EU Battery Passport: What Every Brand Should Know (2026)

The EU Battery Passport is a mandatory digital record, reached through a QR code. From February 18, 2027, three kinds of battery placed on the EU market or put into service must have one: EV batteries, light means of transport (LMT) batteries such as e-bike and e-scooter batteries, and industrial batteries over 2 kWh (Regulation (EU) 2023/1542, Article 77(1)). Batteries are the first product group for which a Digital Product Passport becomes mandatory in the EU. How the battery passport works in practice is likely to shape the passports for textiles, furniture, electronics and other product groups under the ESPR (Regulation (EU) 2024/1781).

What Does the EU Battery Passport Require?

Annex XIII of Regulation (EU) 2023/1542 lists what the battery passport must contain. We group it here under five headings.

Product Identity and Specifications

Each battery that needs a passport has its own passport, with its own unique identifier (Article 77(1) and (3)). This is not a model-level identifier. The company that places the battery on the market or puts it into service uploads that identifier to the EU registry (Article 77(10)). The passport data itself is stored by the company responsible for the passport, or by a company authorized to act on its behalf (Article 78(c)). At first, the responsible company is the one that places the battery on the market.

The required identity fields are:

• Unique battery identifier (under ISO/IEC 15459 or an equivalent, Article 77(3))
• Battery chemistry and type (e.g., lithium-ion NMC, LFP, solid-state)
• Rated capacity, voltage and weight
• Manufacturing date and place of manufacture
• Information identifying the manufacturer and the battery (Annex VI, Part A)

This serial-level traceability is a significant requirement, and not every DPP tool is built to hold it — we signed in to four platforms to see which battery fields their forms actually ask for. For textile DPPs, a study prepared for the JRC (May 2026) proposes a passport for each batch at minimum, filled with model-level data, and with batch-level data where products vary. Item-level identifiers would be voluntary. The study does not necessarily reflect the Commission's position. The battery passport's per-unit approach remains the most demanding end of that spectrum.

Environmental Data

The environmental data requirements under the Battery Regulation (EU) 2023/1542 are among the most granular ever imposed on a product category. Among them:

• Carbon footprint: kilograms of CO2 equivalent per kWh of the total energy the battery provides over its expected service life (Article 7(1)). It covers raw material acquisition and pre-processing, main product production, distribution, and end of life and recycling. The use phase is excluded, unless the manufacturer's design choices are shown to make a non-negligible contribution to it (Annex II, point 4)
• Carbon footprint performance class: the class the battery model from a given manufacturing plant belongs to, declared on its carbon footprint label (Article 7(2)). The law gave the Commission deadlines for the acts behind these values. For EV batteries, the calculation method was due by 18 February 2024 and the performance classes by 18 February 2025. The Commission's battery FAQ says the declaration's format "still must be specified in upcoming implementing acts"
• Recycled content percentages: the shares of cobalt, lead, lithium and nickel recovered from waste. From 18 August 2031, the rule covers EV batteries, industrial batteries over 2 kWh (except those with exclusively external storage) and SLI batteries, when their active materials contain cobalt, lead, lithium or nickel. Their technical documentation must show minimum recycled shares of 16% of the cobalt, 85% of the lead, 6% of the lithium and 6% of the nickel. From 18 August 2036, the cobalt, lithium and nickel shares rise, and LMT batteries are added (Article 8(2) and (3))

None of the three above is due on 18 February 2027 — but one environmental value is. The share of renewable content, Annex XIII 1(f), is marked mandatory for all three battery categories on that date by the Commission's guidance. The Commission's guidance document, in its version 3.2 of 19 October 2026, marks the carbon footprint declaration, the carbon footprint label and all four recycled-content shares "not to be filled/displayed as of February 2027". The law ties each of these values to a Commission act and a fixed date, whichever comes later. For recycled content, that date is 18 August 2028 at the earliest (Article 8(1)). The obligations are real; they start later than the passport. That guidance is not law: it states that it does not represent the Commission's official position, so read it as the Commission's current guidance, not as permission. We set out what a battery passport actually needs on day one field by field.

Update, 29 October 2026. The Commission replaced version 2.0 of this guidance, dated 15 August 2026, with version 3.2, dated 19 October 2026. Its verdicts on these fields did not change.

