The Battery Passport: Your Guide to the First Digital Product Passport

 If you've been keeping up with the DPP (Digital Product Passport) news, you've probably heard that batteries are going to be the first products to need these digital IDs. We now have lots of concrete information about what will go into the EU's Battery Passport and how it will actually work in practice. 

Let’s break down what the EU Commission and the Battery Pass Consortium have shared so far so you know what’s coming and how to prepare. These two are your go-to sources: the EU is the one setting the rules, and the Battery Pass Consortium (backed by the German Federal Ministry for Economic Affairs and Climate Action and the EU)  is helping bring the digital battery passport to life. And just so you know—the digital product passport (DPP) for batteries is officially called the Battery Passport.

Even if batteries aren't your thing, stick around! There's a lot of information that might be relevant to you as well. Batteries are essentially the guinea pigs of the DPP world. While the specific requirements will vary between industries (each getting their own Delegated Acts), there's going to be a lot of overlap in the fundamentals.

So, instead of twiddling our thumbs while we wait for the delegate acts for specific product categories, let's look at what we already know about the battery passport.

Why the Battery Passport matters

Let's start by talking about why the EU chose batteries as the first product group to need digital product passports. 

Turns out it’s not random. The European Commission prioritized industries based on two things:

• Their environmental impact
• Their potential for improving sustainability

And batteries are crucial for Europe to achieve its sustainability goals—to be carbon neutral by 2050 and shift to renewable energy! 

Batteries are essential to Europe’s climate goals

The EU has set some pretty ambitious targets here. They want at least 42.5% of energy to come from renewable sources by 2030 (with hopes to push that up to 45%) and want to be carbon neutral by 2050.

Back in 2019, transport alone was responsible for about a quarter of the EU's total CO2 emissions. That's why they're aiming to slash greenhouse gas emissions from transport by 90% by 2050. 

The only way to achieve this level of decarbonization is through electric vehicles, and for that, we need batteries.  

And guess what? Batteries are not only the technology behind electric vehicles. But they’re also essential for storing energy from renewable sources. 

So, to put it bluntly—the EU simply can’t achieve its sustainability goals without batteries. 

But there’s a catch: batteries come with big sustainability challenges

While electric vehicle batteries and batteries, in general, are key to solving the climate crisis, they also bring their own issues. 

The battery industry relies on critical raw materials like lithium, cobalt, and graphite, which are not only difficult to source but can cause serious damage to the environment. Mining these materials can lead to deforestation, water pollution, and soil degradation. On top of that, much of this mining takes place in regions with poor labor conditions and human rights concerns. 

With demand for these critical raw materials expected to soar, the EU alone will need 18 times more lithium by 2030, and there’s also a growing risk of supply chain disruptions. These critical raw materials can only be found in a few countries around the world, so getting hold of them is not easy. The Russia-Ukraine war has shown just how crucial these materials are and how desperate countries are to make sure they have them.

The map below shows where Europe gets its most critical raw materials from.

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Throughout history, people have developed new technologies to solve specific problems, but they often end up bringing unexpected consequences. 

Take the pioneers of cars, Karl Benz and Henry Ford, who invented the car to solve transportation challenges. They didn’t foresee that cars would one day be a major contributor to the climate crisis. 

Funny enough, early gas-powered cars were actually seen as a cleaner alternative to horses (city streets were a mess).

Now, we’re seeing something similar with electric vehicles.

They were invented to reduce carbon emissions—but the materials inside their batteries are raising new sustainability concerns.

What's the difference this time?

Europe has learned from its past, and instead of waiting to see the negative fallout from the boom in the battery industry. They're looking for ways to take full advantage of this amazing technology while mitigating the social and environmental risks—and one of the ways it’s doing that is with the Battery Passport.

So, how can the Battery Passport help? 

These digital Battery Passports will track key data throughout a battery’s entire life—from production all the way to disposal. The goal is to extend the life of batteries as much as possible and promote recycling once they reach the end of their lifespan.

This kind of visibility will help manufacturers design batteries with sustainability and circularity in mind, making recycling a whole lot easier. This means we can recover and reuse valuable materials like cobalt, lithium, and graphite instead of letting them go to waste—so less mining, which is bad for the environment. 

And by improving how we recycle, we’ll also rely less on imported materials. That means less dependency on global supply chains.

Now, enough about history and theories—let's dive into the practicalities of the Battery Passport!

The regulatory framework for the Battery Passport

You've probably heard of the Ecodesign for Sustainable Products Regulation (ESPR), which lays the groundwork for digital product passports across different product categories and was introduced in March 2022.

