EU Digital Battery Passport 2027: What Battery Manufacturers Need to Know

The European Union is introducing a major new traceability requirement for batteries. From 18 February 2027, certain batteries placed on the EU market or put into service must have their own Digital Battery Passport (DBP).

The requirement comes from Regulation (EU) 2023/1542 on batteries and waste batteries and affects manufacturers, importers and other economic operators placing covered batteries on the European market.

For companies preparing for the new rules, the important point is that a Digital Battery Passport is much more than a QR code or a PDF. It is a structured electronic record that connects an individual physical battery with regulatory, technical and lifecycle information.

EaseCert's EU Digital Battery Passport (DBP) Compliance Service helps companies assess the requirements, structure their Annex XIII data, create the required passport and QR code, and prepare for registration within the EU Digital Product Passport infrastructure.

What Is an EU Digital Battery Passport?

A Digital Battery Passport is an electronic record associated with an individual battery.

The basic structure can be understood as:

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

Each part performs a different function.

1. The Physical Battery

The physical battery is connected to its digital record through a QR code. Depending on the applicable requirements and physical characteristics of the battery, the QR code is marked on the battery or provided through permitted packaging or accompanying documentation.

2. The QR Code

The QR code acts as the access point to the Digital Battery Passport. It does not contain the complete passport itself.

Instead, it connects the user to the unique identifier and the electronic passport associated with that battery.

3. The Unique Identifier

Each covered battery must be assigned a unique identifier by the economic operator placing it on the market.

The QR code and unique identifier must comply with the applicable ISO/IEC 15459 standards or equivalent requirements.

4. The Digital Battery Passport

The passport is the structured electronic record behind the identifier. It contains information about the battery model as well as information relating specifically to the individual battery.

Some information is publicly available. Other information is restricted to parties with appropriate access rights, such as competent authorities, notified bodies, repairers, remanufacturers, second-life operators or recyclers.

Which Batteries Need a Digital Battery Passport?

Article 77 of Regulation (EU) 2023/1542 establishes the Digital Battery Passport requirement from 18 February 2027 for:

• Light Means of Transport (LMT) batteries, including batteries used in products such as e-bikes and e-scooters
• Industrial batteries with a capacity greater than 2 kWh
• Electric vehicle (EV) batteries

Businesses manufacturing or importing these batteries should therefore begin preparing their data and identification structures before the February 2027 application date.

Does Every Battery Need Its Own Passport?

One of the most important aspects of the new system is its individual-battery approach.

The Battery Regulation requires passport information relating both to the battery model and to the individual battery.

That means batteries belonging to the same model can share substantial technical information while still having individual identifiers and passport records.

Example

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

This distinction becomes particularly important when lifecycle information begins to differ between individual batteries.

What Information Goes Into a Digital Battery Passport?

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

Depending on the battery category and applicable implementation dates, the passport can contain information including:

• Battery and model identification
• Manufacturer information
• Manufacturing location
• Battery category
• 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

Not every requirement necessarily becomes applicable on the same date. Battery manufacturers should therefore assess both the passport requirement itself and the implementation dates applying to individual categories of information.

Who Can See the Information in a Battery Passport?

A Digital Battery Passport is not simply a public webpage containing every piece of technical information about a battery.

The Battery Regulation establishes different access levels.

Public Information

Certain battery information must be accessible to the general public. This can include applicable model-level information about the battery and its characteristics.

Restricted Technical Information

Other information can be made available only to parties with a legitimate interest. Depending on the applicable rules, this can include information needed for repair, remanufacturing, second-life applications, dismantling and recycling.

Authority and Compliance Information

Certain information is reserved for notified bodies, market surveillance authorities and the European Commission.

Individual Battery Data

The passport can also contain information relating specifically to the individual battery, including applicable information resulting from its use.

Why Isn't a QR Code Linking to a PDF Enough?

This is one of the most common misunderstandings surrounding the Digital Battery Passport.

A company might reasonably ask why it cannot simply generate a QR code and link it to a PDF containing its battery specifications.

The answer is that the QR code is only the data carrier. The underlying passport has additional regulatory and technical requirements.

Article 77 requires the information to be based on open standards and provided in an interoperable format. The information must be transferable without vendor lock-in, machine-readable, structured and searchable.

The passport architecture must also address requirements including:

• Different access rights
• Data authentication
• Reliability and integrity
• Security and privacy
• Data portability
• Interoperability
• Lifecycle updates
• Long-term availability

A conventional PDF can be useful as supporting documentation, but it is not equivalent to the structured Digital Battery Passport architecture required by the Regulation.

What Is the EU Digital Product Passport Registry?

Another important distinction is the difference between the Digital Battery Passport and the EU Digital Product Passport Registry.

The EU registry should be understood primarily as an index rather than as the location where the complete battery passport is stored.

