The digital battery passport
The date is already set: 18 February 2027.
For anyone placing batteries on the EU market — sold on their own or built into products — the digital battery passport is no longer optional. It is a legal requirement that is already in force. Regulation (EU) 2023/1542 is the EU’s first product-specific digital passport, with a hard date and a precisely defined data scope. Below: the facts, the dates and links to the official acts.
18 February 2027 — from this date every LMT (light means of transport) battery, every industrial battery above 2 kWh and every EV battery placed on the EU market must carry a digital battery passport accessible via QR code. The same regulation brings supply-chain due-diligence duties (from 18 August 2027) and a carbon-footprint declaration.
Straight answer
A short answer to “why do I need this meeting”
No fluff. Three reasons to talk about the battery passport now — even if your team already has its hands full.
01
Because it’s required by law
Regulation (EU) 2023/1542 applies directly in every EU country — no national transposition needed. The battery passport has a hard date, 18 February 2027, not a vague “someday”.
02
Because it’s a real advantage, not just compliance
Full traceability of critical raw materials, a carbon footprint calculated per plant, market and OEM access, and a second life for cells — all from a single source of data.
03
Because the groundwork takes time
Collecting data on the origin of cobalt, lithium, nickel and graphite, on the carbon footprint and on cell state-of-health means months of work deep into the supply chain. Start now and you do it calmly and more cheaply.
Legal basis
It’s already law, not a trend
One regulation, five streams of obligations that together make the battery passport mandatory. Each links to an official source — you can verify it in a minute.
Regulation (EU) 2023/1542
Regulation on batteries and waste batteries
The EU framework law that establishes the digital battery passport as a mandatory traceability tool. In force since 17 August 2023, applicable (mostly) from 18 February 2024, replacing the Batteries Directive 2006/66/EC. As a Regulation it applies directly in every EU country.
Battery passport · Art. 77
Battery passport mandatory from 18 February 2027
Every LMT battery, industrial battery above 2 kWh and EV battery placed on the EU market must carry an individual battery passport accessible via QR code (permanently affixed, with a unique identifier per item). Portable and SLI batteries have other duties (label, QR, removability) but no passport.
Carbon footprint · Art. 7
Carbon-footprint declaration
A three-step regime: declaration → performance class → maximum lifecycle threshold. Phased in for EV, industrial (>2 kWh) and LMT batteries. The actual start of each phase depends on the Commission publishing the methodology and format, so dates may shift against the statutory ones.
Due diligence · Art. 48–53
Supply-chain due diligence
Operators with turnover ≥ €40m must run a due-diligence policy for cobalt, lithium, nickel and natural graphite, verified by a notified body. The deadline was moved from 2025 to 18 August 2027 by Regulation (EU) 2025/1561 (the “stop-the-clock” act).
Recycled content · Art. 8
Recycled content and recovery targets
From 18 August 2031 minimum shares of recovered raw materials apply (cobalt 16%, lead 85%, lithium 6%, nickel 6%), rising from 2036. The regulation also sets collection and recovery targets — e.g. 95% recovery of cobalt, copper, lead and nickel and 80% lithium recovery by 2031.
Sources: EUR-Lex and the European Commission (links above). Dates confirmed in official publications. Some carbon-footprint dates depend on the Commission first adopting delegated and implementing acts and may shift. As of June 2026.
Timeline
A clock that’s already ticking
From the old directive to hard deadlines. The nearest key obligation — the battery passport — lands on 18 February 2027.
- 2006Batteries Directive 2006/66/EC — the first framework for batteries
- Aug 2023Regulation (EU) 2023/1542 enters into force
- Feb 2024Regulation becomes applicable (most provisions)
- 2025Directive 2006/66/EC repealed; carbon-footprint declaration for EV batteries begins (with Commission acts)
- 18 Feb 2027Battery passport + QR code; removability of portable batteries
- 18 Aug 2027Supply-chain due-diligence obligations (postponed from 2025)
- 2028LMT battery collection target 51%; carbon-footprint declaration for LMT
- 2031Minimum recycled content (Co 16%, Li 6%, Ni 6%, Pb 85%); 80% lithium recovery
- 2036Higher recycled-content thresholds
Scale of the problem
The DPP for batteries, in numbers
Why the EU is regulating batteries — and why the product passport brings order to it. Every figure is sourced.
