Battery Delegated Act Tracker: EU Battery Regulation Status and Timeline

Q: Is the Battery Passport the same as the ESPR Digital Product Passport?

The Battery Passport is a Digital Product Passport for batteries, established by EU Regulation 2023/1542 (the Battery Regulation) rather than an ESPR delegated act. The data structure and technical requirements are aligned with ESPR, but the legal basis is the Battery Regulation. The Battery Passport is the first DPP to become mandatory.

Q: What batteries are exempt from the Battery Passport requirement?

Batteries used in military equipment, space equipment, and batteries for portable light sources are exempt. Batteries below the capacity thresholds specified in the Battery Regulation are also exempt from the Battery Passport requirement, although they remain subject to other Battery Regulation requirements.

Q: Can I self-host my Battery Passport data?

Yes, but the self-hosted system must meet the technical requirements of the EU Battery Passport Registry specification, including GS1 Digital Link URL structure, JSON-LD data format, and API requirements for data access by authorised parties. Using a compliant third-party registry is simpler and reduces compliance risk.

Q: What is the carbon footprint threshold for Battery Passport compliance?

The Battery Regulation sets carbon footprint performance class thresholds that will be published by the European Commission by 18 February 2025. Batteries that exceed the maximum carbon footprint threshold for their class cannot be placed on the EU market. The exact thresholds are not yet published.

Q: What happens to batteries already on the market when the Battery Passport becomes mandatory?

The Battery Passport requirement applies to batteries placed on the market from 18 February 2027. Batteries already on the market before that date are not required to have a Battery Passport retroactively, but batteries placed on the market after that date must comply regardless of when they were manufactured.

PUBLISHED — EU Regulation 2023/1542

The Battery Passport is the first Digital Product Passport to become mandatory under the ESPR framework. Unlike most ESPR product categories, the Battery Passport requirement is established not by an ESPR delegated act but by EU Regulation 2023/1542 (the Battery Regulation), which entered into force on 17 August 2023. The Battery Passport is mandatory from 18 February 2027 for industrial batteries above 2 kWh and EV batteries.

Truth Anchor: EU Regulation 2023/1542, Article 77(1): "From 18 February 2027, industrial batteries with a capacity above 2 kWh, light means of transport batteries, and electric vehicle batteries placed on the market or put into service shall have a battery passport." — EUR-Lex CELEX:32023R1542

Battery Passport: Current Status

Milestone	Date	Status
Battery Regulation published in EU Official Journal	28 July 2023	Complete
Battery Regulation entered into force	17 August 2023	Complete
EU Battery Passport Registry goes live	18 February 2026	Upcoming
Battery Passport mandatory — EV batteries & industrial batteries >2 kWh	18 February 2027	Hard Deadline
Battery Passport mandatory — light means of transport batteries	18 August 2027	Upcoming
Battery Passport mandatory — portable batteries in general appliances	18 February 2027	Hard Deadline

What the Battery Passport Must Contain

EU Regulation 2023/1542 Annex XIII specifies the mandatory data fields for the Battery Passport. The data fields are divided into information accessible to all users (public data) and information accessible only to authorised parties such as recyclers and market surveillance authorities (restricted data). The public data includes the battery model identifier, battery category, battery chemistry, rated capacity, nominal voltage, carbon footprint per kWh, recycled content of cobalt, lithium, nickel, and lead, and a link to the EU Declaration of Conformity.

Data Category	Specific Fields	Access Level
Battery identification	Unique battery identifier, model identifier, battery category	Public
Battery chemistry	Cathode, anode, and electrolyte materials	Public
Carbon footprint	Carbon footprint per kWh (lifecycle), carbon footprint performance class	Public
Recycled content	Percentage recycled cobalt, lithium, nickel, lead	Public
State of health	State of Health (SoH), State of Charge (SoC), remaining capacity	Restricted (authorised parties)
Supply chain due diligence	Responsible sourcing policy, supply chain audit reports	Restricted
End-of-life data	Dismantling instructions, hazardous substance locations	Restricted (recyclers)

Who Must Comply with the Battery Passport Requirement?

The Battery Passport requirement applies to any manufacturer, importer, or distributor who places batteries in scope of EU Regulation 2023/1542 on the EU market. This includes non-EU manufacturers who export batteries to the EU — they must appoint an EU Authorised Representative and register their Battery Passport with the EU Battery Passport Registry before their batteries can be placed on the EU market from 18 February 2027.

South African manufacturers of lithium-ion batteries for export to the EU are directly affected. The Battery Regulation applies to batteries used in electric vehicles, industrial energy storage, and consumer electronics. South Africa's growing battery manufacturing sector — driven by the Minerals Council's battery value chain initiative — must comply with the Battery Passport requirement for all EU-destined products.

Battery Passport QR Code Requirements

EU Regulation 2023/1542 Article 77(3) requires the Battery Passport to be accessible via a QR code that is "permanently attached" to the battery. The QR code must encode a GS1 Digital Link URL that resolves to the Battery Passport data record. The QR code must be scannable throughout the battery's lifetime — which for industrial batteries and EV batteries can be 10–20 years. This means the QR code must be engraved, laser-etched, or applied using a durable label that will not degrade over the battery's expected lifetime.