Well, when it comes to the battery industry, there's a separate regulation—the EU Battery Regulation (Regulation 2023/1542). This one kicked in on August 18, 2023, replacing the older Battery Directive (2006/66/EC). The goal? To make sure all batteries placed on the European market are sustainable and safe throughout their entire lifecycle.

However, even though the Battery Passport has its own regulations, it's been designed to work hand-in-hand with the ESPR. Both are key pieces in the EU's broader push for more sustainable product design and circular economy principles. 

Who needs a Battery Passport? 

From February 18, 2027, the Battery Passport will be mandatory for:

• Light means of transport (LMT) batteries (like those in e-bikes and e-scooters)
• Industrial batteries with a capacity greater than 2 kWh
• Electric vehicle (EV) batteries

The table below shows more details about which types of batteries will have to have a Battery Passport.

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3 key components of the Battery Passport

1. Unique identifier: your battery’s digital fingerprint

Every battery must have a unique identifier, which you can think of as a battery’s social security number or fingerprint. It’s a one-of-a-kind code that links a product to its digital passport.

This identifier must be serialized and follow strict standards (like ISO/IEC 15459). The goal here is to make sure each battery (and, therefore, each Battery Passport) has its own serial number so it can be identified without any confusion or overlap.

2. Data carrier 

So, how will people access Battery Passport info? Through a QR code!

By February 18, 2027, all batteries covered by the EU Battery Regulation must have a QR code that's engraved or printed directly on the battery. It needs to be easy to spot and read and impossible to rub off. If that's not practical (like with tiny batteries), the QR code can go on the packaging or in the accompanying documents.

Each QR code must be connected to the product's unique identifier and give you access to the Battery Passport. Think of these QR codes as little windows into the life story of each battery—just scan and instantly access everything from its manufacturing details to its projected end-of-life information. 

3. Data storage 

The Battery Passport system will rely on a decentralized data setup, meaning companies are responsible for storing and managing their own data.

If you're a smaller business without the tech resources to handle this, you can authorize a service provider to manage the data for you—just make sure they don't sell, reuse, or process it beyond what's needed.

The European Commission will also keep some data in a central registry to verify passport authenticity, check compliance with eco-design rules, and help customs officials when batteries cross borders.

At a minimum, this registry will store those unique battery identifiers we mentioned earlier. While the Commission handles security, it’s up to companies selling batteries to ensure their data is uploaded correctly.

What data goes into the Battery Passport?

Battery Pass Consortium has identified 90 mandatory data attributes that need to be included (based on Article 77 and Annex XIII of the regulation). On top of that, companies can also include voluntary data to provide even more transparency.

These data points fall into two main categories:

• Static data: This is set when the battery first enters the market and rarely changes—unless parts are replaced or key specs are updated. It covers details like the battery’s carbon footprint, sourcing information, and initial performance data.
• Dynamic data: This info evolves throughout the battery’s life and must be updated regularly to reflect how the battery is performing based on its actual use. The Battery Regulation doesn’t specify exactly when or how often updates should happen—that’s up to each economic operator.

Data attributes 

To make things easier, the Battery Pass Consortium grouped these data points into seven content batches. Each cluster covers a specific aspect of the battery's lifecycle and characteristics. 

The graphic below shows the seven content batches and provides an overview of what type of information goes into each group.

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Who gets to see what? 

Let's talk about who gets access to all this Battery Passport information. 

Everyone will be able to access the Battery Passport for free, but different groups of people will have different levels of access based on their role in the battery lifecycle.

While the European Commission is still working on who gets to see what for DPPs, the Battery Regulation has already outlined some access groups in Article 77 and Annex XIII:

• General public: Consumers will be able to see basic battery details, like sustainability requirements and key data about batteries placed on the market. This will help consumers make informed decisions when choosing electric vehicle batteries, industrial batteries, or other battery types.
• Authorities and regulators: Notified bodies, market surveillance authorities, and the European Commission will have deeper access. They will be able to see detailed test results, battery model information, safety measures, and details on parts, composition, and dismantling. This will help them make sure batteries meet sustainability requirements and comply with EU Battery Regulation standards.
• “Persons with a legitimate interest”: This group (to be defined by the European Commission by August 18, 2026) will have access to more specific details like battery performance, durability, and usage data. They may include those assessing a battery's condition for second-life use, recycling, or the battery value chain.

To protect sensitive business information, access to this data will be limited to only what's necessary and will follow EU rules. Think of it as a "need to know" basis—you only get to see what's relevant to your role in the battery's lifecycle.

Your data cheat sheet

In the table below, you'll find a complete list of data attributes that the Battery Pass Consortium has identified for the Battery Passport. They've organized everything by battery categories and access groups, so you can easily see who gets to access what information for different types of batteries. It's basically your cheat sheet for all the data that needs to be included. It's pretty handy, right?

