What is a Battery Passport?
A battery passport is a digital dataset that consolidates the essential information about a battery across its entire lifecycle, from cell production to recycling. The EU Battery Regulation simply calls it an electronic record, and that is a good way to picture it: material composition, raw material origins, carbon footprint, performance metrics, and recyclability all sit in one standardized place. Whoever inspects, repairs, or recycles the battery later on does not have to piece the data together.
For structured capture of all mandatory data, DIN SPEC 99100 software provides a guided workflow based on the standard. For an overview of the practical implementation, see the battery passport software page.
The battery passport is not voluntary. It becomes mandatory for certain battery types under the EU Battery Regulation (EU 2023/1542) and sits at the core of the European strategy for a sustainable, circular battery value chain.
Technically, the battery passport is based on DIN SPEC 99100, which defines a unified data structure with seven categories. The data is accessible via a QR code or a unique identifier such as the GS1 Digital Link, so authorities, recyclers, and other economic operators can pull up the information they need at any time.
One question often gets skipped: which level the passport attaches to. It applies to the battery placed on the market, so in practice at pack level. Modules and cells below it do not get their own passport; their data appears in the pack's passport.
Why is the Battery Passport being introduced?
Above all, the EU wants one thing from the battery passport: no battery should enter the market without verifiable data about what is in it and where it comes from. The market is growing fast on the back of electromobility and the energy transition, and with it grows the volume of cells that will come back for recycling in a few years. Whoever has to process them then will need today's data.
Specifically, the battery passport aims to:
- Create transparency: Manufacturers, importers, recyclers, and consumers can trace what a battery is made of, where the raw materials come from, and under what conditions it was produced.
- Promote sustainability: Mandatory documentation of the carbon footprint gives manufacturers a tangible incentive to make production more climate-friendly.
- Enable circular economy: With data on material composition and recyclability, recycling companies can process batteries more efficiently and recover valuable raw materials.
- Ensure responsible supply chains: The supply chain due diligence requirements ensure that raw materials like lithium, cobalt, and nickel are sourced in compliance with human rights and environmental standards.
So the battery passport goes beyond a data sheet. It is a tool of European industrial and climate policy, and it affects the entire value chain, from cell manufacturer to recycler.
Who needs a Battery Passport?
The EU Battery Regulation addresses all economic operators who place batteries on the EU market. That primarily means three groups:
- Manufacturers: Companies that produce batteries and offer them on the EU market under their own name.
- Importers: Companies that bring batteries from third countries into the EU.
- Authorized representatives: Companies authorized by non-European manufacturers to act on their behalf.
Not all battery types are equally affected. The battery passport requirement initially applies to:
- Traction batteries for electric vehicles (EV batteries)
- Industrial batteries with a capacity exceeding 2 kWh
- LMT batteries (Light Means of Transport), for example for e-bikes and e-scooters
Portable batteries and starter batteries are currently exempt from the battery passport requirement but are subject to other provisions of the regulation such as labeling and collection targets. Whether your battery is affected and which deadlines apply, find out in detail at Battery Passport: When Is It Mandatory?.
What data does a Battery Passport contain?
The data structure of the battery passport is defined by DIN SPEC 99100 and comprises seven clearly delineated categories. Each category contains mandatory and optional fields that apply depending on battery type and use case.
1. Identification and Product Data
Unique identification of the battery via standardized identifiers (e.g., GS1 Digital Link), information about the manufacturer, battery type, model, production date, and manufacturing facility. This category forms the foundation for traceability.
2. Materials and Composition
Detailed breakdown of the raw materials and materials used: cathode material, anode material, electrolyte, and casing. Origin information is required for critical raw materials such as lithium, cobalt, nickel, and manganese.
3. Carbon Footprint
The carbon footprint captures greenhouse gas emissions across the entire lifecycle, from raw material extraction through production to transport. The value is expressed in kg CO₂ equivalent per kWh and will be classified into performance classes in the future.
4. Supply Chain Due Diligence
Proof of compliance with supply chain due diligence obligations, particularly regarding human rights, working conditions, and environmental standards in raw material sourcing.
5. Circularity and Resource Efficiency
Information on recyclability, recycled content share, disassembly instructions, and expected lifespan. Without this data, a circular economy cannot work.
6. Performance and Durability
Performance metrics such as rated capacity, energy density, charge cycles, internal resistance, and expected lifespan. They make battery quality measurable and products comparable.
7. Labeling and Conformity
Information on CE marking, EU declaration of conformity (as a manufacturer document), test reports, and relevant symbols. This category documents the regulatory conformity of the battery.
The seven data categories of DIN SPEC 99100 cover the entire lifecycle of a battery, from raw material extraction to recycling. Together, they form a complete picture of its ecological, social, and technical properties.
Not all of this data is publicly accessible. The EU Battery Regulation defines a three-tier access model that governs who can view which information. For details, see Battery Passport Data Access: What Becomes Public?.
When does the Battery Passport become mandatory?