A study prepared for the JRC (May 2026) proposes something similar for textiles: a carbon footprint class, an absolute footprint value and a robustness score.

Performance and Lifecycle Data

Unlike a static product label, the battery passport holds data about each individual battery through its life. Point 4 of Annex XIII lists it, for people with a legitimate interest:

• The values of the performance and durability parameters in Article 10(1), when the battery is placed on the market and when its status changes
• Information on the state of health under Article 14. For EV batteries, this is the state of certified energy. For stationary storage systems and LMT batteries, it includes the remaining capacity (Annex VII)
• The status of the battery: original, repurposed, re-used, remanufactured or waste
• Data from its use, including the number of charging and discharging cycles, negative events such as accidents, and periodically recorded operating conditions, including temperature and the state of charge

Article 14 adds a rule for the battery management system of stationary battery energy storage systems, LMT batteries and EV batteries. It must hold up-to-date data for determining the battery's state of health and expected lifetime (Annex VII).

This lifecycle tracking is the most technically challenging requirement — and the most relevant precedent for other DPPs. It requires the battery passport to be a living document, updated through the product's service life, at least whenever the battery's status changes. Textile DPPs are unlikely to require per-item lifecycle values, but the infrastructure for ongoing data updates (not just one-time declarations) is being established through the battery passport. The CEN-CENELEC Joint Technical Committee 24 (JTC 24) writes the standards for this data exchange. They are horizontal standards, written for passports under the ESPR (Regulation (EU) 2024/1781), and the Commission also points battery companies to them.

Composition and Materials

The passport describes what is inside the battery model. Part of it is public, and part is only for people with a legitimate interest and for notified bodies and authorities (Article 77(2) and Annex XIII). The passport must include:

• The material composition, which is public: the chemistry, the hazardous substances present other than mercury, cadmium or lead, and the critical raw materials present (Annex XIII 1(b)). A hazardous substance is one classified as hazardous under the CLP Regulation (EC) 1272/2008 (Article 3)
• Information on responsible sourcing, as given in the due diligence report of the company that places the battery on the market, which is also public (Annex XIII 1(d) and Article 52(3)). The due diligence rules apply from 18 August 2027
• The detailed composition, including the materials used in the cathode, anode and electrolyte. Only people with a legitimate interest, notified bodies, market surveillance authorities and the Commission may see it (Article 77(2) and Annex XIII 2(a))

This level of material transparency has a direct parallel for textiles. The study prepared for the JRC proposes that the textile passport include substances of concern and recycled content. Brands that already track their material inputs in detail will have a significant head start.

End-of-Life Information

The circular economy is central to the Battery Regulation (EU) 2023/1542. The passport carries the information that collection, repair and recycling depend on:

• Information on the prevention and management of waste batteries, which is public. It covers separate collection, take-back and collection points, preparation for re-use and repurposing, and the treatment available, among other points (Annex XIII 1(s) and Article 74(1))
• Dismantling information, including exploded diagrams, disassembly sequences, fastening techniques, tools and warnings, together with safety measures. Only people with a legitimate interest, notified bodies, market surveillance authorities and the Commission may see it (Article 77(2) and Annex XIII 2(c) and (d))
• Part numbers for components and contact details of sources for replacement spares, for the same readers (Annex XIII 2(b))

This end-of-life transparency is a blueprint for textile DPPs. The study prepared for the JRC proposes fibre composition, a recyclability score and disassembly information for the textile passport.

Why Should Non-Battery Brands Care About the Battery Passport?

If you sell clothing, not batteries, why should you pay attention? Because the battery passport establishes three critical precedents.

Precedent 1: The Technical Architecture

The battery passport and the expected textile DPP share most of their building blocks. The GS1 entries show one common way to build them:

If you understand the battery passport technically, you understand most of how the textile DPP will work. The differences are mainly in the data fields, plus the backup copy and the access rules shown above. For more on the technical details of QR codes and GS1 Digital Link, see our product passport QR code guide.

