EU Digital Battery Passport (DBP) Compliance Service

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From 18 February 2027, certain batteries placed on the European Union market or put into service must have an individual Digital Battery Passport (DBP) under Regulation (EU) 2023/1542.

EaseCert provides a complete Digital Battery Passport compliance and implementation service for manufacturers, importers and other economic operators preparing for the EU battery passport requirements.

One-time fee. No EaseCert subscription. No annual EaseCert compliance fee.

Which Batteries Require an EU Digital Battery Passport?

From 18 February 2027, the Digital Battery Passport requirement applies to:

  • Light Means of Transport (LMT) batteries, including batteries used in e-bikes and e-scooters
  • Industrial batteries above 2 kWh
  • Electric vehicle (EV) batteries

Each battery falling within the requirement must have an electronic passport associated with that individual battery.

What Is an EU Digital Battery Passport?

A Digital Battery Passport is an electronic record for an individual battery. It connects the physical battery to structured regulatory, technical and lifecycle information through a QR code and unique identifier.

The basic structure is:

Battery → QR Code → Unique Identifier → Digital Battery Passport → EU Digital Product Passport Registry

The QR code is the access point. The unique identifier identifies the individual battery. The Digital Battery Passport is the structured electronic record containing the applicable information. The EU Digital Product Passport Registry records the identifier and associated registration information.

The QR Code

The QR code is printed, engraved or otherwise applied to the battery in accordance with the applicable requirements. Where direct marking is not possible, applicable rules may allow the QR code to appear on packaging and accompanying documentation.

Scanning the QR code provides access to the Digital Battery Passport associated with that battery.

The Unique Battery Identifier

Each battery requiring a Digital Battery Passport must have a unique identifier. The identifier connects the physical battery to its digital record and must follow the applicable identification requirements, including the ISO/IEC 15459 framework.

Where appropriate, existing GS1 identification structures can form part of the implementation.

The Digital Battery Passport Record

The passport is a structured, machine-readable electronic record rather than a conventional PDF or static webpage.

It contains different categories of information depending on who is accessing the passport and what information they are entitled to view.

The EU Digital Product Passport Registry

The EU Digital Product Passport Registry acts primarily as an index rather than the host of the complete passport. The passport itself must therefore exist and remain accessible separately.

The responsible economic operator must register the applicable battery identifier and registration information with the EU system.

Why Is a QR Code or PDF Not Enough?

A QR code is only the data carrier. It is not the Digital Battery Passport itself.

Similarly, linking a QR code to an ordinary PDF or conventional product webpage does not by itself provide the complete Digital Battery Passport architecture required under EU legislation.

The underlying passport must meet applicable requirements concerning:

  • Structured and machine-readable data
  • Interoperability
  • Searchability
  • Data portability
  • Access rights
  • Data integrity
  • Security
  • Lifecycle updates
  • Long-term availability
  • Transferability without vendor lock-in

The passport must also control which information is publicly available and which information may only be accessed by authorised persons, persons with a legitimate interest or competent authorities.

What Information Is Included in the Battery Passport?

The applicable information is defined primarily through Annex XIII of Regulation (EU) 2023/1542 and related provisions of the Battery Regulation.

Depending on the battery and applicable implementation date, information can include:

  • Battery identification
  • Manufacturer information
  • Battery category
  • Manufacturing location and date
  • Battery chemistry
  • Battery weight
  • Rated capacity
  • Voltage
  • Power capability
  • Internal resistance
  • Expected battery lifetime
  • Expected number of cycles
  • Temperature range
  • Capacity fade
  • State of health
  • Hazardous substances
  • Critical raw materials
  • Recycled material information
  • Dismantling information
  • Replacement spare-part information
  • Safety information
  • End-of-life information
  • Carbon-footprint information where applicable
  • Responsible sourcing and due-diligence information where applicable

Different Battery Passport Access Levels

Not everyone accessing a Digital Battery Passport is entitled to see the same information. The EU framework distinguishes between different categories of passport data.

Public Battery Information

Public information can include model-level information such as battery chemistry, capacity, identification information and expected lifetime.

Information for Persons with a Legitimate Interest

Certain technical information can be restricted to eligible parties such as repairers, remanufacturers, second-life operators and recyclers with a legitimate interest.

This can include detailed composition, spare-part information, dismantling instructions and safety information.

Information for Authorities

Certain compliance information, including applicable test documentation, may be restricted to competent authorities, notified bodies or other authorised institutions.

Individual Battery Information

The passport can also contain information relating specifically to the individual battery, including applicable state-of-health, status and use information.

What Does EaseCert Provide?

1. Digital Battery Passport Applicability Assessment

EaseCert first determines whether your battery falls within the Digital Battery Passport requirements.