The EU Battery Regulation provides for a phased timeline. The decisive date for the digital battery passport is 18 February 2027. From this date, certain battery types placed on the EU market must have a complete digital battery passport.
Timeline overview:
- 18 February 2025 (EV) and 18 February 2026 (industrial batteries > 2 kWh): earliest possible start of the carbon footprint declaration under Art. 7(1) of the Battery Regulation. It applies only 12 respectively 18 months after the delegated methodology act and the implementing format act enter into force, whichever is later. As of 20 August 2026 neither act has been adopted, so the declaration is not yet mandatory.
- 18 August 2026: CO₂ performance classes for EV batteries, once the corresponding delegated act is in place (as of 4 August 2026 it has not been adopted); maximum CO₂ threshold from 18 February 2028
- 18 February 2027: Digital battery passport becomes mandatory for EV batteries, industrial batteries > 2 kWh, and LMT batteries
For manufacturers this means: preparation should begin now. Capturing and structuring the data takes time, especially when it has to be consolidated from various sources (ERP, PLM, suppliers).
How to create a Battery Passport
Creating a battery passport requires a structured approach. There are essentially three paths:
Option 1: In-house development
Large corporations with their own IT departments can implement the DIN SPEC 99100 data structure themselves. However, this requires deep understanding of the specification, custom JSON schema validation, and infrastructure for hosting the data. The effort typically amounts to several months of development time.
Option 2: Specialized software
Specialized SaaS tools like DPP Hero provide the DIN SPEC 99100 data structure out of the box. Data entry runs through a guided interface in seven steps, without you having to deal with the technical schema yourself. PDF export, JSON export, and QR code generation are typically integrated.
Option 3: System integration via API
For companies with large product portfolios, programmatic integration via a REST API is the most efficient path. Existing systems (ERP, PLM, MES) transfer data directly to the battery passport software, via bulk import or single-product API.
Regardless of the chosen path: start with the data you already have. Most companies already hold a significant portion of the required information in their existing systems. The first step is taking stock: What data is available, what's missing, and how do you close the gaps?
For a step-by-step walkthrough of all seven data categories, see How to Create a Battery Passport: 7-Step Guide. For typical implementation costs, see Battery Passport Costs.
Where the data sits, and who checks that it is right
Two questions come up almost every time the obligation is clear: where is the data stored, and who actually checks whether it is correct?
Storage is decentralised, not at the EU
The regulation is unambiguous here. Article 78(c) provides that “the data included in the battery passport shall be stored by the economic operator responsible for fulfilling the requirements set out in Article 77(4) and (7), or by operators authorised to act on their behalf”. So there is no central EU database holding the passport content. The central EU registry under the Ecodesign Regulation stores identifiers and references, not the content itself.
If you use a service provider, point (d) applies: such operators may not sell, re-use or process the data, in whole or in part, beyond what is necessary for the storage and processing services themselves. And point (e) requires the passport to remain available “even if the economic operator responsible for fulfilling the requirements ... ceases to exist or ceases its activity in the Union”. For product passports under the Ecodesign Regulation, Article 10(4) goes one step further and requires a backup copy with an independent third-party service provider; for the battery passport that explicit duty is not in the Battery Regulation.
Checking is done by market surveillance
Accuracy is first assured by the economic operator itself: under Article 77(4) it ensures that the information is accurate, complete and up to date, and Article 78(g) requires that “the authenticity, reliability and integrity of the data” be ensured. This is checked by the market surveillance authorities of the member states; Article 79 gives them the procedure once they have sufficient reason to believe a battery does not meet the requirements. Notified bodies enter elsewhere: Annex XIII point 3 expressly reserves the results of the test reports for notified bodies, market surveillance authorities and the Commission.
For product passports under the Ecodesign Regulation, Article 10(4) goes one step further and requires a backup copy with an independent third-party provider; for the battery passport that explicit duty is not in the Battery Regulation. You still owe the availability.
In practice: nobody checks your passport in advance and stamps it. There is no approval and no seal for battery passports. The check happens when an authority looks, and then what counts is what the passport says.
Why the technology is the real hurdle today
A passport is of little use if only your own system can read it. For the interface there is the European standard EN 18222, which describes how a passport is retrieved via the product identifier or the passport ID and how earlier versions are accessed.
The other half is still missing: the Commission's semantic catalogue, the register that defines every data point consistently and machine-readably. Without it, every provider can name the same field differently, and that is precisely why registering battery passports in the EU registry is not yet possible, even though Implementing Regulation (EU) 2026/1778 has applied since 6 August 2026.
In daily work this shows up as a system break: the cell manufacturer sends a spreadsheet, the test lab a PDF, your own production an ERP field, and no two use the same name for the same value. Anyone starting today should therefore not collect the data in a document but in fields that can later be mapped onto a schema without re-entry.
What happens at the end of the battery life
The passport does not end with the sale but with the battery. Article 77(8) puts it briefly: the battery passport is deleted once the battery has been recycled. There is no fixed retention period; availability is tied to the life of the battery.
