EU Battery Regulation
Digital Product Passport
Regulation (EU) 2023/1542 mandates a Digital Product Passport for industrial batteries, EV batteries, and LMT batteries. Compliance is required from October 2026 — covering carbon footprint, materials sourcing, and end-of-life data.
What a battery DPP must contain
Under Annex XIII of Regulation (EU) 2023/1542, a compliant battery DPP must expose the following data — machine-readable, accessible via QR code, and cryptographically verifiable.
Battery Identification
Unique identifier per battery model and per individual battery unit (serial number). Encoded in a QR code or data matrix accessible without specialist equipment.
MandatoryCarbon Footprint
Life-cycle carbon footprint in kg CO₂e per kWh of battery capacity, declared per manufacturing batch. Required from 2025 for declaration, verified threshold compliance from 2027.
MandatoryRecycled Content
Percentage by weight of cobalt, lithium, nickel, and lead recovered from waste and used in active materials. Minimum thresholds apply from 2027.
MandatoryResponsible Sourcing
Due diligence policy for cobalt, natural graphite, lithium, and nickel. Supply chain risk categories and supplier audit results.
MandatoryBattery State & Performance
State of health (SoH %), remaining capacity (Ah), state of charge, cycle count, and expected battery lifetime under normal operating conditions.
MandatoryChemistry & Hazardous Substances
Electrochemical chemistry (e.g. LFP, NMC, NCA), hazardous substances present above threshold concentrations, and applicable REACH SVHCs.
MandatoryManufacturer & Supply Chain
Battery manufacturer name and address, cell manufacturer, cathode and anode active material suppliers, and location of manufacturing facilities.
MandatoryEnd-of-Life & Disassembly
Removability and replaceability information, disassembly instructions for waste treatment operators, and instructions for safe removal of hazardous substances.
MandatoryAnnex XIII schema — built in
PassportLab enforces the Battery Regulation Annex XIII data schema at the point of entry. Mandatory fields are validated before a passport is published — so you can't accidentally ship a non-compliant DPP.
Annex XIII schema enforcement
PassportLab validates battery passport data against the Regulation (EU) 2023/1542 Annex XIII schema before publishing. Mandatory fields are blocked, not warned.
State of health updates over time
Battery performance data (SoH, remaining capacity, cycle count) changes with use. PassportLab supports live data updates via API with a full immutable audit trail of every change.
Carbon footprint & recycled content tracking
Track per-batch carbon footprint declarations and recycled content percentages for cobalt, lithium, nickel, and lead — with audit-ready evidence links.
W3C Verifiable Credential signing
Every battery DPP is signed with Ed25519 and issued as a W3C VC v2.0. Regulators and customs authorities can independently verify the credential without calling PassportLab.
Battery Regulation DPP — key dates
From 18 August 2024, all batteries covered by the regulation must carry a QR code linking to battery information. The full DPP is not yet mandatory.
Battery manufacturers must begin calculating and declaring lifecycle carbon footprints per battery model. Data collection infrastructure should be in place now.
Digital Product Passports become mandatory for industrial batteries >2kWh and LMT (light means of transport) batteries. All Annex XIII fields must be published and verifiable.
Digital Product Passports extend to electric vehicle batteries. State of health and remaining capacity reporting becomes mandatory at point of sale and throughout the battery lifecycle.
Source: Regulation (EU) 2023/1542 on batteries and waste batteries. View all ESPR deadlines →
Battery DPP — FAQ
Which batteries does the DPP requirement apply to?
The Battery Regulation DPP requirement applies to industrial batteries with a capacity greater than 2kWh, LMT (light means of transport) batteries (e-bikes, e-scooters), and electric vehicle batteries. Portable batteries (consumer electronics) are not in the first phase but will be brought in later.
Does the battery DPP apply to batteries imported into the EU, or only those manufactured there?
Both. Any battery placed on the EU market must have a DPP, regardless of where it was manufactured. The importer or authorised representative in the EU is responsible for ensuring compliance.
What recycled content percentages are required?
From 2030: minimum 12% recycled cobalt, 4% lithium, 4% nickel per battery model (by active material weight). From 2035: 20% cobalt, 10% lithium, 12% nickel. These thresholds must be declared in the DPP and verified by a notified body.
What is a 'state of health' declaration and how is it updated?
State of health (SoH) is a percentage reflecting the battery's remaining capacity relative to its rated capacity. Under the Battery Regulation, the DPP must be updateable with current SoH data throughout the battery's lifecycle — not just at point of sale. PassportLab supports live SoH updates via API.
How does the battery DPP relate to the ESPR?
The Battery Regulation (EU) 2023/1542 is a standalone regulation — separate from ESPR — specifically covering batteries. However, the DPP data model follows similar principles (unique identifier, QR code, verifiable data) and the two regulations will need to be managed together for products that contain batteries as components.
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