Precedent 2: The Enforcement Model

The battery passport will be the first test of whether the EU can actually enforce DPP compliance at scale. The EU General Product Safety Regulation (GPSR, Regulation (EU) 2023/988), which took effect in December 2024, already strengthened market surveillance powers — and the DPP registry adds a digital enforcement layer on top. What to watch:

• Customs enforcement: Customs is not required to check a battery passport in the registry before releasing the battery. The European Commission's battery passport FAQ says a battery passport's registration identifier does not go on the customs declaration. An importer still needs the passport, because the import normally places the battery on the EU market. ESPR products are different. Once the registry connects to national customs systems, customs will check that the product's registration identifier and commodity code match the registry before release (ESPR Article 15(2)). That connection is due by August 2030 (ESPR Article 15(3)).
• Market surveillance: How quickly do national authorities act on non-compliant products? Under ESPR (Regulation (EU) 2024/1781), penalties must be "effective, proportionate and dissuasive". Each member state sets its own fine levels
• Marketplace gatekeeping: Will Amazon, eBay, and other platforms pre-screen for battery passport compliance? Online service providers, platforms included, must already cooperate with market surveillance authorities on request, to remove or reduce the risks of a product sold through them (Regulation (EU) 2019/1020, Article 7(2)). Online marketplaces also have product safety duties under the GPSR (Article 22)
• Grace period reality: How much tolerance will authorities show for incomplete data in the first months? Nobody can tell yet

The answers will directly inform how aggressive enforcement is for textile DPPs when they become mandatory. See our DPP penalties guide for what non-compliance looks like.

What the Commission Clarified on 30 September 2026

At its battery passport webinar on 30 September 2026, the European Commission said:

• The company that places the battery on the EU market registers it in the EU registry itself. The Commission's battery FAQ says so, and its speakers said this cannot be delegated under the current rules.
• No fixed update frequency is set, and daily updates are not required. At a minimum, the data that changes during the battery's life must be updated when its status changes or a change is being considered (battery FAQ 8.3).
• A battery placed on the EU market before 18 February 2027 needs no passport, even if it reaches the end user later.
• In general, a replacement module for an existing battery is not a battery in its own right and needs no passport of its own.
• A repurposed battery gets a new passport, linked to the original one, often under a new economic operator.

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The Commission also gave dates for its own next steps:

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You can enrol and verify your organisation today. The Commission has published the data model for batteries, in documents dated 30 October 2026. On 6 November 2026 we could not register a battery in the test registry, because its content check was not running yet. Our step-by-step guide to enrolling in the EU DPP Registry goes through each screen in order.

Precedent 3: The Delay Pattern

The Battery Regulation (EU) 2023/1542 shows how EU product rules handle implementation difficulties, and the pattern is instructive. Supporting requirements have slipped, while the headline passport date has held:

The pattern: supporting requirements get delayed, but the core passport deadline holds. REACH (Regulation (EC) 1907/2006) followed the same path: its registration deadlines did not move. For textiles under ESPR (Regulation (EU) 2024/1781), the delegated act may slip too. The Commission now plans it for the second half of 2027, and a JRC presentation in May 2025 still showed early 2027 for apparel. Once the act is adopted, it sets its own application date. Do not confuse delayed delegated acts with a delayed mandate.

What Is the Battery Passport Implementation Timeline?

Already in Effect

Coming Next

The harmonized labels come after the passport mandate, not before it. Every battery, or the packaging of a very small one, must already carry the separate collection symbol, required since 18 August 2025 (Article 13(4)). The QR code follows for all batteries on February 18, 2027.

What Does the Battery Passport Reveal About DPP Costs?

Batteries are the first product group to build passports, so they show where the cost of a passport lies for other product groups under ESPR (Regulation (EU) 2024/1781). The comparison below is our own assessment, not measured data:

In our assessment, the biggest cost is the work of collecting data, not the software: collecting data from upstream suppliers, checking it against the rules, and keeping it current as products change. This applies equally to textiles, where tracing fiber origins, chemical inputs, and manufacturing conditions across multi-tier supply chains is the core challenge. See our DPP compliance cost breakdown for detailed estimates.

What Can Fashion Brands Learn from the Battery Passport?

1. Start Data Collection Before the Deadline

Battery manufacturers who started data collection in early 2025 had, as of September 2026, been at it about eighteen months longer than a brand starting then. Anyone starting later has to map their supply chains, collect material composition data, and integrate with a DPP platform inside whatever time is left before 18 February 2027.

