Legal Framework: Two Regulations, One Goal
The Digital Battery Passport (DBP) is not a voluntary initiative — it is binding EU law. The legal basis is the Battery Regulation (EU) 2023/1542, which, together with the overarching ESPR Regulation (EU) 2024/1781, establishes the mandatory framework for digital product passports across the EU.
As of February 18, 2027, industrial batteries, traction batteries for electric vehicles, and stationary storage systems with a capacity of 2 kWh or more must be accompanied by such a passport. Any party placing batteries on the EU market — whether manufacturer, importer, or authorized representative — bears compliance responsibility. This also affects companies outside the EU: the UK's Department for Business and Trade has already launched a survey on the impact on British exporters, because the requirements effectively apply to UK manufacturers supplying the EU market as well.
Required Data: What the Passport Must Actually Contain
Product-Specific Carbon Footprint at Batch Level
This is the most technically demanding data point. The product-specific carbon footprint (PCF) must be calculated using ISO 14067-compatible methods — and it must be batch-specific, not aggregated at the model level. The European Commission's JRC draft makes this clear: a single PCF figure per battery model is not sufficient. Each production batch requires its own traceable value.
This has direct implications for data architecture. If you calculate PCF values only once per battery type and apply them across all batches, you do not meet the requirement. The calculation must be integrated into production processes — with interfaces to energy consumption data, material origin, and transport logistics.
State-of-Health Data for the Second-Life Market
For repurposed batteries, the Battery Regulation requires the recording of State of Health (SoH) and State of Charge (SoC). These data points are not static — they change throughout the entire service life and must be updated in the battery passport accordingly. For operators of second-life applications (such as stationary storage systems built from retired EV batteries), this means the passport must be dynamically updatable, not merely a one-time document issued at first placement on the market.
Additional Mandatory Fields at a Glance
The regulation also requires information on:
- Raw material origin and supply chain (cobalt, lithium, nickel, manganese down to mine level)
- Recycled content in active materials (with phased minimum quotas starting in 2030/2035)
- Capacity, service life, and performance parameters
- Hazardous substances in accordance with REACH requirements
- Repairability and disassembly instructions
The battery passport must be accessible via a GS1 Digital Link-compatible QR code or Data Matrix code that links directly to the data — not to a generic product page.
Compliance Reality: Two Structural Problems
The Minespider Implementation Report 2026 analyzes the current state of industry readiness and identifies two structural problems that run across the entire value chain.
Problem 1: Data Fragmentation
Battery supply chains are complex and globally distributed. Raw material data sits with the mining company, cell data with the cell manufacturer, module integration with the Tier 1 supplier, and final assembly with the OEM. None of these actors alone holds all the mandatory data required for the battery passport. Aggregating this data into a coherent, regulation-compliant data model is the central operational challenge.
The problem is compounded by a lack of standardization in data formats across supply chain partners. Many companies still rely on proprietary ERP exports, PDF certificates, or Excel spreadsheets — formats that cannot be directly mapped to a DPP data model.
Problem 2: Dynamic Data Updates
A Digital Product Passport is not a static document. State data such as SoH and SoC change continuously. Recall notices, recycling information, and certification updates must be able to be added after the fact. This requires a backend infrastructure that supports data updates across the entire product lifecycle — including versioning and an audit trail.
Many companies have so far only evaluated static solutions (such as PDF-based data sheets with a QR code), which are fundamentally incapable of meeting this requirement.
Market Developments: Who Is Positioning How
BatteryPass-Ready: A Neutral Validation Environment
On June 24, 2026, the BatteryPass-Ready project will launch its public testing environment. Companies will be able to validate their DPP solutions against EU requirements there — in a neutral, standards-based setting with no vendor lock-in. This matters because the market is currently flooded with proprietary solution promises that are nearly impossible to compare objectively. A vendor-independent testing environment creates a shared reference baseline for the first time.
Bureau Veritas & Circulor: Inspection Expertise Meets Traceability
Bureau Veritas and Circulor have announced a strategic partnership that combines testing, inspection, and certification expertise with a digital traceability platform. The approach directly addresses the data fragmentation problem: Bureau Veritas contributes on-site physical verification (raw material audits, cell testing), while Circulor provides digital supply chain tracking. Together, they aim to ensure data integrity across multiple supply chain tiers.
Securikett Codikett 2.0: Tamper-Evident Labeling
Securikett introduced its Codikett 2.0 platform, a tamper-evident labeling solution directly linked to DPP data management. The approach targets a real problem: a QR code on a battery housing must be physically counterfeit-proof — otherwise a counterfeit product could be linked to a legitimate battery passport. Tamper evidence at the label level is not an explicit regulatory requirement, but it is a sensible addition for high-value battery systems.
GS1 Digital Link as the Connectivity Standard
Markem-Imaje has introduced CoLOS Software Version 7, a solution for GS1 Digital Link-compliant 2D codes that enables centralized management and automated workflows for smart labels. The GS1 Digital Link is the technical linchpin: it encodes not just a URL, but structured product identifiers (GTIN, serial number, batch number) that are machine-readable and standardized. Without this standard, an interoperable DPP infrastructure is virtually unachievable.
What Companies Should Do Now
The time remaining before February 2027 is tighter than it appears. Typical DPP infrastructure implementation projects take 12–18 months — which means the implementation start should have happened no later than summer 2025. If you haven't started yet, you are already behind.
The following steps are immediate priorities:
Conduct a data inventory across the supply chain: Which mandatory data exists where, in what format, and at what quality level? Without this baseline assessment, realistic implementation planning is impossible.
Set up batch-specific PCF calculation: This is the most complex individual requirement and demands integration with existing production systems. External consultants with ISO 14067 expertise are almost always necessary here.
Choose a DPP backend with update capability: Static solutions are a non-starter. The backend must support data updates across the entire product lifecycle, provide versioning, and maintain audit trails.
Plan GS1 Digital Link-compliant labeling: The physical QR code on the battery must comply with the GS1 standard. This applies to both the data structure and the print quality and durability under industrial conditions.
Use the BatteryPass-Ready testing environment: From June 24, 2026, a neutral validation environment will be available. You should test your solutions there early — before moving into series production.
The regulation is enacted, the deadline is set. Anyone still banking on a postponement or a softening of the requirements is risking market access problems in one of the most important growth markets of the coming decade.
