Insights

The Digital Battery Passport under the EU Batteries Regulation: scope and timing

Which batteries need a passport, from when, and the access layers for its information.

Article 77 of the EU Batteries Regulation (EU) 2023/1542 sets out the Digital Battery Passport (DBP), which the Regulation calls the ‘battery passport’. Certain types of batteries are also the first product group for which a Digital Product Passport (DPP) becomes mandatory in the EU. This summary follows the text of the Regulation to help with project preparation.

  1. EU Batteries Regulation enters into force
  2. Deadline for legitimate-interest implementing acts (Art. 77(9))
  3. Digital Battery Passport applies
Three access layers
  1. PublicAnnex XIII point 1
  2. Persons with a legitimate interestAnnex XIII points 2 and 4
  3. Notified bodies · market surveillance · CommissionAnnex XIII point 3

Which batteries need a passport

Under Article 77(1), from 18 February 2027 the following batteries placed on the market or put into service in the EU shall have an electronic record (‘battery passport’):

  • Light means of transport (LMT) batteries
  • Industrial batteries with a capacity greater than 2 kWh
  • Electric vehicle batteries

What the passport contains

Information on the battery model and information specific to the individual battery, including information resulting from its use, as set out in Annex XIII. Information is included to the extent it applies to the battery category concerned.

Three access layers

  • Information accessible to the public (Annex XIII point 1), for example material composition, critical raw materials and collection and recycling information
  • Information accessible to persons with a legitimate interest (Annex XIII points 2 and 4; point 2 also to the Commission), for example detailed composition, part numbers and dismantling information
  • Information accessible only to notified bodies, market surveillance authorities and the Commission (Annex XIII point 3), for example test reports proving compliance

Access and responsibility

The passport is accessed through the QR code referred to in Article 13(6), which links to a unique identifier attributed by the economic operator placing the battery on the market. That operator ensures the information is accurate, complete and up to date and may authorise another operator in writing to act on its behalf.

After preparation for re-use, repurposing or remanufacturing, the responsibility passes to the operator that places the battery on the market or puts it into service again. The passport ceases to exist after the battery has been recycled.

What this means for preparation

  • Confirm early which battery category your product falls into
  • Map where the Annex XIII information comes from, inside and outside the company
  • Decide who creates and updates unit-level information
  • Follow the implementing acts the Commission publishes

Official sources

This article helps with project preparation and is not legal advice. Refer to the official text and professional advice for specific obligations.