Why the EU Digital Product Passport Will Reshape Compliance for Battery Manufacturers in 2027

Article Highlights:

• Starting on February 18, 2027, every LMT battery, industrial battery with a capacity greater than 2 kWh, and electric vehicle battery placed on the EU market or put into service there must have a battery passport.

• The economic operator placing the battery on the EU market or putting it into service is responsible for fulfilling the battery passport obligations. That operator may authorize another party to act on its behalf, but the regulatory responsibility does not disappear simply because data collection or passport creation is outsourced.

• There isn’t just a single compliance deadline in 2027 for battery manufacturers. Rather, the EU is rolling out a sequence of requirements with different legal triggers.

On February 18, 2027, the EU digital product passport will become a compliance reality for a myriad of critical battery categories. On that date, every light means of transport (LMT) battery, industrial battery above 2 kWh, and electric vehicle battery placed on the EU market or put into service must have an electronic battery passport. It’s worth noting that this change is bigger than simply adding a QR code. It actually evolves compliance expectations, moving requirements toward a continuously maintained digital record that connects material composition, performance data, and supply chain evidence.

For battery manufacturers, the implication is straightforward. Compliance can no longer depend primarily on periodic declarations, spreadsheets, and one-and-done supplier campaigning. Instead, the underlying data must now be traceable, current, and capable of supporting the battery passport throughout its entire life cycle.

What Is the EU Digital Product Passport?

The EU Digital Product Passport is a structured digital record that connects a product to information about its characteristics, sustainability, compliance, and life cycle. The battery passport, meanwhile, is the battery-specific implementation required under the EU Batteries Regulation.

The broader Digital Product Passport (DPP) framework was established by the Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781. ESPR establishes the technical and governance framework for DPPs, including persistent product identifiers, data carriers, interoperability, access rights, data registries, and machine-readable data. The regulation is designed to make product information more accessible and improve traceability across value chains.

Batteries are among the first product categories where this digital approach becomes operational at scale. The Batteries Regulation, Regulation (EU) 2023/1542, creates a specific digital battery passport and requires it to be interoperable with other digital product passports established under EU ecodesign legislation.

This distinction matters. The battery passport is not simply another name for the generic ESPR DPP. It’s a battery-specific legal requirement under the Batteries Regulation, but its architecture is designed to operate within the broader EU digital product passport ecosystem.

Digital Product Passport vs. Battery Passport

The EU Digital Product Passport is the broader regulatory concept, while the EU Battery Passport is a specific application of that concept. The ESPR establishes the horizontal framework for digital product passports across product groups. The Batteries Regulation establishes the specific information, access, and lifecycle requirements for batteries.

For battery manufacturers, that means preparing for the battery passport also means preparing for a broader shift in how the EU expects product compliance information to be created and maintained.

Which Batteries Need a Digital Battery Passport by February 2027?

Starting on February 18, 2027, every LMT battery, industrial battery with a capacity greater than 2 kWh, and electric vehicle battery placed on the EU market or put into service there must have a battery passport.

This requirement comes directly from Article 77 of Regulation (EU) 2023/1542. It applies regardless of whether the battery manufacturer is established inside or outside the EU. As long as the in-scope battery is placed on the EU market, it requires a passport.

The responsible economic operator must ensure that the passport is placed on the battery, and that the information therein is accurate, complete, and up to date.

For companies outside the EU, the important question is therefore not simply where the battery manufacturer is located. The question is whether the battery is being placed on the EU market or put into service there.

Who Is Responsible for the Battery Passport?

The economic operator placing the battery on the EU market or putting it into service is responsible for fulfilling the battery passport obligations. That operator may authorize another party to act on its behalf, but the regulatory responsibility does not disappear simply because data collection or passport creation is outsourced.

This is one reason supplier data is now more important than ever. A battery manufacturer may own the final passport, but much of the information needed to populate and substantiate it originates elsewhere in the supply chain.

What Data Does the EU Digital Product Passport Require?

The EU Battery Passport requires a combination of battery model information, material and composition data, compliance information, performance characteristics, and individual-battery data. Further, the regulation requires that different information be made available to the public, authorities, and relevant stakeholders. Article 77 and Annex XIII divide passport information according to access rights, rather than making every data field accessible to everyone.

