Digital Product Passports for Batteries: What Manufacturers Need to Know

The battery passport is the first mandatory Digital Product Passport in the EU. From 18 February 2027, every electric vehicle battery, industrial battery over 2 kWh, and light means of transport battery placed on the EU market must have a digital passport — accessible via a QR code on the battery itself, containing roughly 90 data attributes across seven categories.

If you manufacture, import, or distribute batteries in the EU, this isn't a distant regulation to monitor. It's an operational requirement with a hard deadline less than a year away. Most of the data the passport requires already exists somewhere in your technical documentation — spec sheets, test reports, material safety data, carbon footprint studies. The challenge is getting it out of those documents and into structured, machine-readable format.

This article covers the scope, the data requirements, the timelines, and the practical steps to prepare — including what you can start doing today with the documentation you already have.

Which Batteries Need a Passport

The battery passport requirement under Article 77 of the Battery Regulation (EU) 2023/1542 applies to three categories:

Not in scope for the full passport: portable batteries (phones, laptops, power tools), SLI batteries (starting, lighting, ignition — conventional vehicle batteries), and industrial batteries at or below 2 kWh. These are still subject to the broader Battery Regulation — labelling, QR codes, collection targets, hazardous substance restrictions — but not the full digital passport with its 90 data attributes.

What the Battery Passport Must Contain

The DIN DKE SPEC 99100 standard, published in February 2025, formalizes approximately 90 mandatory data attributes organized into seven clusters. This is expected to become the de facto standard for EU battery passport implementation. Here's what each cluster requires:

If you look at that table and think “we have most of this data already” — you're probably right. Battery spec sheets, test reports, Declarations of Conformity, and material safety data sheets collectively contain the majority of these data points. The gap isn't usually missing data — it's that the data lives in unstructured PDFs spread across different departments, in different formats, sometimes in different languages.

Carbon Footprint: From Declaration to Market Ban

The carbon footprint requirements are already partially in effect and escalate significantly over the next three years. The methodology uses the European Commission's Product Environmental Footprint (PEF) method, with footprint expressed as kg CO²-equivalent per kWh of total energy provided over the battery's expected service life.

Five lifecycle stages are covered: raw material acquisition, pre-processing, manufacturing, distribution, and end-of-life/recycling. The use phase is explicitly excluded. Primary data is mandatory for core components — no default values allowed for anode, cathode, electrolyte, and separator manufacturing data.

That last row is the one that changes the game. The “maximum CO² threshold” means that from 2028, batteries exceeding a yet-to-be-determined carbon ceiling cannot be placed on the EU market at all. This isn't a labelling requirement — it's a market access gate. The Commission will set the specific thresholds via delegated act, but the mechanism is already law.

Recycled Content and Material Recovery Targets

The regulation introduces mandatory minimum recycled content thresholds in two phases, targeting four critical materials:

Before the minimums kick in, there's a disclosure phase starting August 2028 where manufacturers must report recycled content percentages without meeting specific targets. On the recycling side, material recovery targets also ramp up: 90% recovery for cobalt, copper, lead, and nickel by December 2027, rising to 95% by 2031. Lithium recovery targets start at 50% (2027) and reach 80% (2031).

For the battery passport specifically, recycled content data per material must be included from day one (February 2027) — even though the mandatory minimums don't arrive until 2031. The passport acts as the transparency mechanism that makes the future thresholds enforceable.

State of Health: Dynamic Data From the BMS

Unlike most DPP data attributes, state of health parameters aren't static. The battery management system (BMS) must continuously track and report these values throughout the battery's operational life:

The BMS must provide a read-only interface so that anyone who legally purchases the battery can evaluate its residual value and suitability for reuse, repurposing, or remanufacturing. This is the circular economy mechanism in action — second-life operators and recyclers need this data to make informed decisions about batteries coming off their first application.

Who Sees What: Tiered Access Control

Not all 90 data attributes are public. The battery passport uses three access tiers defined in Annex XIII of the regulation:

This tiered model protects commercially sensitive data (detailed supply chain information, proprietary chemistry details) while ensuring the right stakeholders get the information they need. It's also the template other DPP product categories will follow.

Supply Chain Due Diligence (Postponed, Not Cancelled)

The due diligence requirements were originally set to apply from August 2025. In July 2025, the EU Council adopted a “stop-the-clock” regulation postponing them to 18 August 2027. The reasons: manufacturers needed more time to analyse supply chains, notified body designation was delayed, and due diligence schemes for battery raw materials were still being developed.

When the obligations do apply, they require: a formal due diligence policy aligned with OECD guidance, risk identification for cobalt, lithium, nickel, and natural graphite supply chains (covering human rights, environmental, and conflict risks), annual third-party audits, and public reporting. The current turnover threshold is €40 million, with a proposal under negotiation to raise it to €150 million.

Even though the due diligence data requirements are postponed, the battery passport structure includes the due diligence cluster from February 2027. Manufacturers would be wise to start populating this data early — the fields exist in the passport, and having the data ready when enforcement arrives is significantly easier than retrofitting it under deadline pressure.

What This Means for Your Existing Documentation

Map the seven data clusters against the documents you already produce:

The practical problem is format, not existence. A PDF spec sheet with capacity, voltage, energy density, and operating temperature range contains exactly the data the passport needs — but the passport needs it as structured, machine-readable fields, not as text on page 3 of a 12-page document. The gap is extraction and structuring — converting document-bound data into property/value/unit tuples that a passport system can ingest.

How to Start Preparing

Complete Battery Regulation Timeline

The battery passport is also the reference model for the broader EU Digital Product Passport framework under the ESPR. The access control model, QR code linkage, and data attribute structure being established for batteries will inform how passports work for construction products, textiles, iron and steel, and every other product category that follows. Companies investing in battery passport infrastructure now are building capabilities that transfer directly to future DPP requirements.

SpecMake extracts structured data from technical documentation and maps it to DPP-ready JSON-LD format. Upload a battery spec sheet and see how the extraction, audit, and structured export work with your own documentation.