For textiles, the Commission plans to adopt the delegated act under ESPR (Regulation (EU) 2024/1781) in the second half of 2027. Its requirements cannot apply earlier than 18 months after it enters into force, except in duly justified cases (ESPR Article 4(4)). That sounds like plenty of time, but textile supply chains are often spread across many suppliers and countries. Start collecting material composition, supply chain, and environmental data now, while there is no deadline pressure, and you will avoid a rush at the end.

2. Choose Standards-Based Infrastructure

A battery passport needs a unique identifier and data that other systems can read. The Battery Regulation requires the QR code and the unique identifier to follow the ISO/IEC 15459 standards or their equivalent (Article 77(3)). It does not name GS1, and the EU registry does not require GS1 either. GS1 is an issuing agency under ISO/IEC 15459, so GS1 identifiers are one common way to meet the rule. GS1 Digital Link is one standard way to put such an identifier in a web address.

Textile passports under ESPR (Regulation (EU) 2024/1781) need a unique product identifier as well, one that also enables a web link to the passport (ESPR Article 2(30)). GS1 Digital Link has its own standard, the GS1 Digital Link Standard: URI Syntax, which defines how such an identifier is written in a web address. A resolver then sends the reader on to the passport. For details on how GS1 Digital Link works for product passports, see our product passport QR code guide.

3. Plan for Tiered Access

The Battery Regulation (EU) 2023/1542 sets out who may read which part of the battery passport (Article 77(2) and Annex XIII). Some data is public, for anyone scanning the QR code. Some is only for people with a legitimate interest and for notified bodies and authorities. The Regulation sets the purposes for which someone has a legitimate interest, and names the people those purposes are for. Repairers, remanufacturers, second-life operators and recyclers may see what they need for dismantling and the detailed composition. The purchaser of a battery, or parties acting on the purchaser's behalf, may see the data about that battery to offer it to independent energy aggregators or energy market participants. Test reports are only for notified bodies, market surveillance authorities and the Commission. The Commission's battery FAQ says its coming implementing act "will determine who may access restricted data and what they may do with it, but not the detailed authentication mechanism".

ESPR (Regulation (EU) 2024/1781) does not set these tiers itself. It leaves them to the delegated act for each product group, adopted under Article 4. No textile delegated act exists yet, so the exact tiers are still open. That means your DPP platform must support role-based access control from the start — not as an afterthought. Fashion brands should keep the data that only some readers may see separate from the data every reader sees.

4. Expect Enforcement to Ramp Quickly

The EU is building the tools to enforce passports. The central DPP registry (ESPR (Regulation (EU) 2024/1781) Article 13) has been live since 20 July 2026. A link to customs through the EU Single Window Environment for Customs (Regulation (EU) 2022/2399) is due by August 2030. The Union Product Compliance Network coordinates market surveillance (Regulation (EU) 2019/1020, Article 29). By the time textile DPPs become mandatory, national market surveillance authorities will have years of battery passports behind them. Customs is different: it is not required to verify battery passports in the registry before release, so the registry check at the border starts with ESPR products.

Plan as if the textile requirements apply in full from their first day.

5. The Delay Pattern Is Not Permanent

Battery due diligence obligations got a 2-year delay (from August 2025 to August 2027, via Regulation (EU) 2025/1561), and the carbon footprint declaration still waits for the Commission's acts. But the core battery passport deadline of February 18, 2027 has not moved by a single day. Supporting measures can slip, but the headline mandate has held.

Do not assume textile DPP deadlines will be pushed back just because the delegated act is taking time. Once the textile delegated act under ESPR (Regulation (EU) 2024/1781) is published, the compliance clock starts. Build your timeline assuming the published dates hold, and treat any delay as bonus preparation time, not an excuse to wait.

How PassportCraft Fits In

PassportCraft publishes battery passports today, alongside textile and general product passports. What a battery passport asks of you:

• The same technical base as every other passport we publish: a GS1 Digital Link address when the battery has a GTIN, machine-readable JSON-LD, and data split by who may read it
• A unique identifier for each battery, because the Regulation records data about the individual item
• Supply-chain data from your cell supplier, which is often the slowest part for importers
• A public part anyone scanning the QR code can read. Restricted and authority values stay off the public page

See what battery passport software has to cover. Start free with PassportCraft and create your first battery passport today. The deadline is 18 February 2027.