We review factors including:

  • Battery category
  • Intended use
  • Energy capacity
  • Product configuration
  • EU market placement structure
  • Manufacturer and importer responsibilities
  • Responsible economic operator
  • Applicable implementation dates

2. Annex XIII Data Gap Assessment

EaseCert reviews your existing battery documentation against the applicable Digital Battery Passport data requirements.

We identify which information is already available, which information requires additional verification and which data points are still missing.

3. Battery Passport Data Preparation

We structure the available product and compliance information according to the applicable requirements of Regulation (EU) 2023/1542 and Annex XIII.

This includes separating information according to its applicable access category and preparing the information for implementation within the Digital Battery Passport.

4. Unique Identifier Implementation

EaseCert assists with establishing the appropriate identification structure for the batteries covered by the project.

This includes consideration of applicable ISO/IEC 15459 requirements and existing GTIN or GS1 identification structures where relevant.

5. QR Code Creation and Implementation

A QR code is created for the Digital Battery Passport and can be integrated into the applicable battery marking, label, packaging or accompanying documentation.

EaseCert reviews the proposed implementation to ensure the Digital Battery Passport information is incorporated into the product labelling structure correctly.

6. Digital Battery Passport Creation

EaseCert creates the structured Digital Battery Passport record based on the verified information supplied by the manufacturer.

The passport associates the individual battery with the applicable regulatory, technical and lifecycle information.

7. Digital Battery Passport Hosting

The complete passport is not hosted by the EU Digital Product Passport Registry. The underlying electronic record must remain hosted and accessible separately.

As part of the EaseCert service, dedicated Digital Battery Passport infrastructure is used to maintain the structured electronic record and provide access through the battery's QR code.

There is no annual EaseCert subscription or recurring EaseCert compliance fee.

8. EU Digital Product Passport Registry Support

EaseCert prepares the information required for registration of the battery identifier with the EU Digital Product Passport Registry and guides the responsible economic operator through the registration process.

Under the current battery passport framework, the registration must be completed under the verified status of the economic operator placing the battery on the EU market.

One Passport Per Battery

The Digital Battery Passport operates at the individual battery level.

Multiple batteries of the same model may share substantial model-level technical information, but individual batteries still require their own identifiers and individual passport records where the Digital Battery Passport requirement applies.

Example

Battery Model ABC-48
Battery 000001 → Unique ID → Passport 000001
Battery 000002 → Unique ID → Passport 000002
Battery 000003 → Unique ID → Passport 000003

This individual identification becomes particularly important for lifecycle information such as battery status, use and state of health.

Updating the Digital Battery Passport

The Digital Battery Passport is not necessarily a static record.

The economic operator remains responsible for ensuring that applicable passport information remains accurate, complete and up to date.

Where information changes, the electronic record behind the identifier can be updated without necessarily replacing the QR code already applied to the battery.

Repairs

A simple repair does not automatically require the creation of a completely new passport.

Repurposed or Remanufactured Batteries

A repurposed or remanufactured battery requires a new passport linked to the original passport. The economic operator placing the repurposed or remanufactured battery back on the market assumes the applicable responsibilities.

End of Life

When a battery becomes waste, the applicable passport responsibilities may pass to the producer, producer responsibility organisation or waste management operator. Once the battery has been recycled, the passport ceases to exist.

Long-Term Passport Availability

The Digital Battery Passport must remain available throughout the applicable battery lifecycle, including where the original economic operator ceases to exist or ceases its activities in the European Union.

The passport architecture must therefore support long-term availability, data portability and transfer to another operator where necessary.

Manufacturer and Economic Operator Responsibilities

Using EaseCert to assist with Digital Battery Passport implementation does not transfer the underlying legal responsibility of the relevant economic operator.

The responsible company must ensure that:

  • The information provided for the passport is correct
  • The passport information remains accurate and complete
  • Applicable dynamic information is updated
  • Each applicable battery receives the required unique identifier
  • The QR code is applied correctly
  • The required EU registry registration is completed
  • EaseCert is informed of relevant changes affecting the passport

EaseCert Digital Battery Passport Compliance Package

Our service can include:

  • Digital Battery Passport applicability assessment
  • Regulatory review under Regulation (EU) 2023/1542
  • Annex XIII data-gap analysis
  • Review of available battery documentation
  • Battery passport data preparation
  • Structuring of public and restricted passport information
  • Unique identifier implementation support
  • QR code creation
  • QR code and battery label review
  • Digital Battery Passport creation
  • Passport publication
  • Dedicated passport hosting
  • EU Digital Product Passport Registry preparation
  • Registry registration guidance
  • Lifecycle update framework
  • Passport data portability support
  • Regulatory implementation support

One-Time Fee, No Subscription

€500 per Battery Product Group

Setup & Documentation Fee: €50 per order

EaseCert follows a straightforward one-time fee model. There is no annual EaseCert subscription, recurring EaseCert membership or annual EaseCert compliance fee for this service.