The underlying passport remains a separate electronic record maintained by the responsible economic operator or an authorised operator acting on its behalf.

The EU Registry and the Passport Have Different Functions

In simplified terms:

The EU registry records that the passport exists and associates it with the relevant identifier. The Digital Battery Passport contains the underlying battery information.

This is why the existence of an EU registry does not eliminate the need for dedicated Digital Battery Passport infrastructure.

Who Is Responsible for the Digital Battery Passport?

The economic operator placing the battery on the EU market remains responsible for the passport obligations established by the Battery Regulation.

In particular, the responsible economic operator must ensure that the passport information is accurate, complete and up to date.

Another operator can be authorised in writing to perform certain work on its behalf, but this does not remove the underlying responsibility of the economic operator.

What Happens When Battery Information Changes?

A Digital Battery Passport is designed to accompany the battery through its lifecycle. It should therefore not be treated as a document that is created once and never changed.

Where applicable information changes, the electronic record behind the identifier can be updated while the identifier and QR code continue to point to the same battery passport.

This allows information to evolve without requiring manufacturers to replace an existing QR code every time an applicable passport data point changes.

What Happens When a Battery Is Repaired, Repurposed or Remanufactured?

The Battery Regulation also addresses what happens later in the battery's lifecycle.

Repair

A repair does not necessarily mean that the battery needs an entirely new passport. Relevant information can continue to be associated with the existing battery record where appropriate.

Repurposing and Remanufacturing

A battery that has been repurposed or remanufactured receives a new battery passport linked to the passport of the original battery.

The economic operator placing the repurposed or remanufactured battery on the market then assumes the applicable passport responsibilities.

Recycling

When the battery becomes waste, responsibility can transfer according to the Battery Regulation's applicable waste and producer responsibility provisions.

The battery passport ceases to exist once the battery has been recycled.

Why Long-Term Passport Availability Matters

The passport must remain available even if the responsible economic operator ceases to exist or ceases its activity in the European Union.

This makes long-term availability an important part of Digital Battery Passport planning.

A battery manufacturer should therefore consider more than simply how to generate the initial QR code. The implementation needs to address how passport data remain accessible, transferable and associated with batteries already in circulation.

How Should Battery Manufacturers Prepare for 2027?

Companies should not wait until February 2027 to start collecting the required information.

A practical preparation process should include:

• Identifying which battery models fall within the Digital Battery Passport requirement
• Determining the responsible economic operator for the EU market
• Reviewing existing battery technical documentation
• Mapping available information against Annex XIII
• Identifying missing data
• Reviewing existing GTIN, GS1 and serial-number structures
• Establishing the individual battery identification method
• Preparing the QR code and physical labelling concept
• Creating the structured passport data
• Preparing for EU Digital Product Passport Registry registration
• Establishing a process for future passport updates

How EaseCert Supports Digital Battery Passport Compliance

EaseCert provides an EU Digital Battery Passport (DBP) Compliance Service for companies preparing batteries for the European market.

The service can include:

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

One-Time EaseCert Fee, No Subscription

EaseCert follows a straightforward one-time fee model.

The standard Digital Battery Passport Compliance Service is available from:

€500 per battery product group

A €50 Setup & Documentation Fee applies per order.

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

For manufacturers with large battery portfolios, high production volumes or substantial individual-unit passport requirements, the implementation scope can be assessed separately and a fixed project quotation provided before work begins.

What Documentation Should Manufacturers Prepare?

Companies preparing for a Digital Battery Passport assessment should collect as much existing battery and compliance documentation as possible.

This can include:

• Battery product list and SKUs
• Technical datasheets
• Battery specifications
• Product photographs
• Manufacturer information
• Manufacturing location
• Battery chemistry
• Capacity and voltage information
• BOM and material information
• Test reports
• EU Declaration of Conformity where applicable
• Safety documentation
• 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

It is not necessary to have every passport data point available before beginning the process. A data-gap assessment can first establish what is available and what still needs to be obtained.

The 18 February 2027 Deadline Is Approaching

For manufacturers of LMT batteries, industrial batteries above 2 kWh and electric vehicle batteries, the Digital Battery Passport represents a significant change in how battery information is identified, structured, maintained and made available throughout the product lifecycle.

The important point is to look beyond the QR code.

A compliant implementation requires the physical battery, unique identifier, structured passport data, access rights, lifecycle information and EU registry requirements to work together as one system.

Companies that begin preparing their battery data and identification structures early will be in a much better position to implement the required passports before the 18 February 2027 application date.

Prepare Your Digital Battery Passport with EaseCert

If your company manufactures, imports or sells 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 compliance approach.

Our team can assess your existing documentation, identify missing Annex XIII information, prepare the passport structure and support implementation of the unique identifier, QR code and EU registry requirements.

View the EaseCert EU Digital Battery Passport (DBP) Compliance Service