The EU Battery Passport Registry: A Manufacturer's Guide

Updated 4 August 2026: In response to our inquiry, the European Commission's DPP Help Desk named two dates. The semantic catalogue and the registry APIs are planned for Q4 2026, and only then can battery passports be registered at all. The rules for service providers registering on behalf of manufacturers will follow in a separate legal act, which the Commission expects around Q2 2027. The act on access rights still carries the 18 August 2026 deadline but is now planned by the Commission for Q4 2026. Details in having your battery passport registered.

Update July 2026: The registry has been live since 20 July 2026, including a test environment, and Implementing Regulation (EU) 2026/1778 has been published. Details in our article The EU DPP registry is live.

From 18 February 2027, every LMT battery placed on the EU market (e.g. for e-bikes and e-scooters), every industrial battery above 2 kWh and every electric-vehicle battery needs a battery passport (Art. 77(1)). 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.

Especially relevant for importers: battery passport for importers. The broader ESPR context is covered on the DPP software page.

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.

The hard deadline is in the ESPR: the Commission must set up the central registry by 19 July 2026 (Art. 13(1)). 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.

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.

How registration works (ESPR Art. 13 and 15)

The ESPR already sets out the process in concrete terms. It consists of three steps:

1. Upload: the economic operator placing the battery on the market or putting it into service uploads the identifiers to the registry itself (Art. 13(4)). The EU does not register for you, the upload is your obligation.
2. Receive a registration identifier: the registry automatically returns a unique registration identifier (Art. 13(5)). Important: this confirmation explicitly does not count as proof that your product is compliant. Responsibility for the passport data stays with you (Art. 77(4)).
3. Customs handling: whoever declares a battery subject to registration for release for free circulation provides customs with exactly this registration identifier once the registry is operational (Art. 15(1)).

The technical onboarding details (interfaces, procedures, formats) will be specified by the Commission in an implementing act. Those detailed rules are still pending; the deadline for setting up the registry itself and the obligations above are already binding law.

Before that: your company has to be verified

One step comes before the first upload, and it is easy to miss: only a verified economic operator may enter the registry. How that proof works is set out in Implementing Regulation (EU) 2026/1778, in force since 17 July 2026.

• Legal persons prove their identity, and where relevant their establishment, with a qualified electronic seal based on a qualified certificate for electronic seals under the eIDAS Regulation (EU) No 910/2014, issued by a qualified trust service provider.
• Sole traders use a qualified electronic signature with a qualified certificate under the same regulation instead of a seal.

The status “verified” is granted in a single verification procedure and lasts until the end of the validity of your electronic identification means, and “in no case for more than three years”. In practice: get the seal from a qualified trust service provider and plan the renewal before it lapses. Starting only when the upload is due costs weeks on a formality.

Verifying your company is one thing; having the figures themselves checked is another. For the requirements of Articles 7 and 8, the carbon footprint and the recycled content, Article 17(2) allows only two routes: Module D1 (quality assurance of the production process) or Module G (unit verification). Module A, the internal production control that suffices for the other requirements, is expressly not enough here. For due diligence it is in the definition itself: the obligations include independent third-party verification and monitoring by notified bodies. Sourcing that evidence only at registration time is too late.

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:

• 19 July 2026: by this date, the Commission must have set up the central digital product passport registry (ESPR Art. 13(1)).
• 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 LMT batteries, industrial batteries above 2 kWh and EV batteries (Art. 77(1)). 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: may appoint an EU-based authorized representative by written mandate (Art. 40). Core obligations such as due diligence (Art. 48 to 52) and the technical documentation are excluded from that mandate; responsibility for the passport lies with the party placing the battery on the market, which for third-country goods is usually the importer.

Responsibility can shift: if a battery is prepared for a second use, repurposed or remanufactured, responsibility for the passport passes to the economic operator that places the refurbished battery back on the market. These batteries need a new passport linked to the passport of the original battery (Art. 77(7)). Once the battery has been recycled, the passport is deleted (Art. 77(8)).

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:

1. Define your battery portfolio: record which of your batteries fall under Art. 77 (EV, industrial above 2 kWh, LMT) and which are exempt.
2. 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.
3. 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.
4. Clarify responsibilities: determine who updates the passport after service, repurposing or remanufacturing.
5. 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.

Who sees what, where you search, and what happens when nothing is there

Three access levels. Article 77(3) of the Battery Regulation splits passport data into three circles. Publicly readable through the QR code is Annex XIII point 1. Points 2 and 3 are seen only by notified bodies, market surveillance authorities and the Commission. Points 2 and 4, including the entries for the individual battery, are open to those who demonstrate a legitimate interest, such as repairers, remanufacturers, second-life users and recyclers.

A portal for searching and comparing. Alongside the registry itself, Article 14 of the Ecodesign Regulation provides for a publicly accessible web portal: the Commission sets it up and maintains it so that stakeholders can search and compare the data held in digital product passports, each within their own access rights. The registry itself is accessible under Article 13(6) to the Commission, the competent national authorities and the customs authorities, so they can carry out their tasks.

And if nothing is there? Market access goes first: without a passport the battery concerned may not be placed on the market from 18 February 2027, and customs can refuse release for free circulation. Then comes the penalty. In Germany, section 60(2) no. 29 BattDG covers the case where passport entries are not correct, complete or up to date; that number does not appear in the higher tiers listed in subsection 3, so it falls under the remaining cases with up to 10,000 euros. Leave the passport out entirely and the fine is the smaller problem, market access the larger one.

From the identifier to the registry entry

Which identifier you use is not prescribed. Article 77(3) requires the QR code and the unique identifier to comply with ISO/IEC standards 15459-1 to -6 or equivalent standards, and the term GS1 does not appear once in the Ecodesign Regulation. GS1 Digital Link is therefore one possible route, not the prescribed one.

What goes into the registry follows Article 13(1) of the Ecodesign Regulation: at least the unique product identifier, for goods destined for free circulation also the commodity code, and expressly the individual identifiers for batteries under Article 77(3). So your identifier has to be storable in that form, whatever system it comes from. If you already run GTIN and serial number you can use GS1 Digital Link and reuse the same code at the retail checkout later; if you hold no GS1 identifiers, you do not need to apply for them for the battery passport.

Frequently asked questions

What happens to the passport if my company stops trading?

The regulation anticipates this. Article 78(e) requires the battery passport to remain available even if the responsible economic operator ceases to exist or ceases its activity in the Union. For product passports under the Ecodesign Regulation, Article 10(4) goes further: there the economic operator expressly provides a backup copy through an independent digital product passport service provider, and Annex III lists that provider's reference as a data point of the passport. For the battery passport that explicit duty is not in the Battery Regulation; you still owe the availability beyond the end of the company. So when choosing a provider today, ask what happens to the data if your own company no longer exists.

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 LMT batteries, industrial batteries above 2 kWh and electric-vehicle batteries applies from 18 February 2027. From this date, the unique identifier of every battery placed on the market must be findable. The Commission must set up the central registry by 19 July 2026 (ESPR Art. 13(1)).

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?

An authorised representative can be appointed by written mandate (Art. 40), but core obligations such as due diligence and the technical documentation are excluded from that mandate. In practice, for third-country goods the EU importer is the responsible party placing the battery on the market and therefore in charge of the passport and the identifier.

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.