The case before that is more interesting. Many traction batteries are still usable after the vehicle life and move on as stationary storage; the industry calls this second life. For this repurposing, Article 77(7) requires a new passport for the new battery, linked to the old one. The history is not lost, it gains a second entry.
In practice this means two things. Anyone creating passports today should expect the data to be read years later by someone else, for example a second-life operator or a recycler. And anyone repurposing a used battery becomes a passport creator themselves, even without ever having built the cell.
Fixed and running data: who keeps the passport current
A battery passport is not a datasheet you file once. Article 77(2) requires two things side by side: information about the battery model and specific information for the individual battery, expressly including information “resulting from this battery's use”.
You maintain the fixed entries once per model: composition, capacity, labeling, the due diligence report. They come from the datasheet and the test report and do not change because a customer uses the battery differently. The running entries belong to exactly one unit: state of health, cycle count, negative events. Under Annex XIII point 4 they are not part of the public tier; they are reserved for persons with a legitimate interest, such as repair businesses and recyclers.
Who keeps them current is set out in paragraph 4: the economic operator placing the battery on the market. That operator must ensure the entries are correct, complete and up to date, and may authorise others in writing to act on their behalf, a vehicle manufacturer for instance. The responsibility stays with them.
It moves when the battery's life stage changes. If a battery is prepared for re-use, repurposed or remanufactured, paragraph 7 puts the duty on whoever places it on the market again, and the battery receives a new passport linked to the old one. Once it becomes waste, the duty passes to the producer, the producer responsibility organisation or the appointed waste operator. And paragraph 8 ends it: the passport is deleted once the battery has been recycled.
What about batteries built before the deadline?
The most common question in the warehouse: does the duty also apply to stock that is already finished? Article 77(1) does not look at the production date but at the market: from 18 February 2027, every LMT battery, industrial battery above 2 kWh and electric vehicle battery placed on the market or put into service must have a passport.
Both consequences follow. A battery placed on the market before the deadline needs no passport, even if it is sold or built in later. A battery produced in 2026 and placed on the market only in March 2027 needs one. Anyone holding stock should therefore know which part of it reaches the market before 18 February 2027 and which part after.
Battery passports outside the EU
So far only the European route is binding. Alongside it there is a voluntary scheme that is often confused with it: the Battery Passport of the Global Battery Alliance. It is a reporting and certification scheme meant, in its own words, to make supply chains more visible, traceable and comparable.
The alliance timeline: a first pilot phase in 2023, a second round in 2024, operational trials in 2026 with 17 consortia, and a launch planned for 2027. Its greenhouse gas rulebook is being written explicitly in anticipation of the EU delegated act on carbon footprint.
Two things follow for you. Taking part does not replace the duty under the Battery Regulation, and anyone serving both should maintain the data once and export it twice rather than keeping two separate records.
Two questions always come up about scope. First the level: Article 77(1) requires a passport for every LMT battery, industrial battery above 2 kWh and electric vehicle battery placed on the market, and paragraph 2 separates battery model information from information on the individual battery. The passport therefore attaches to the product you place on the market, not to module level or cell level below it.
Second the timing: the regulation ties the duty to placing on the market or putting into service. There is no rule that the passport must already be retrievable at customs clearance; the words customs and release for free circulation do not appear in the regulation text once.
What a finished battery passport looks like
Descriptions only get you so far. After that it helps to look at a real passport. This example battery passport holds a fully filled record, the way an end user sees it after scanning the QR code: no login, no app, no cost.
Every value in it is fictitious, and the page says so. What is real is the structure: the public tier with composition, capacity and labeling, the restricted fields with a lock icon, and the layout following Annex XIII. If you want to know how much work sits behind a passport, skim that sample once from top to bottom.
Frequently Asked Questions
Does the battery passport apply to portable batteries?
No, under the current regulation, portable batteries (e.g., in smartphones, laptops) are exempt from the battery passport requirement. The obligation initially applies to EV batteries, industrial batteries above 2 kWh, and LMT batteries. An extension to additional battery types is possible in later phases.
What happens if I don't have a battery passport?
Batteries without a valid digital battery passport may not be placed on the EU market after the deadline of 18 February 2027. This means: no sales, no imports, no market introduction. Specific sanctions will be determined by individual EU member states but may include fines and sales bans.
Do I have to create the battery passport myself or are there service providers?
The responsibility for the accuracy and completeness of the data lies with the economic operator, meaning the manufacturer, importer, or authorized representative. You can use software for creation and management, but the responsibility for the content remains with you.
How does the battery passport relate to the Digital Product Passport (DPP)?
The battery passport is the first concrete implementation of the Digital Product Passport (DPP) under the EU strategy. The European Commission plans to gradually introduce digital product passports for additional product categories. Textiles and apparel, furniture, tyres and mattresses are next on the list, together with iron, steel and aluminium as intermediate products; the battery passport serves as the blueprint.
