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Digital Battery Passport 2027: What the Industry Needs to Know Now

Starting February 2027, the Digital Battery Passport becomes mandatory. An overview of requirements, practical challenges, and current market developments.

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Digital Battery Passport 2027: What the Industry Needs to Know Now

The countdown is on: Starting February 18, 2027, industrial batteries, traction batteries for electric vehicles, and stationary storage systems with a capacity of 2 kWh or more must be equipped with a Digital Battery Passport (DBP). The legal basis is the Battery Regulation (EU) 2023/1542, which — together with the overarching ESPR Regulation (EU) 2024/1781 — establishes the binding framework for digital product passports in the EU. With fewer than eight months until the deadline, the industry is still far from widespread compliance readiness.

What the Battery Passport Actually Requires

Mandatory Content and Data Structure

The Digital Battery Passport is not a voluntary sustainability declaration — it is a machine-readable data object that must be accessible via a unique identifier, typically a GS1 Digital Link-compliant QR code. Among other things, the regulation mandates:

  • Product-specific carbon footprint (PCF) at the batch level, calculated using ISO 14067-compatible methods. The JRC draft from the European Commission specifies that the PCF declaration may not be aggregated at the model level — it must be genuinely batch-specific.
  • Data on critical raw materials (cobalt, lithium, nickel, manganese), including proof of origin and due-diligence documentation in accordance with supply chain obligations.
  • Recyclability and recycled content — both as actual values and as targets for future product generations.
  • Condition data (State of Health, State of Charge) for reused batteries in the second-life market.

The batch-level PCF requirement in particular poses significant challenges for many manufacturers: if you are still calculating based on annual average figures from energy procurement, you will not meet the requirements.

Technical Infrastructure: Resolvers and Data Access

The regulation requires that the battery passport be accessible via a publicly available resolver. For end consumers, a portion of the data must be retrievable without authentication; tiered access rights apply for authorities, authorized repair shops, and recyclers. This corresponds to the principle of the Digital Product Passport as defined by the ESPR as an overarching concept: one product, one identifier, multiple data layers with role-based access.

Where the Industry Stands Today: Two Core Problems

The Minespider Implementation Report 2026 analyzes the current state of compliance readiness and identifies two structural problems that run across the entire value chain:

Problem 1: Data Fragmentation

Battery cell manufacturers, module producers, system integrators, and OEMs use different ERP systems, PLM platforms, and quality management systems. A continuous, machine-readable data chain from raw material extraction to the finished product exists in very few cases. Particularly critical: the batch-level PCF requires energy consumption data from production — data that in many facilities is still recorded manually or is not available in digital form at all.

Problem 2: Dynamic Data Updates

A battery passport is not a static document. Condition data changes over the product lifecycle, recalls require immediate updates, and recycling information must be added at the end of the use phase. Systems based on immutable PDF exports or static QR codes fundamentally fail this requirement. In this context, the use of dynamic QR codes and centralized data management — as enabled by bulk import for scalable deployments, for example — is not a convenience feature but a technical necessity.

Market Movements: Who Is Positioning Now

Recent weeks have brought a series of relevant market developments that illustrate how technology and certification providers are preparing for the deadline.

Validation Infrastructure: BatteryPass-Ready

On June 24, 2026, the BatteryPass-Ready project launches its public test environment. Companies can use it to validate their DPP solutions against EU requirements — in a neutral, standards-based manner and without vendor lock-in. This is an important step, as no independent testing body previously existed that could make a reliable statement about the conformity of a specific implementation.

Certification and Traceability: Bureau Veritas and Circulor

Bureau Veritas and Circulor have announced a strategic partnership that combines testing, inspection, and certification expertise with a digital traceability platform. The model is symptomatic of a broader trend: traditional certification bodies are recognizing that physical audits alone are insufficient to ensure data continuity across multi-tier supply chains. Digital traceability systems are becoming an integral part of the certification process.

Labeling: Tamper-Evident Labels and GS1-Compliant Printing Systems

Securikett presented its Codikett 2.0 platform — a tamper-evident labeling solution directly linked to DPP data management. In parallel, Markem-Imaje released CoLOS Software Version 7, a solution for GS1 Digital Link-compliant 2D codes on industrial printing systems, featuring centralized management and automated workflows. Both approaches address a practical challenge: the physical connection between a product and its digital passport must be tamper-proof and scalable.

Also noteworthy: Polytag and DataLase have announced a collaboration that enables GS1-compliant QR codes to be applied to difficult packaging substrates using laser-reactive printing — even at production line speeds. While this is primarily relevant to the consumer goods sector, it demonstrates how printing technology is responding to the requirements of the GS1 Digital Link standard.

Greenwashing Risk: EmpCo as an Underestimated Factor

Alongside the Battery Regulation, the EmpCo Directive (EU) 2024/825 has entered into force, prohibiting misleading environmental claims in the B2C space. This also applies to information made accessible via a battery passport: if you communicate a carbon footprint that was not calculated using a recognized methodology, you risk not only compliance issues under the Battery Regulation but also violations of the greenwashing prohibition.

The European Environmental Bureau (EEB), together with ten civil society organizations, has published a position paper analyzing the DPP as a tool for modernizing REACH chemicals regulation. The core demand: substance data in the product passport must be linked to the central ECHA registry to avoid duplication and improve data reliability. This has not yet been decided at the policy level, but it signals the direction in which the regulatory framework could evolve.

Recommendations for Manufacturers and Importers

The time remaining until February 2027 is sufficient for a complete implementation — but only if you start now. The following steps should be prioritized:

  1. Define your PCF methodology: Which system boundaries, allocation methods, and primary data sources will you use? ISO 14067 conformity must be documented before the first batch is declared.
  2. Map your data sources: Which systems supply which mandatory data? Where are the gaps that need to be closed manually or through supplier integration?
  3. Choose your resolver architecture: Self-hosted, platform provider, or a hybrid model? This decision has long-term implications for data sovereignty and operating costs.
  4. Use the test environment: The BatteryPass-Ready test environment, available from June 24, 2026, offers the opportunity to validate implementations against the official requirements early — before market surveillance authorities become active.

The Battery Regulation is the first major real-world test of the EU's DPP concept. How well the industry meets this deadline will significantly influence how ambitious the follow-on regulations for textiles, electronics, and other product categories under the ESPR will be.

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