Most of the Digital Product Passport conversation is about ESPR, which arrives category by category through the end of the decade. The battery passport is different: it comes from the EU Battery Regulation, it has a fixed date, and that date is 18 February 2027.
That makes it the first moment at which a European authority can ask a company for a working product passport and expect one to exist.
Who is in scope
The obligation covers LMT batteries (light means of transport — e-bikes, scooters), EV batteries, and industrial batteries above 2 kWh. Portable batteries — the cells in consumer electronics — are not covered by the passport requirement.
The duty sits with the economic operator placing the battery on the EU market. If you manufacture outside the EU, that is your importer, and they will require the underlying data from you. In practice, the request lands with the cell manufacturer and the pack assembler long before it lands with the importer.
What the passport has to contain
The battery passport is more prescriptive than anything ESPR has produced so far. Expect, broadly:
Identity and general information — manufacturer, battery model, place and date of manufacture, chemistry, weight. Performance and durability — rated capacity, expected lifetime, internal resistance, state of health parameters. Composition — materials, hazardous substances, and the recycled content of cobalt, lithium, lead and nickel. Carbon footprint — a declared value calculated according to the prescribed methodology. Supply chain due diligence — the report required under the regulation’s due diligence provisions. End of life — dismantling information and safety instructions for handling.
Access is tiered. Some fields are public; some are restricted to notified bodies and market surveillance authorities; some are available to legitimate businesses such as recyclers and repairers. Any system claiming to deliver a battery passport must implement that tiering, not merely publish a page.
Why this is harder than a textile passport
Three reasons, and they are worth understanding even if batteries are not your category — because they preview what mature DPP regimes look like.
The carbon footprint is a calculated value with a prescribed methodology, not a supplier-declared number. That is a genuine analytical workstream with a real lead time.
The recycled content figures require chain-of-custody evidence from your material suppliers. Assertion is not enough.
The state of health data is dynamic. Unlike a textile passport, which is largely static after publication, a battery passport is expected to reflect the battery’s condition over its life — which means your passport infrastructure needs an update path, not just a publish action.
If you are in scope and have not started
There is enough time, but not a lot of it. A workable sequence:
Confirm scope precisely — the 2 kWh industrial threshold excludes more products than people assume, and the first useful hour is spent establishing whether you are actually in scope.
Then start the carbon footprint work immediately, because it has the longest lead time of anything on the list. Everything else can move in parallel; this cannot be compressed at the end.
Next, send the recycled-content and due-diligence data requests up your supply chain, and expect the first round of answers to be incomplete.
Finally, choose infrastructure that handles tiered access and post-publication updates. A static hosted page will not satisfy this regulation, and rebuilding later is more expensive than choosing correctly now.
The wider signal
For companies outside the battery sector, February 2027 is still worth watching closely. It is the first real-world test of the EU DPP registry, of customs interaction with passport identifiers, and of whether the standards published in 2026 hold up in production.
Whatever breaks in batteries in early 2027 will shape how the textile and steel regimes are enforced afterwards.