Table 1: Battery Passport data by category and access group

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Who’s responsible for the Battery Passport?

Just like with the DPP, the responsibility for meeting Battery Passport requirements falls on the shoulders of the "economic operator"—basically whoever places the battery on the EU market. They are responsible for creating the Battery Passport, keeping it updated, and making sure all that information is properly stored.

Who can be an economic operator?

The economic operator can be either a manufacturer or an importer. Here’s what that means:

Manufacturer: This is any company or person that produces batteries or has them designed or manufactured by another company but sells them under its name or trademark.

For example, General Motors (GM) (the parent company of Chevrolet) does not manufacture its batteries. It sources batteries for its Chevrolet Bolt from LG Chem. Even though LG Chem actually produces the batteries, GM is considered the manufacturer—and therefore the economic operator—because they market these batteries as part of their own branded vehicles. That means GM is responsible for the Battery Passport.

Importers: An importer is any person or company based in the EU that places batteries from non-EU countries onto the EU market.

For example, Balustrade, a battery distributor in Poland, imports batteries from Panasonic Eneloop (Japan) and Rayovac (United States). Even though these batteries are manufactured abroad, Baltrade is a company based in the EU that is bringing them into the EU market. This makes them the economic operator responsible for the Battery Passport.

What about online sales? 

When an EU-based company sells batteries online, it's pretty straightforward. Only the selling method is different—the batteries are still considered "placed on the market" by either the manufacturer or importer. Same rules, different storefront.

For sellers based outside the EU, things get a bit more interesting. The key question becomes: is this online seller actually targeting EU customers?

You're likely targeting the EU market if you:

• Ship to EU addresses
• Accept euros (or other EU currencies)
• Offer your website in EU languages

In these cases, EU battery regulations apply, and the online seller is considered to be "placing the product on the market" therefore, the economic operator. 

These decisions are usually made case-by-case, but the bottom line is this: if you're deliberately selling to EU customers (even from outside the EU), you've got to play by EU rules.

Look at the table below to see who's responsible for the battery passport. 

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When does the economic operator's responsibility end?  

There are basically two main scenarios where this happens:

When the battery becomes "waste": Once a battery is discarded (or about to be), it’s considered waste. At this point, responsibility shifts to the waste management operator. The good news? A new Battery Passport isn’t needed in this case.

When the battery gets a second life: If a battery is prepared for re-use, repurposing, or remanufacturing, it’s considered a brand-new product. That means a new digital Battery Passport is required, and the responsibility moves to the new economic operator placing it back on the market.

Some interesting points:

• Once a battery has been fully recycled, its passport ceases to exist. (Though the exact moment in the recycling process when this happens isn't super clear-cut.)
• If a battery gets exported outside the EU, the exporting operator should decommission the Battery Passport. And if that same battery somehow finds its way back into the EU later? The importer becomes the new responsible economic operator.

One important thing to remember: Even if an economic operator delegates Battery Passport tasks to someone else, they’re still responsible for complying with the EU Battery Regulation. You can outsource the work, but not the accountability.

The graphic below shows the lifecycle of a battery passport.

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How can businesses benefit from the Battery Passport?

Let’s talk about the benefits of the Battery Pass! Sure, some upfront investment will be needed to comply with the Battery Passport regulation—but it’s also an opportunity for businesses to boost revenue, build customer trust, and stand out in the growing sustainable battery industry. 

Show off green credentials 

If your business is serious about sustainability, the digital Battery Passport is your chance to prove it. With clear data on your battery’s carbon footprint, sourcing, and life cycle, you can backup your eco-friendly claims—reducing the risk of being seen as just another greenwashing brand.

This transparency doesn’t just improve your reputation—it can attract eco-conscious buyers, secure green investments, and give you a competitive edge in the battery industry.

Help customers make the right choices (by choosing you!) 

The Battery Passport gives consumers clear, comparable data on things like capacity, expected lifetime, certifications, and battery chemistry. Armed with this info, they can confidently choose the best product for their needs—ideally, yours!

For businesses, this is a chance to build trust by offering transparent information, which can lead to happier customers, better reviews, and fewer returns or complaints.

New revenue streams 

The Battery Passport makes servicing and repairing batteries easier. With key data like battery model details, technicians can quickly diagnose problems and carry out repairs efficiently. This opens doors for businesses to offer new services like repair packages, maintenance plans, or guidance on battery use—all potential revenue streams.

Recycle more efficiently (and profitably)

At the moment, recycling batteries is an expensive and complex process. However, data from the Battery Passport—such as detailed information on the composition and dismantling procedures—will make recycling much more efficient. 

