Knowledge
Battery passport and Digital Product Passport
Why the battery passport is the EU's first mandatory DPP and how it relates to the Ecodesign Regulation.
As of October 2026
A Digital Product Passport (DPP) is an electronic record about a product, retrieved through a data carrier such as a QR code. The battery passport, mandatory from 18 Feb 2027, is the first product passport the EU makes binding. The general framework for further product groups is set by the Ecodesign for Sustainable Products Regulation (EU) 2024/1781, ESPR for short, in force since 18 Jul 2024.
Two regulations, one system
The battery passport is based on the Batteries Regulation (EU) 2023/1542, mainly Art. 77, Art. 78 and Annex XIII. The ESPR regulates the product passport in general. The two are interlinked:
- The battery passport must be fully interoperable with the product passports under ecodesign law in technical, semantic and organisational terms (Art. 78(a) Batteries Regulation).
- The ESPR inserted Art. 77(10) into the Batteries Regulation. Under it, the economic operator uploads the identifier of each battery to the DPP registry under Art. 13 ESPR.
- Art. 13(1) ESPR expressly names battery identifiers as content of this registry.
What the battery passport already lays down
Many principles meant to apply to all product passports in future are already law for batteries:
- A unique identifier per battery, linked to the QR code (Art. 77(3)).
- Three access levels: public, authorities, persons with a legitimate interest (Art. 77(2)).
- Open standards, machine-readable, structured, searchable and transferable without vendor lock-in (Art. 77(5)).
- Decentralised storage by the responsible economic operator or an authorised service provider (Art. 78(c)).
- Availability even after the economic operator ceases to exist (Art. 78(e)).
The DPP registry
The registry under Art. 13 ESPR is governed by Implementing Regulation (EU) 2026/1778. It has been online since 20 Jul 2026. It stores no passport data, only the identifier, details of the registrant, a timestamp and a checksum of the passport version. As of October 2026, battery passports cannot yet be registered there because the data catalogue for batteries is missing. More on this in the article on the EU registry.
Identifiers and standards
For batteries, Art. 77(3) prescribes the ISO/IEC 15459 series or equivalent standards. The ESPR also provides for unique identifiers for economic operators and facilities. The European standardisation organisations CEN and CENELEC published six cross-product standards for product passports on 27 May 2026, including EN 18219 (identifiers), EN 18220 (data carriers) and EN 18223 (interoperability). The Commission referenced them in the Official Journal with Implementing Decision (EU) 2026/1736 of 15 Jul 2026. Two further standards on access rights and data integrity had not yet been referenced as of October 2026.
Which product groups follow
Under the ESPR, a product only needs a passport once a delegated act for its product group requires one. The Commission's first working plan of 16 Apr 2025 lists as priorities steel and aluminium, textiles with a focus on apparel, furniture, tyres and mattresses. For textiles, the Commission plans the delegated act for 2027. The obligation only starts after a transition period. As of October 2026 there were no binding dates for other product groups.
What this means for you
- Setting up a battery passport today builds processes you will later need for other products as well: maintaining master data, querying suppliers, assigning identifiers, printing labels.
- Keep your data in the official format. Batterypass Online follows the official attribute list (version 2.0), and every passport can be exported as JSON.
- With any provider, check data export and portability, because Art. 77(5) prohibits vendor lock-in.
Do you need a battery passport? Two or three questions and you know.
Take the obligation checkSources
- Regulation (EU) 2023/1542, Art. 77 and 78 (EUR-Lex)
- Regulation (EU) 2024/1781 (Ecodesign, ESPR), Art. 9 to 13 (EUR-Lex)
- European Commission: Digital product passport for batteries
This article summarises the legal situation in plain language and is not legal advice. The text of the regulation is authoritative.