The EU battery passport is the first hard Digital Product Passport obligation in EU law, and its date does not move with the rest of the Battery Regulation. From 18 February 2027, every electric vehicle battery, light means of transport (LMT) battery, and industrial battery above 2 kWh placed on the EU market or put into service must carry a battery Digital Product Passport under Article 77 of Regulation (EU) 2023/1542. A battery that should carry one and does not cannot be placed on the market.

This guide separates what is legally enforceable on that date from the milestones and postponements circulating around it, and sets out what manufacturers should have in place now.

Not sure where your product data stands against the 2027 requirement? You can request a compliance review to map your current gaps.

Key Takeaways

• The battery passport is mandatory from 18 February 2027 under Article 77(1) of Regulation (EU) 2023/1542, with no conditional extension clause.

• Scope is EV batteries, LMT batteries, and industrial batteries above 2 kWh. Portable, SLI, and industrial batteries at or below 2 kWh are outside Article 77.

• The 2025 postponement moved supply chain due diligence to 18 August 2027. It did not touch the passport date. Treat the two as separate.

• Passport data is split by access tier (public, legitimate interest, authorities) under Annex XIII, so the data model matters as much as the content.

• Most of the work is multi-tier supplier and BOM-level data, which is why data infrastructure lead time, not drafting, drives the timeline.

What the EU Battery Passport Is

The battery passport is an electronic record, reached through a QR code on the battery, that carries defined information about that specific battery across its life. It is established by Article 77 of the EU Batteries Regulation and is the first product category for which a Digital Product Passport is mandatory under EU law.

Source: Regulation (EU) 2023/1542.

Each passport carries a unique identifier that complies with the ISO/IEC 15459 series or an equivalent standard (Article 77(3)). The economic operator that places the battery on the market is responsible for keeping the record accurate, complete, and up to date (Article 77(4)), and access to it is free of charge (Article 78).

This applies regardless of where the battery is manufactured. A producer outside the EU placing covered batteries on the EU market is in scope through its importer or authorised representative.

Which Batteries Need a Passport From 18 February 2027

Article 77(1) does not cover every battery. Scope is defined by category and, for industrial batteries, by capacity. Getting this right prevents both over-building for products that are out of scope and under-preparing for products that are in.

A separate obligation sits alongside the passport: from the same date, Article 13(6) requires a QR code on all batteries, not only those that carry a passport. The two requirements are often merged in coverage, which hides that the QR code reaches batteries that will never have an Article 77 passport.

Which batteries require an EU battery passport under Article 77 from 2027

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Why 18 February 2027 Is a Fixed Date

The most consequential planning error in late 2026 is assuming the passport date will slip because another obligation did. It did not, and the two are structurally different.

In July 2025, Regulation (EU) 2025/1561 postponed battery supply chain due diligence under Article 48 by two years, from 18 August 2025 to 18 August 2027, as part of the Commission's simplification work. That amendment did not touch Article 77. The battery passport deadline remains 18 February 2027, and unlike most dates in the Regulation, Article 77 carries no suspensive or conditional clause tied to a forthcoming act.

Meanwhile, the supporting infrastructure is already live, which further undercuts the "it will be delayed" argument. The EU Digital Product Passport Registry opened on 20 July 2026, and Implementing Regulation (EU) 2026/1778, the registry's operating rulebook, has been in force since 6 August 2026.

What the Passport Must Contain and Who Can See It

Annex XIII defines the passport content, and it is not a single public document. Information is divided by access tier, so the data model, not just the data, determines compliance. The operator must know which field is visible to whom.

Two structural points matter for build planning. First, some fields tied to due diligence exist in the passport schema but will be empty in February 2027 because the underlying obligation does not apply until August 2027. An infrastructure that does not reserve those fields now will need reworking six months after go-live. Second, Article 77(7) gives a repurposed or remanufactured battery a new passport linked to the original, and Article 77(8) ends the record once the battery is recycled, so lifecycle state must be tracked, not just a static datasheet. This is where continuous, audit-ready documentation becomes a data problem rather than a filing exercise.

