Digital Product Passports Under the EU Battery Regulation: What's Required

The regulation, in one paragraph

Regulation (EU) 2023/1542, the EU Battery Regulation, is the first EU rule to attach a hard Digital Product Passport deadline to a product category: industrial batteries over 2 kWh, electric vehicle (EV) batteries, and light means of transport (LMT) batteries must carry a DPP starting February 2027.

It's also the most detailed DPP data model published so far, which makes it a useful reference even for teams whose product category isn't batteries.

What data the passport must contain

The regulation specifies data at both the battery-model and, in some cases, individual-battery level:

• Manufacturer and origin — legal entity, manufacturing location, unique battery identifier.
• Material composition — including critical raw materials (cobalt, lithium, nickel, natural graphite) by weight percentage.
• Carbon footprint — a declared carbon footprint value, calculated per the regulation's own methodology, not a generic PCF standard.
• Performance and durability — rated capacity, expected cycle life, and degradation data over time for EV and LMT batteries specifically.
• Due diligence — supply-chain due diligence report references for the critical raw materials listed above.
• End-of-life — recycled content percentage, collection and recycling instructions.

Who's on the hook

The economic operator placing the battery on the EU market carries the compliance obligation. In practice, that's typically:

• The battery pack assembler, if cells are sourced from a separate manufacturer.
• The OEM, if batteries are integrated into a larger product (e.g. an EV) and sold under the OEM's own market placement.

This means passport data assembly is often a multi-tier supply chain exercise — the assembler needs verified data from cell suppliers, who in turn need due-diligence data from raw material suppliers.

Why this matters beyond batteries

Because the Battery Regulation's passport requirement is the first to have both a fixed date and a published data model, it's become the reference implementation other ESPR delegated acts (textiles, electronics) are expected to follow structurally, even though the specific fields will differ. Building a battery passport pipeline now is a reasonable template for what a textile or electronics passport pipeline will eventually need.