It cuts down on costly sampling and testing, helps recyclers recover more materials, and makes sure the valuable materials get reused instead of tossed. What does this mean for companies? That there will be more recycled materials available in the market, which usually come at a lower cost. 

What should your business be doing right now?

The Battery Passport becomes mandatory on February 18, 2027. That may sound like it’s far off, but it’s really not.

Just ask BMW—they’ve been working on this since 2017. That’s a solid reminder of how long it can take to get everything in place.

So, here’s what you can do now to stay ahead of the game:

1. Start early—like, now

Don’t treat 2027 like a future-you problem. You’ll need time to build the right processes and get your team on board.

• Establish a project pipeline specifically for the battery passport implementation, identifying the necessary steps and timelines.
• Set up your Battery Passport team and get the right people involved early. This isn’t a one-team job—it’ll take collaboration across IT, marketing, engineering, compliance, and supply chain teams.

And don't forget that batteries are but one of the products that DPPs will apply to, so you might want to start getting ready for DPP as a whole.

2. Check what data you already have

Good news: you don’t have to start from scratch. The Battery Passport (like all DPPs) is about managing existing data—not creating new data. 

The Battery Pass Consortium has published a helpful data overview in Table 1 that outlines most data attributes you’ll need for the Battery Passport.  

Here’s what to do:

• Review the table
• Identify which data points you already have
• Make a plan to track down the rest

Even if you’re not in the battery industry, it’s worth a look. The Battery Passport is basically the 

3. Talk to your supply chain

Once you know what data you’re missing, loop in your supply chain partners. They probably have a lot of the data you’re looking for.

Also, start conversations on how you will share and update data moving forward. 

4. Get serious about data management

You’ll need a place to store and manage all this data—and no, spreadsheets won’t cut it.

A Product Information Management (PIM) system can help you:

• Store product data and digital assets (like certificates, images, videos)
• Map out required attributes based on Table 1
• Track completeness so you can see what’s missing
• Keep everything up-to-date, accurate, and audit-ready

Remember: 80–85% of the battery passport effort is just data handling. The cleaner your system, the easier your life.

5. Standardize your data

This isn’t just about collecting data—it’s about making it usable.

• Use the Battery Pass Consortium Technical Standard Stack to see how to standardize your data.
• Come up with a process to collect data from your value chain in a set format.

• Prioritize automation and integration for data collection processes to reduce workload, costs, and errors—a good PIM can help with that, too.
  
  

6. Prepare for data accuracy

As the economic operator, it will be your responsibility to make sure all data is accurate and up to date. Therefore, create a clear process to check and validate all the data you get from suppliers. 

Look into automated systems that can flag missing data, spot inconsistencies, and document your verification steps to keep track of what data has been checked.

6. Budget for it

Yes, this will cost something—both upfront and ongoing. Factor in things like software, data systems, team time, and product development. 

7. Choose your implementation strategy

You’ve got options:

• Build an in-house solution
• Use a third-party provider
• Or go hybrid

Each has pros and cons—think about data ownership, costs, long-term maintenance, and internal resources. Regardless of the route you pick, the prep steps are the same.

8. Go beyond compliance

Sure, the Battery Passport is a regulation—but it’s also an opportunity.

You can use this data to:

• Improve quality control
• Increase supply chain visibility
• Support circular economy goals
• Open new revenue streams (like repair programs or recycling partnerships)
• Build consumer trust through transparency

💡 Idea: Create a return-and-recycle program where customers get points or perks for sending batteries back. You win, they win, the planet wins.

9. Know the rules (they’re still changing)

Stay up to date on legal requirements and evolving definitions. Things are still in flux, so this is one area where you’ll want someone keeping an eye on updates.

The takeaway

Implementing the Battery Passport will take time and effort and will probably come with some upfront costs, but it’s a real opportunity for businesses to grow, stand out, and meet the rising demand for sustainable products.

The Battery Passport isn’t optional—it’s happening. That’s why now is the time for businesses to focus on how to make the most of it. You’ve probably heard the saying that data is the oil of the 21st century—well, the Battery Passport will give us access to valuable data that wasn't available before. Companies should explore how to leverage this data to enhance battery design, improve manufacturing processes, streamline operations, and refine their marketing strategies.

More importantly,  we're starting to see a real societal shift where customers are actively seeking more sustainable products. The Battery Passport helps build trust with eco-conscious consumers actively looking for products that align with their values. By embracing this shift now, companies can position themselves as leaders in the move toward a circular economy.

So, instead of seeing the Battery Passport as just another rule to follow, think of it as your chance to innovate, connect with your audience, and drive long-term success. Sustainability and profitability can go hand in hand—and the Battery Passport can help get you there.