If you've started researching battery compliance, you've met at least four names that sound interchangeable: Battery Pass, battery passport, Batteriepass, BatteryPass-Ready. They are not the same thing — and only one of them is a legal obligation. This article untangles them, because the distinction decides what you actually have to do before 18 February 2027.
The battery passport: the legal obligation
The battery passport is the digital record required by Article 77 of the EU Battery Regulation (EU) 2023/1542. From 18 February 2027, every EV battery, every LMT battery (e-bikes, scooters), and every industrial battery above 2 kWh (including stationary storage) placed on the EU market must have one, accessible via a QR code on the battery.
This is the only item on this list with a deadline and penalties attached. The economic operator placing the battery on the market — the manufacturer, or the importer if the manufacturer sits outside the EU — is responsible. If you import batteries into the EU, this obligation lands on you, whether or not your supplier has heard of it.
What goes into it is defined by Annex XIII of the regulation, detailed further by the Commission's guidance "Digital Batteries Passport – data points by category" (v2.0, August 2026), which labels 71 data points across public, restricted and authority-only access levels: identification, materials and composition, carbon footprint, due diligence, circularity, performance and durability, labelling and conformity.
Battery Pass: the consortium that wrote the playbook
Battery Pass (often written BatteryPass) is a German, federally funded consortium project — industry partners plus research institutes such as Fraunhofer IPK — that worked out how a battery passport should be implemented in practice. Its best-known output is the Battery Passport Content Guidance, which mapped the regulation's requirements to concrete data attributes long before the Commission's own guidance existed.
The Battery Pass project is not a law, not an authority, and not something you register with. But its work directly shaped the standards below, and its name is why half the internet calls the legal document a "battery pass". If you search Batteriepass in German, you'll find both meanings mixed together — the legal passport and the consortium.
DIN DKE SPEC 99100: the data structure
DIN DKE SPEC 99100:2025-02 is the German specification that turned the Battery Pass consortium's content work into a formal data structure: seven clusters covering identification, materials & composition, carbon footprint, due diligence, circularity, performance & durability, and labelling/conformity.
It is not legally binding either — the binding data model will come with the delegated acts under Articles 77/78, which are not yet adopted. But DIN DKE SPEC 99100 is the working basis the industry (and PassportLab's own canonical schema) maps to today, precisely so that the jump to the final delegated acts is a re-mapping, not a rebuild.
Alongside it, CEN/CENELEC JTC 24 has produced the first EN standards for DPP system architecture, including EN 18222 for the interface/API layer — recognised in July 2026, though the Commission's citation decision that would create a presumption of conformity is still pending.
BatteryPass-Ready: the test environment
BatteryPass-Ready is a validation environment from Fraunhofer IPK: eleven test scenarios plus data validation that check whether a battery passport dataset is structured correctly. Passing it is voluntary — a public trust marker, not a certificate of legal conformity. It's the closest thing the ecosystem currently has to a conformance check, and a good question to ask any provider: do your exports pass BatteryPass-Ready?
So what do you actually have to do?
- Check whether your batteries are in scope. EV, LMT, or industrial >2 kWh placed on the EU market from 18 February 2027 → yes. Our battery check answers this in two minutes.
- Start collecting the data now. The 71 data points pull from your suppliers, your test reports, and your carbon footprint calculations. Gathering and cleaning that data is the slow part — typically months, not weeks — and supplier lead times don't care about your deadline.
- Don't wait for the delegated acts. They will refine the format, not remove the obligation. A passport built on DIN DKE SPEC 99100 today is built to be re-mapped, not rebuilt.
- Plan for registration. The EU DPP Registry is live, but battery registration specifically is not yet possible — the battery data model is still pending. When it opens, you (or a service provider you authorise) register each passport's identifier.
The short version
| Name | What it is | Binding? |
|---|---|---|
| Battery passport | Legal requirement, Art. 77, Reg. (EU) 2023/1542 | Yes — from 18 Feb 2027 |
| Battery Pass | German consortium project; wrote the content guidance | No |
| DIN DKE SPEC 99100 | Data structure specification based on that guidance | No (working basis) |
| BatteryPass-Ready | Fraunhofer IPK test environment | No (trust marker) |
If the deadline applies to you and your product data lives in supplier PDFs and spreadsheets, that's exactly the case our battery passport software and service was built for: send us the raw data, we map it to every Annex XIII field, flag the gaps, and keep the passport current as the delegated acts land.