The Battery Passport Is Not the Same as the ESPR DPP

Much of the "DPP milestone" noise comes from conflating two distinct instruments. The battery passport is a sector-specific obligation under the Battery Regulation with a fixed 2027 date. The broader Digital Product Passport is a framework under the ESPR, Regulation (EU) 2024/1781, rolled out product group by product group through delegated acts.

Under the first ESPR Working Plan (COM(2025) 187, adopted 16 April 2025), priority groups such as textiles, furniture, mattresses, tyres, iron and steel, and aluminium have only indicative adoption dates, and as of late 2026 no product-specific ESPR delegated act has made a DPP mandatory for those groups.

Source: European Commission, Ecodesign for Sustainable Products Regulation.

The practical takeaway: the battery passport is the only DPP with a hard, enforceable date today. If your product is a covered battery, you are not waiting on a delegated act. Our overview of why the Digital Product Passport is becoming the backbone of compliance explains how the two systems are designed to interoperate through the shared registry.

Why Passport-Ready Data Takes 12 to 18 Months

Drafting a passport is not the hard part. Assembling verified, source-level data for every covered battery is. A battery passport consolidates information that sits across multiple suppliers, test reports, and material declarations, much of it below the first tier of the supply chain.

For most manufacturers the gating items are material composition and recycled content data from cell and component suppliers, carbon footprint inputs where applicable, and the lifecycle fields that must stay current after the battery is sold. Collecting, validating, and structuring that data across a multi-tier supply chain is what consumes the 12 to 18 months, which is why a Q4 2026 start is realistic and a 2027 start generally is not. Our deeper 12-18 month build analysis breaks down that timeline step by step.

If supplier data collection is your bottleneck, see how Certivo handles it: speak with a compliance specialist.

Where the Data Problem Actually Sits

For a battery or energy storage manufacturer, passport readiness is less a regulatory interpretation problem than a data operations problem. Three questions determine whether February 2027 is a managed deadline or a market-access risk.

• Can you collect and validate material and composition data from suppliers at every tier, not only Tier 1?

• Can you map that data to the specific battery model and bill of materials that carries the passport?

• Can you keep the record accurate after sale, including for repurposed batteries that require a new linked passport?

These map directly to capabilities that matter across other frameworks too, which is why automotive and energy infrastructure manufacturers increasingly treat battery passport data as part of a single compliance backbone rather than a one-off project.

Workflow to build passport-ready battery data for the EU battery passport

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How Certivo Supports Battery Passport Readiness

Certivo is built to turn this from a manual exercise into a managed one. The platform acts as a centralized system of record for product compliance data, with CORA, its embedded regulatory intelligence, supporting the work that drives the timeline.

• Automated supplier data collection through supplier portals, reducing the manual effort of chasing composition and recycled content data across tiers.

• CORA-powered document parsing and certificate validation, which extracts and checks data from test reports and declarations rather than relying on manual re-keying.

• BOM-level material mapping, linking supplier data to the specific battery that carries the passport, through capabilities like tracking compliance by BOM.

• Audit-ready documentation with historic state tracking, so the record can be kept accurate and up to date as Article 77(4) requires.

Certivo does not remove the underlying obligation or guarantee a given outcome. It reduces compliance surprises, shortens evidence retrieval, and gives compliance, engineering, and procurement teams a shared, current view of where each battery stands. The goal is a move from reactive, deadline-driven scrambles toward continuous, proactively managed compliance.

What to Do Before February 2027

A practical sequence for the remaining months:

1. Confirm scope. Identify which of your batteries fall under Article 77 (EV, LMT, industrial above 2 kWh) and which do not.

2. Map the data sources. For each in-scope battery, identify where every required Annex XIII field comes from, including sub-tier suppliers.

3. Start supplier data collection now. This is the long pole. Begin collecting and validating composition, recycled content, and carbon inputs where applicable.

4. Reserve the dormant fields. Build the schema to hold the due diligence fields that apply from August 2027, to avoid a rework.

5. Plan lifecycle maintenance. Establish how the record stays current after sale, and how repurposed batteries receive a new linked passport.

To pressure-test your readiness against the 2027 requirement, book a compliance risk assessment and map your current data gaps across products and suppliers.