- 14×
- projected growth in global battery demand by 2030; the EU could account for ~17% of it
- European Commission
- ~12×
- projected growth in EU lithium demand by 2030 (and ~21× by 2050)
- Critical Raw Materials Act
- 63%
- of the world’s cobalt is extracted in the Democratic Republic of Congo
- European Commission
- ~19%
- share of battery-electric vehicles (BEV) in new EU car registrations in 2025
- ICCT
- ~251GWh
- annual battery-cell production capacity in Europe (Sept 2025)
- T&E / Bruegel
- 2kWh
- capacity threshold above which an industrial battery needs a passport
- Reg. 2023/1542
- 40m €
- turnover threshold from which supply-chain due diligence applies
- Reg. 2023/1542
- 95%
- target recovery rate for cobalt, copper, lead and nickel by 2031
- Reg. 2023/1542
- ~20×
- projected growth in nickel demand by 2040 (graphite ~19×, lithium ~14×)
- JRC
Statistics sources:European Commission — BatteriesCritical Raw Materials Act (CRMA)ICCT (2025)JRC — RMIS
Benefits
What you actually gain
The passport is not a compliance cost — it is data infrastructure that pays back on four fronts at once.
Compliance and market access
- Avoid having sales halted in the EU and losing OEM contracts.
- Ready for the passport, due diligence and carbon footprint without a costly last-minute rollout.
- A single data record consistent with CE marking and the declaration of conformity.
Full raw-material traceability
- Origin of cobalt, lithium, nickel and graphite, and every link of the supply chain.
- A carbon footprint calculated per plant — ready for declaration and performance classes.
- Proof of due diligence and conformity for any audit or customs request.
Brand and partner trust
- Protection against greenwashing claims — every statement backed by data.
- QR code as a product information channel: specs, safety, instructions.
- Credibility with OEMs and retailers that demand transparency.
Circularity and second life
- Cell state-of-health (SoH) opens the door to repurposing and second-life storage.
- Easier dismantling and recycling — the battery “knows” its composition and safety profile.
- Higher residual value and support for lithium, cobalt and nickel recovery targets.
Authenticity & safety
A battery that proves its origin and condition
The passport is more than legal compliance — it’s a digital identity that lets your customer, your installer and you verify the origin, specs and authenticity of every cell in seconds. In a world where counterfeit, unsafe cells can cause fires, that’s real protection for your brand and the user.
- Verify authenticity and specs with a single scan (QR) — no more “is this really a safe, genuine cell?”.
- Full origin: chemical composition, critical raw materials and every link of the supply chain.
- Protection against counterfeits and unsafe cells — a fake has no valid battery passport.
- State of health and history: registration, carbon footprint and higher value on the secondary and second-life markets.
Cost of inaction
What waiting costs you
“Let’s wait until it settles” is the most expensive strategy. Here’s why.
- A rollout under the pressure of the 18 February 2027 deadline costs many times more than calm preparation ahead of time.
- No carbon-footprint and due-diligence data = a real risk of halted EU sales and lost OEM contracts.
- Data on the origin of cobalt, lithium and nickel takes months to gather deep in the supply chain — it can’t be “made up” a week before the deadline.
- Competitors who implement earlier will own the “responsible battery” narrative and the edge in tenders.
We’ll show it on your batteries
Let’s book a short meeting. We’ll walk through your obligations on the timeline, assess the data scope for the passport and show how to launch the digital battery passport at your scale — without manual work.
Common doubts
Straight answers to the questions we hear from battery manufacturers and importers.
We manufacture batteries outside the EU — does this apply to us?
Yes. The obligation applies to anyone placing a battery on the EU market — on its own or built into a product (e-bike, power tool, energy storage, vehicle). What matters is selling in the EU, regardless of where it is made.
Which batteries does the passport cover?
The passport is mandatory for LMT (light means of transport), industrial (>2 kWh) and EV batteries from 18 February 2027. Portable and SLI batteries have other duties — label, QR code and removability — but no passport.
What exactly must the battery passport contain?
Among other things: identity data and chemical composition, share of critical raw materials, carbon footprint and performance class, due-diligence information, recycled content, performance and state of health (SoH), and dismantling and recycling instructions (Art. 77 and Annex XIII).
Are the carbon-footprint dates certain?
The declarations themselves are in the regulation, but their actual start depends on the Commission’s delegated and implementing acts — some dates have slipped against the original ones. The passport (18 February 2027) and due diligence (18 August 2027), however, are confirmed.
We have a small turnover — does due diligence apply to us?
Due-diligence duties apply to operators with turnover ≥ €40m; smaller companies are exempt. The battery passport, labelling and CE requirements, however, apply regardless of company size.
How is a DPP different from the QR code we already put on the cell?
Today that is usually a static code. The passport is a standardised (GS1 / Digital Link), updatable data record with a unique identifier per item — readable by the user, market-surveillance authorities and recyclers, and compliant with Regulation 2023/1542.