will already be in place — the technical details are being specified through Commission implementing acts. For the basics of what a battery passport is, see our complete guide to the battery passport.
Registry vs. battery passport — the key difference
Many manufacturers confuse the registry and the passport. The difference is central to understanding your obligations: the passport is the document, the registry is the directory that points to all documents.
| Feature | Battery passport (Art. 77) | Battery passport registry |
|---|---|---|
| What it is | Digital dataset per individual battery | Central EU database of identifiers |
| Content | Complete data under Annex XIII | Unique identifier + reference data |
| Storage | Decentralized, with the economic operator | Central, with the EU Commission |
| Access | QR code on the battery | Authorities & customs via the identifier |
| Legal basis | Art. 77 Reg. (EU) 2023/1542 | ESPR, Reg. (EU) 2024/1781 (Art. 12–13) |
| From when | 18 February 2027 | First version ~mid-2026 |
In short: as a manufacturer, you create and maintain the passport with all the data. The unique identifier of that passport is stored in the central registry so that authorities can match your battery. The two belong together but are technically and legally separate.
Timeline: which registry deadlines apply in 2026/2027
Several dates matter for the registry infrastructure and the related obligations. The following overview puts them in context:
- ~mid-2026: the first version of the digital product passport registry for batteries is expected to be operational. The horizontal ESPR framework provides that the Commission sets up the central registry by 19 July 2026.
- 18 August 2026: deadline for the Commission's implementing act on access rights. It defines which actors with a 'legitimate interest' (e.g. recyclers, repairers, second-life providers) may see which restricted data. More on this in the article on battery passport access rights.
- 18 February 2027: the battery passport becomes mandatory for EV and industrial batteries above 2 kWh. From this date, the unique identifier of every battery placed on the market must be findable in the registry. Which categories are affected and when is covered in Battery passport: from when and for whom?
- 18 August 2027: the supply chain due diligence obligations (Art. 48) become enforceable — after being postponed by Regulation (EU) 2025/1561. That is a six-month offset from the passport obligation.
You will find the full deadline overview for the regulation in the timeline of the EU Battery Regulation.
Which data goes into the registry — and which stays in the passport
A common misconception: that the registry contains all battery data. In fact, the split is clearly defined. The central registry mainly holds identification and reference data:
- the unique product identifier of the battery passport
- the identifier of the data carrier (the QR code on the battery)
- details of the economic operator that places the battery on the market
- the assignment to product or battery model and commodity code
The content data, by contrast, stays in the decentralized passport and is linked via the identifier. Under Annex XIII of the regulation, this includes, among others:
- material composition and the critical raw materials contained
- the battery's carbon footprint
- shares of recycled cobalt, lithium, nickel and lead
- supply chain due diligence information
- performance and durability data, including the state of health
For you, this means: the effort lies not in the registry entry itself, but in the complete and correct capture of the passport data. The identifier is only the key that points to this data.
Who must register — and who is responsible
The party responsible is always the economic operator that first makes the battery available on the EU market — the so-called party placing it on the market. Depending on the supply chain, that is the manufacturer or the importer. This operator must ensure that a complete battery passport exists and that its identifier is findable in the registry.
- EU manufacturers: create the passport themselves and store the identifier.
- Importers: ensure that the third-country manufacturer has supplied a complete passport, and add missing details. More in the article on obligations for importers.
- Manufacturers outside the EU: must appoint an EU-based authorised representative who takes on the obligations.
Responsibility can shift: if a battery is prepared for a second use, repurposed or remanufactured, responsibility for the passport passes to the actor performing that activity.
Important: the EU Battery Passport Registry is not the same as producer registration under Art. 55 of the regulation (in Germany with stiftung ear). The latter concerns extended producer responsibility for the disposal of waste batteries — an entirely separate process. Both obligations exist independently of one another.
How to prepare
Even though the final technical connection to the registry will still be specified through implementing acts, you can prepare in a structured way today. The following steps make sense regardless of the last detailed rules:
- Define your battery portfolio: record which of your batteries fall under Art. 77 (EV, industrial above 2 kWh, LMT) and which are exempt.
- Set an identifier strategy: define how you assign a unique identifier to each battery, and test the path from the QR code to the dataset early.
- Build your data base: gather all fields required under Annex XIII — from material composition through the carbon footprint to due diligence — in a single, well-maintained data source.
- Clarify responsibilities: determine who updates the passport after service, repurposing or remanufacturing.
- Use a structured tool: with battery passport software like DPP Hero, you capture and manage the data points for the battery passport in line with DIN SPEC 99100, assign unique identifiers and publish the passport directly as a page accessible behind the QR code. If needed, you can additionally export the data as a structured dataset or via API — the basis for entering the identifier into the registry later.
A concrete step-by-step preparation is provided by the battery passport checklist for 2027.
Frequently asked questions
What is the difference between the battery passport and the battery passport registry?
The battery passport is the complete digital dataset of a single battery, stored decentrally with the economic operator and retrieved via the QR code. The registry is a central EU database that stores only the unique identifiers of these passports, so that authorities and customs can match a battery.
From when must I store the identifier in the registry?
The battery passport obligation for EV and industrial batteries above 2 kWh applies from 18 February 2027. From this date, the unique identifier of every battery placed on the market must be findable. The first version of the registry infrastructure for batteries is expected to be available as early as ~mid-2026.
Is the battery passport registry the same as registration with stiftung ear?
No. Registration with stiftung ear follows Art. 55 of the regulation and the German Battery Act (BattDG) and concerns extended producer responsibility for the collection and disposal of waste batteries. The EU Battery Passport Registry, by contrast, concerns the digital findability of passports. Both obligations are separate and must be met independently of one another.
As a manufacturer outside the EU, must I register myself?
Manufacturers without an establishment in the EU must appoint an EU-based authorised representative who takes on the obligations — including providing the passport and the identifier. Alternatively, the EU importer becomes the responsible party placing the battery on the market.
How does DPP Hero help with preparing for the registry?
DPP Hero is battery passport software based on DIN SPEC 99100. You capture and structure the data points for the battery passport in it, check your entries for completeness and assign unique identifiers. You publish the finished passport directly via DPP Hero as a publicly accessible page that the QR code on the battery points to — you do not need your own infrastructure for that. If you prefer to process the data yourself, you can export it at any time as a structured dataset or via API. Via the share-link feature, your suppliers can contribute required information directly — so you have the passport data ready as soon as the identifier needs to be entered into the registry.