Digital Product Passport for Batteries
The only category with a binding passport deadline today. Art. 77(1) of Regulation (EU) 2023/1542 requires a battery passport from 18 February 2027 for every EV battery, every LMT battery and every industrial battery above 2 kWh. Portable and SLI batteries are outside passport scope and instead need a QR code under Art. 13(6) and Annex VI Part C. LabelEU builds passports that support the GS1 Digital Link format.
Passport binding (Art. 77)
18 Feb 2027
In passport scope
EV, LMT, industrial
Industrial threshold only
>2 kWh
Applicable EU regulations
Regulations covering batteries
EU Battery Regulation
(EU) 2023/1542
Sustainability, safety and circularity rules for batteries placed on the EU market. Art. 77 is the only binding passport obligation in force for any LabelEU category.
Key articles
- Art. 77 - Battery passport, binding 18 Feb 2027
- Art. 7 - Carbon footprint declaration, methodology act not adopted
- Art. 8 - Recycled content, methodology act was due 18 Aug 2026 and is not adopted
- Art. 13(6) and Annex VI Part C - QR code for portable and SLI batteries
Ecodesign for Sustainable Products Regulation
(EU) 2024/1781 (ESPR)
Framework regulation. It does not itself impose a battery passport, but its Art. 78 inserted Art. 77(10) into the Battery Regulation, so the battery unique identifier must be uploaded to the EU DPP registry.
Key articles
- Art. 9 - Passport mandatory only through an Art. 4 delegated act
- Art. 13 - EU DPP registry
- Art. 78 - Amendment inserting Batteries Art. 77(10)
DPP registry implementing rules
(EU) 2026/1778
In force since 6 August 2026. Sets how operators verify themselves with an eIDAS qualified electronic seal, how registrations are validated, and what a proof of registration contains. The registry itself went live on 20 July 2026.
Key articles
- Art. 4-5 - eIDAS verification, valid at most three years
- Art. 8 - Model, batch or item granularity and automatic validation
- Art. 9 - Sealed proof of registration, valid 90 days
Key dates
Compliance timeline for batteries
Each entry is tagged with how firm it is. Binding means the date is fixed in the Official Journal. Adopted means the instrument exists but the date has not arrived. Indicative means it comes from a Commission working plan or our own estimate and is not law.
17 Aug 2023
BindingBattery Regulation enters into force
Regulation (EU) 2023/1542 published in the Official Journal and became law.
Reg. (EU) 2023/1542
18 Aug 2024
BindingPerformance and durability documentation
Rechargeable industrial batteries above 2 kWh, LMT and EV batteries must carry electrochemical performance and durability documentation, and the battery management system must hold Annex VII state of health data with read-only access.
Reg. (EU) 2023/1542 Arts. 10(1) and 14(1)
18 Aug 2026
BindingRecycled content methodology act was due
The Art. 8(1) delegated act setting the calculation methodology for recycled cobalt, lithium, nickel and lead was legally due on this date and has not been adopted. The same is true of the Art. 77(9) implementing act defining who holds a legitimate interest in restricted passport data.
Reg. (EU) 2023/1542 Arts. 8(1) and 77(9)
18 Feb 2027
BindingBattery passport binding
One passport per physical battery for every EV battery, every LMT battery and every industrial battery above 2 kWh, with the unique identifier uploaded to the EU DPP registry under Art. 77(10). All batteries, including portable and SLI, must bear a QR code under Annex VI Part C from the same date.
Reg. (EU) 2023/1542 Art. 77(1) and (3)
18 Aug 2027
BindingDue diligence obligations apply
Battery due diligence under Arts. 48 to 52 applies, postponed from 18 August 2025 by Regulation (EU) 2025/1561. Chapter VII does not apply to operators below EUR 40 million net turnover.
Reg. (EU) 2025/1561 amending Art. 48(1); exemption in Art. 47
18 Aug 2031
Adopted, not yet applicableRecycled content minimum targets
Minimum recycled shares of cobalt (16%), lithium (6%), nickel (6%) and lead (85%) in industrial, EV, SLI and LMT batteries. The calculation methodology act is still missing, so the figures are not yet operable.
Reg. (EU) 2023/1542 Art. 8(2)
What compliance reviewers look for
DPP data requirements for batteries
Where no delegated act has been adopted for this category, the list below is our reading of the likely data set, not a legal requirement. Collecting it early is still the work that takes the longest. Everything below is supported out of the box in LabelEU.
Identity and composition
- Battery model, manufacturer, and unique identifier
- Battery chemistry and nominal capacity (Wh)
- Weight and physical dimensions
- Hazardous substances declaration
Sustainability data
- Carbon footprint value (kg CO2e per kWh)
- Carbon footprint performance class (A to E)
- Recycled content share (cobalt, nickel, lithium, lead)
- Supply chain due diligence report reference
Circularity and access
- Removability and replaceability instructions
- Collection and recycling guidance
- State of health parameters (for EV batteries)
- GS1 Digital Link URL and QR code
How LabelEU helps
Built for batteries compliance
Battery-specific DPP fields
Our guided form covers every required field: chemistry, carbon footprint class, recycled content, and state of health parameters.
GS1 Digital Link QR codes
Each battery passport gets a QR code that supports the GS1 Digital Link format. Customs, retailers, and recyclers can scan it for years.
Lifecycle updates without reprinting
Update carbon footprint data, state of health, or recycling info any time. The QR stays the same, so labels never go out of date.
Product examples
Common batteries and their key requirements
EV traction battery
- Full carbon footprint declaration
- State of health data access
- Recycled content percentages
Industrial energy storage system
- Chemistry and capacity disclosure
- Due diligence documentation
- Removability instructions
E-bike battery pack
- Hazardous substances list
- Collection scheme information
- Performance and durability data
Frequently asked questions
Common questions about Digital Product Passports for batteries.
Ready to create batteries passports?
Ship the QR with confidence today and keep updating the passport as your supply chain evolves.