Frequently Asked Questions

A battery passport is a digital product passport specifically for batteries that becomes mandatory from 18 February 2027. It makes information on material composition, carbon footprint, supply chain due diligence, circularity, performance, and labeling transparent and machine-readable across the entire battery lifecycle. A transitional situation applies to some of these entries: the European Commission's non-binding guidance of 15 August 2026 (version 2.0) defers the carbon footprint declaration until its format is set by an implementing act, and requires the responsible sourcing details only from 18 August 2027. The legal basis is the EU Battery Regulation 2023/1542, Article 77.

From 18 February 2027 under the EU Battery Regulation 2023/1542. This applies to electric vehicle batteries, industrial batteries with a capacity exceeding 2 kWh, and LMT batteries (Light Means of Transport). Since data capture covers seven categories with extensive required fields, early preparation is recommended.

Three categories: electric vehicle batteries (EV), industrial batteries with a capacity exceeding 2 kWh, and LMT batteries, including those in e-bikes and e-scooters. Portable batteries (e.g. in smartphones) and automotive starter batteries are currently not affected. The difference between passport and labeling matters: only these three categories need the passport, but every battery needs the QR code. Article 13(6) requires a QR code in line with Annex VI Part C for all batteries from 18 February 2027, including portable batteries and automotive SLI (starter, lighting, ignition) batteries. For those it does not lead to a battery passport but to the labeling information. Anyone with a mixed product range therefore has to keep two things apart.

The battery passport is the first concrete implementation of the digital product passport (DPP). The ESPR (Ecodesign for Sustainable Products Regulation) will gradually extend the DPP to additional product categories. The battery passport has its own legal basis (EU Battery Regulation 2023/1542) and a fixed start date on 18 February 2027, making it the forerunner for all future digital product passports.

DIN DKE SPEC 99100:2025-02 is a German publicly available specification for the data structure of the battery passport, produced in the PAS procedure. It describes seven data categories: identification, materials and composition, carbon footprint, supply chain due diligence, circularity, performance and durability, and labeling with the EU declaration of conformity. The specification is not a harmonized standard and creates no presumption of conformity. DPP Hero uses it as a reference for the data structure.

The economic operator placing the battery on the EU market is responsible, meaning manufacturers, importers, or authorized representatives. They bear responsibility for the accuracy and completeness of the battery passport data. DPP Hero supports this process as a creation and management tool by structuring data capture according to DIN SPEC 99100.

Annex XIII splits the data into four points, and Article 77(2) assigns three access classes to them. Point 1 is public and readable by anyone through the QR code. That covers composition, capacity, voltage and expected lifetime. Points 2 and 3 are seen by notified bodies, market surveillance authorities and the Commission. Points 2 and 4 are seen by persons with a legitimate interest. Point 2 holds the detailed material composition and the dismantling instructions. Point 3 holds exactly one thing: the test reports. Point 4 covers data on the individual battery such as the state of health. Who counts as a person with a legitimate interest is to be set by an implementing act under Article 77(9). Its deadline, 18 August 2026, has passed.

Article 93 leaves the level to the member states. It only requires effective, proportionate and dissuasive sanctions. In Germany section 60 BattDG sets the frame: up to 500,000, 100,000 or 10,000 euros depending on the breach. The top tier covers supply chain due diligence and disregarded official orders. It does not cover the passport duty itself. Besides the fine, market surveillance can have a product withdrawn. In detail in the article on penalties for non-compliance.

Yes, from 18 February 2027. The Commission's central registry has been operating since 20 July 2026 and Implementing Regulation (EU) 2026/1778 has been in force since 6 August 2026. For battery passports, however, registration is still closed on the EU side because the semantic catalogue is missing; the Commission's user guide gives no date for it. Until then nobody can credibly deliver a finished registry connection. You lose nothing by waiting: your data is created now, registration is a later technical step.

The passport is meant to close the loop. Today knowledge about a battery usually ends with the manufacturer. Whoever later repairs, repurposes or recycles it knows neither the material composition nor the condition. The passport makes exactly this retrievable across the lifetime, tiered by access right. The benefit is twofold. For the market: repair, second life and recycling become plannable. For your company: the data you have to gather for Annex XIII anyway then sits structured. It can be reused for tenders, customer questions and supplier checks.

Through the QR code on the battery. Annex VI Part C prescribes strong color contrast and good readability, expressly including mobile phones. A scan leads to the passport page, without an app and without an account. What is visible there depends on the access level. The public part is visible to anyone. Further data is open only to persons with a legitimate interest and to authorities.

At the level that is placed on the market. Article 77(1) ties the electronic record to the battery that reaches the market. Its components are not meant. If you sell a pack, the pack is the battery. If you sell a container with several racks as one product, that container is the battery. The levels below do not disappear, they sit in the composition and the condition data. For the number of passports the sales unit counts.

The ongoing condition data does not apply to them. Article 14(1) expressly names only stationary battery energy storage systems, LMT batteries and electric vehicle batteries. Industrial batteries that operate safely without a connected system, such as lead-acid or nickel-cadmium batteries in uninterruptible power supplies or forklifts, are not covered there. The data model carries a category of its own for them. The passport is still required, just without data from a system that does not exist.

The non-binding data point guidance of the EU Commission dated 15 August 2026 (version 2.0) lists 71 data points. How many of them are mandatory depends on the battery type: 46 for electric vehicle batteries, 49 for LMT batteries, 32 for industrial batteries. The guidance is not binding, but it organizes the requirements from Annex XIII and states the access tier for each point. Individual points still depend on outstanding legal acts; the larger part is settled.

Yes. Article 77(7) is clear. Batteries prepared for re-use or repurposing, repurposed or remanufactured need a new passport. It is linked to the passport of the original battery. Under paragraph 3 the passport is retrieved through the QR code tied to the individual identifier. So the new passport needs its own identifier and its own code on the battery. The duty to keep the data current passes to the operator placing the repurposed battery on the market. Once the battery is recycled, the passport is deleted under paragraph 8.

A service called a resolver, and there are three models for it. The canonical GS1 Digital Link address always starts with https://id.gs1.org under the syntax standard. That resolver only returns links the brand owner has released. Second, the passport provider can run the service under their own domain: valid, but not canonical. Third, you can run it yourself; GS1 publishes an open source Community Edition for that. The consequence matters. The domain name later sits printed on the battery. And Article 78(e) requires the passport to stay reachable even if the responsible party no longer exists.

No, and the other markets have their own systems that do not replace it. In the United Kingdom the Waste Batteries and Accumulators Regulations 2009 apply. Whoever first places batteries there reports tonnage and chemistry annually. From one tonne of portable batteries per year, membership of a Battery Compliance Scheme is mandatory. In the USA there is no federal registration, but there is state law. California requires a take-back program under the Responsible Battery Recycling Act of 2022. The state keeps a public list of compliant producers and bans sales for anyone not on it. In China the Interim Measures of MIIT and five other bodies have applied since 1 April 2026. Every traction battery gets a digital identity, and there is a national traceability platform.