Publicly accessible information includes the following information:

• Battery identification and model information

• Material composition and battery chemistry

• Hazardous substances present in the battery

• Critical raw materials

• Carbon-footprint information

• Responsible sourcing information

• Recycled and renewable content information (when applicable)

• Rated capacity and voltage

• Power capability

• Expected battery lifetime

• Relevant performance and durability information

• EU declaration of conformity information

• Waste management information

More detailed information can be restricted to authorities, notified bodies, or key stakeholders. This can include detailed battery composition, dismantling guidelines, component information, test reports, and information needed to repair and remanufacture the battery.

The passport also contains information relating to the individual battery, including information that can change through use. Depending on the applicable battery category, this includes the state of health, battery status, charging and discharging cycles, negative events, operating conditions, and state of charge.

How the Passport Changes Compliance for Battery Manufacturers

The EU digital product passport changes battery compliance from periodic documentation collection to an ongoing data-management process. This is because the underlying information informing the passports must remain accurate, traceable, and accessible.

Traditional product compliance often works as a cycle. A manufacturer identifies a regulation, sends a supplier survey, collects declarations, stores the evidence, and uses that information to support a compliance assessment. When the regulation changes, the process starts again.

The battery passport introduces a different operating model. The manufacturer needs a persistent data structure connecting the battery to the evidence behind its compliance information. If the battery chemistry changes, a component supplier changes, a substance becomes restricted, or an individual battery's health status changes, the relevant information may need to be reflected in the compliance record.

The biggest challenge therefore is not generating a QR code—it’s maintaining the data behind the code.

The Data Starts Upstream

Much of the information needed for a battery passport doesn’t originate with the battery manufacturer. Consider a battery pack containing cells, electronic components, thermal-management materials, adhesive, and coatings. The manufacturer may know the part number and specification for each of these components. But more detailed compliance information on these materials is likely only available several layers upstream.

Cell suppliers may hold information about:

• Cathode and anode chemistry

• Electrolyte composition

• Critical raw materials

• Hazardous substances

• Recycled content

• Manufacturing location

• Carbon-footprint inputs

Component suppliers may hold information about:

• Material composition

• Substances of concern

• Regulatory thresholds

• Homogeneous material information

• Component manufacturing locations

• Supplier and manufacturer identity

• Changes to materials or processes

Data on raw materials often sits even further upstream. This makes supplier data collection a foundational part of passport compliance. A company cannot create a reliable digital battery passport if the underlying supply chain data is incomplete, outdated, or impossible to trace.

The 2027 Battery Compliance Calendar

There isn’t just a single compliance deadline in 2027 for battery manufacturers. Rather, the EU is rolling out a sequence of requirements with different legal triggers. Manufacturers should distinguish fixed dates from obligations whose application depends on future implementing measures.

The February 18, 2027 passport deadline should therefore be treated differently from some of the other sustainability requirements.

The battery passport itself has a defined legal application date. Regulation (EU) 2025/1561 postponed the battery due-diligence obligations from August 2025 to August 18, 2027, giving manufacturers additional time to establish their responsible-sourcing systems.

Carbon-footprint requirements require more nuance. The Battery Regulation establishes the eventual data requirements, methodologies, declarations, and performance classes, but their application depends in part on the relevant acts. The Commission currently notes that not all carbon footprint information will be required in the battery passport at the February 2027 launch, because the implementation framework is not yet complete.

How Z2 Supports Battery Passport Readiness

Z2Data helps battery manufacturers build the product, supplier, and regulatory data foundation needed to support battery passport readiness and the broader 2027 compliance landscape.

Z2’s compliance tool can help organizations sort through substance and regulatory information across products and components, providing a structured way to identify requirements, collect supplier evidence, and monitor compliance data.

The platform also provides visibility into data and compliance gaps, helping teams prioritize the parts, suppliers, and assemblies that require the most attention. This matters because battery passport readiness is primarily a data challenge, one made more complex by a high bar for traceability and supplier engagement.

Manufacturers that use a tool like Z2 to establish this compliance infrastructure before February 2027 will be better positioned to create battery passports and respond to the additional requirements entering into force in 2027 and beyond.

To learn how Z2 can help manufacturers effectively prepare for the EU Digital Product Passport’s impending battery requirements, schedule a free trial with one of our product experts.