EU Battery Regulation DPP Timeline: Key Milestones

The EU Battery Regulation (EU 2023/1542) is the most advanced ESPR-adjacent DPP framework in the EU. The regulation entered into force on 17 August 2023. The key DPP milestones are: from 18 February 2027, industrial batteries with a capacity above 2 kWh, EV batteries, and LMT (light means of transport) batteries must have a Digital Battery Passport. From 18 August 2028, portable batteries of general use must have a DPP. The EU Commission's implementing acts specifying the technical requirements for the Digital Battery Passport are currently under development, with the first implementing act expected in 2025. Manufacturers of batteries subject to the regulation should begin their DPP implementation now — the 2027 deadline does not allow time for a last-minute implementation.

Digital Battery Passport: Current Implementation Status

The EU Commission has published a series of preparatory documents for the Digital Battery Passport, including the Battery Pass Consortium's technical specifications (published in 2023) and the EU Commission's own technical study on DPP implementation (published in 2024). The Battery Pass Consortium — a consortium of battery manufacturers, automotive OEMs, and technology providers — has developed an open-source reference implementation of the Digital Battery Passport based on the W3C Verifiable Credentials Data Model and the GS1 Digital Link standard. This reference implementation is available at batterypass.eu and provides a practical starting point for manufacturers implementing their own DPP systems. The EU Commission has indicated that the implementing acts for the Digital Battery Passport will be based on the Battery Pass Consortium's technical specifications.

Battery DPP Data Requirements: What Must Be Disclosed

The EU Battery Regulation Annex XIII specifies the data that must be included in the Digital Battery Passport. The mandatory data fields include: battery model identifier, battery manufacturer and manufacturing location, battery chemistry (cathode active material, anode active material, electrolyte type), capacity in Ah, energy in Wh, rated voltage, temperature range, expected battery lifetime in cycles and calendar years, carbon footprint per kWh of battery capacity (with lifecycle stage breakdown), recycled content percentage for cobalt, lithium, nickel, and lead, State of Health (SoH) methodology, and end-of-life collection and recycling instructions. The carbon footprint declaration must be verified by a third-party auditor and must reference the EU Battery Regulation's carbon footprint calculation methodology (based on EN ISO 14067).

Frequently Asked Questions: Battery Passport and EU Regulation 2023/1542

Is the Battery Passport the same as the ESPR Digital Product Passport?

What batteries are exempt from the Battery Passport requirement?

Can I self-host my Battery Passport data?

What is the carbon footprint threshold for Battery Passport compliance?

What happens to batteries already on the market when the Battery Passport becomes mandatory?

Register Your Battery Passport

The Battery Passport deadline is 18 February 2027. Africa's first ESPR-compliant DPP registry supports Battery Passport registration. Register now.

Battery Passport Implementation Timeline

The EU Battery Regulation (EU 2023/1542) is the most advanced ESPR-adjacent regulation and serves as the template for all other ESPR delegated acts. The Battery Passport requirements are being implemented in phases. Phase 1 (from February 2027): EV batteries and rechargeable industrial batteries above 2 kWh must have a Battery Passport with a QR code data carrier. Phase 2 (from August 2028): the Battery Passport must include state of health data and carbon footprint data. Phase 3 (from August 2030): the Battery Passport must include recycled content data and supply chain due diligence information.

The technical specifications for the Battery Passport are being developed by the European Commission in collaboration with the Battery 2030+ research initiative and the Global Battery Alliance. The specifications are based on the W3C Verifiable Credentials Data Model and the GS1 Digital Link standard. Draft specifications were published for public consultation in 2023 and are expected to be finalised in 2024–2025. Manufacturers of EV batteries and industrial batteries should monitor the Commission's battery passport webpage for updates on the technical specifications.

Key Compliance Milestones for Battery Manufacturers

Date	Requirement	Applies to
February 2025	Supply chain due diligence policy required	Industrial batteries >2kWh, EV batteries
August 2025	Carbon footprint declaration required	EV batteries, industrial batteries >2kWh
February 2027	Battery Passport required (QR code)	EV batteries, industrial batteries >2kWh
August 2028	State of health reporting required	EV batteries, industrial batteries >2kWh
August 2030	Recycled content requirements take effect	EV batteries, industrial batteries >2kWh

Frequently Asked Questions

The Battery Passport is a specific implementation of the DPP concept for batteries, established under the EU Battery Regulation rather than ESPR. The technical architecture is similar to the ESPR DPP, but the Battery Passport has its own specific data requirements and timeline. Products containing batteries will need both an ESPR DPP (for the product) and a Battery Passport (for the battery).

EV battery manufacturers must comply with the Battery Passport requirement from February 2027. This means that EV batteries placed on the EU market from February 2027 must have a Battery Passport with a QR code data carrier. Manufacturers should begin implementing the Battery Passport system well before this date to allow time for testing and validation.

The Battery Regulation applies to all batteries placed on the EU market. However, the Battery Passport requirement applies specifically to industrial batteries above 2 kWh and EV batteries. Batteries in smartphones and laptops (which are typically below 2 kWh) are subject to other Battery Regulation requirements (such as removability requirements) but not the Battery Passport requirement.

From August 2030, EV batteries must contain minimum percentages of recycled cobalt (12%), recycled lithium (4%), recycled nickel (4%), and recycled lead (85%). These percentages increase in subsequent phases. Manufacturers must verify and disclose the recycled content in the Battery Passport.

The EU Critical Raw Materials Act (CRMA) aims to reduce EU dependence on imported critical raw materials, including lithium, cobalt, and nickel used in batteries. The Battery Regulation's supply chain due diligence and recycled content requirements support the CRMA's objectives by promoting responsible sourcing and increasing the recovery of critical materials from end-of-life batteries.