Manufacturers with large battery portfolios, high production volumes or substantial individual-unit passport requirements will receive a fixed project quotation based on the required implementation scope.

Battery Product Grouping

Multiple battery models can only be grouped where their relevant regulatory and technical characteristics are sufficiently equivalent.

EaseCert considers factors including:

  • Battery category
  • Intended function
  • Chemistry
  • Construction
  • Technical characteristics
  • Capacity range
  • Manufacturing process
  • Manufacturer and factory
  • Applicable regulatory requirements
  • Safety characteristics
  • Risk profile

Grouping the technical compliance assessment does not remove the requirement for individual battery identification where an individual Digital Battery Passport is required.

What Documents Do We Need?

To start the assessment, please provide all available battery and compliance documentation.

This can include:

  • Product list and SKUs
  • Battery specifications
  • Battery datasheets
  • Product photographs
  • Manufacturer details
  • Manufacturing location
  • Battery chemistry
  • Capacity and voltage information
  • BOM and material information
  • Test reports
  • EU Declaration of Conformity where applicable
  • Safety documentation
  • Battery performance and durability data
  • Carbon-footprint information where applicable
  • Responsible sourcing information where applicable
  • Dismantling and repair information
  • Existing GTIN or GS1 information
  • Battery labels
  • Packaging artwork
  • User manuals and accompanying documentation

You do not need to have every required data point available before starting. EaseCert can first conduct the gap assessment and identify what additional information is required.

Prepare Before the 18 February 2027 Deadline

The Digital Battery Passport requirement becomes applicable on 18 February 2027 for the relevant battery categories.

Manufacturers should prepare their underlying battery data, identification structure, passport architecture and QR code implementation before the application date rather than waiting until batteries are ready to enter the EU market.

Frequently Asked Questions

What is an EU Digital Battery Passport?

An EU Digital Battery Passport (DBP) is an electronic record associated with an individual battery. It contains structured regulatory, technical and lifecycle information and is accessed through a QR code and unique battery identifier.

When does the EU Digital Battery Passport become mandatory?

The Digital Battery Passport requirement applies from 18 February 2027 to the battery categories covered by Article 77 of Regulation (EU) 2023/1542.

Which batteries require a Digital Battery Passport?

The requirement applies to Light Means of Transport (LMT) batteries, such as batteries used in e-bikes and e-scooters, industrial batteries above 2 kWh, and electric vehicle (EV) batteries.

Does every battery need its own Digital Battery Passport?

For batteries within the scope of the requirement, the passport operates at individual-battery level. Batteries of the same model can share model-level information, but each individual battery must have its own unique identifier and associated passport record.

Is a QR code enough to comply with the Digital Battery Passport requirements?

No. The QR code is the data carrier that provides access to the passport. The Digital Battery Passport itself is the structured electronic record behind the QR code and unique identifier.

Can we simply link the QR code to a PDF?

No. A static PDF alone does not provide the structured, machine-readable, interoperable, searchable, access-controlled and updateable record required by the Digital Battery Passport framework. The passport must also support data portability, security and long-term availability.

Can we host the Digital Battery Passport on our normal website?

EU legislation does not prohibit an economic operator from operating its own passport infrastructure. However, the system must meet the applicable requirements for structured and machine-readable data, interoperability, access control, security, data integrity, portability, lifecycle updates and long-term availability. A conventional product webpage will generally not provide these functions by itself.

What information is included in a Digital Battery Passport?

The required information depends on the battery and applicable implementation dates. It can include battery identification, manufacturer information, chemistry, capacity, voltage, weight, manufacturing information, expected lifetime, performance and durability data, hazardous substances, critical raw materials, recycled content, dismantling information, safety information, state of health and other information required under Regulation (EU) 2023/1542 and Annex XIII.

Is all information in the battery passport publicly available?

No. The EU framework distinguishes between different categories of information. Some information is publicly accessible, while other information is restricted to persons with a legitimate interest, competent authorities, notified bodies or other authorised parties.

What is the unique battery identifier?

The unique identifier connects the physical battery to its Digital Battery Passport. Each applicable battery must receive an individual identifier in accordance with the applicable identification requirements, including the ISO/IEC 15459 framework.

Can existing GS1 or GTIN identifiers be used?

Existing GS1 identification structures may form part of the implementation where appropriate. EaseCert reviews the manufacturer's existing identification system and determines how it can be incorporated into the Digital Battery Passport structure.

Where must the QR code be placed?

The QR code is generally marked on the battery. Where direct marking is not possible, the applicable rules provide for placement through the packaging and accompanying documentation under the conditions established by the Battery Regulation. EaseCert reviews the proposed QR code and labelling implementation as part of the service.

What is the EU Digital Product Passport Registry?

The EU Digital Product Passport Registry is the European Commission's central registry for Digital Product Passport identifiers and registration information. It functions primarily as an index. It does not replace or host the complete Digital Battery Passport.

If the EU has a registry, why does the passport need separate hosting?

Because the EU registry and the Digital Battery Passport perform different functions. The registry records identifiers and registration information, while the actual passport contains the structured battery data. The passport therefore needs to be created, hosted, maintained, updated and access-controlled separately.

Does EaseCert register the battery passport with the EU registry?

EaseCert prepares the information required for registration and guides the responsible economic operator through the registration process. Under the current framework for batteries, registration must be completed under the verified status of the economic operator placing the battery on the EU market.

What happens when information in the battery passport changes?

The electronic record behind the battery identifier can be updated. The unique identifier and QR code can remain associated with the same battery, meaning an existing QR code does not normally need to be replaced simply because passport information has been updated.

What happens if a battery is repaired?

A simple repair does not automatically require a new Digital Battery Passport. The existing passport can continue to follow the battery, subject to any required updates to its information.

What happens if a battery is repurposed or remanufactured?

A repurposed or remanufactured battery receives a new Digital Battery Passport linked to the original passport. The economic operator placing the repurposed or remanufactured battery back on the market assumes the applicable passport responsibilities.

How long must a Digital Battery Passport remain available?

The passport must remain available throughout the applicable lifecycle of the battery, including where the original economic operator ceases to exist or ceases its activities in the European Union. Under the Battery Regulation, the passport ceases to exist once the battery has been recycled.

What happens if we change our passport service provider?

The Digital Battery Passport framework requires data portability and transferability without vendor lock-in. The passport architecture must therefore allow the relevant data and responsibilities to be transferred where necessary without losing the connection between the battery and its regulatory record.

Who is legally responsible for the Digital Battery Passport?

The economic operator placing the battery on the EU market remains responsible for the applicable passport obligations, including ensuring that the information is accurate, complete and up to date. Using EaseCert for implementation support does not transfer the economic operator's underlying legal responsibilities.

What does the EaseCert Digital Battery Passport Compliance Service include?

The service can include applicability assessment, Annex XIII data-gap analysis, review of battery documentation, passport data preparation, unique identifier implementation support, QR code creation, passport creation and publication, dedicated passport hosting, label review, EU registry preparation, registration guidance and lifecycle implementation support.

What documents do you need to start?

We recommend providing all available product and compliance documentation, including battery datasheets, specifications, product photographs, manufacturer information, battery chemistry, capacity and voltage data, BOM information, test reports, safety documentation, performance and durability data, applicable declarations, dismantling information, existing GTIN or GS1 information, labels, packaging and accompanying documentation.

Can we start if some battery passport information is still missing?

Yes. EaseCert can first perform a data-gap assessment. We identify which information is already available and provide a clear overview of the additional information required before the passport can be completed.

Can several battery models be grouped together?

Potentially. EaseCert assesses grouping based on factors such as battery category, function, chemistry, construction, technical characteristics, capacity, manufacturing process, factory, applicable requirements and risk profile. Grouping the compliance assessment does not remove individual-battery identification requirements.

How much does the EaseCert Digital Battery Passport Compliance Service cost?

The standard service fee is €500 per battery product group, plus a €50 Setup & Documentation Fee per order. Manufacturers with large portfolios, high production volumes or substantial individual-unit passport requirements receive a fixed quotation based on the implementation scope.

Is the EaseCert Digital Battery Passport Service a subscription?

No. EaseCert provides the service under a one-time fee model. There is no annual EaseCert subscription, recurring EaseCert membership or annual EaseCert compliance fee.

When should manufacturers start preparing?

Manufacturers of affected batteries should prepare well before 18 February 2027. Battery data, identification structures, QR code implementation and the underlying Digital Battery Passport architecture should be established before affected batteries are placed on the EU market.

Start Your EU Digital Battery Passport Assessment

If you manufacture or sell LMT batteries, industrial batteries above 2 kWh or electric vehicle batteries in the European Union, EaseCert can review your products and determine the appropriate Digital Battery Passport implementation before the 18 February 2027 deadline.

Send us your battery product list and available technical documentation. We will review the portfolio, determine the applicable product grouping and identify the information required to establish your Digital Battery Passports.

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