The February 18, 2027 Deadline: What Manufacturers Need to Prepare For
February 18, 2027 marks the end of the transition period for one of the EU's most far-reaching industrial digitalization mandates: from that date onward, 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, complemented by the overarching ESPR Regulation (EU) 2024/1781.
What may look like yet another compliance form at first glance is, in practice, a complex data management and infrastructure challenge — with implications across the entire value chain, from raw material extraction to the recycling facility.
Mandatory Data Fields: What the Passport Must Actually Contain
Product-Specific Carbon Footprint at Batch Level
One of the most technically demanding requirements is the disclosure of the product-specific carbon footprint (PCF). A key clarification from the European Commission's JRC draft makes this explicit: the PCF figure must not be aggregated at the model level — it must be genuinely batch-specific and calculated using ISO 14067-compatible methods.
In practice, this means that manufacturers who have previously reported an average emissions figure per model line will need to fundamentally overhaul their data collection processes. Each production batch will require its own CO₂ metric, which must be retrievable through the passport.
Dynamic Status Data for the Second-Life Market
For reused batteries, the regulation requires that condition data such as State of Health (SoH) and State of Charge (SoC) be dynamically updatable — since these values change continuously throughout a battery's lifecycle. A static QR code written once at the point of production is not sufficient for this purpose.
This is where the structural challenge becomes clear: the passport is not a document — it is a living data object. From a technical standpoint, this requires a backend infrastructure that supports write access over many years while simultaneously guaranteeing data integrity.
Additional Mandatory Fields at a Glance
The regulation requires, among other things:
- Origin and composition of raw materials used (including cobalt, lithium, nickel, and lead)
- Information on hazardous substances
- Capacity, rated voltage, and expected service life
- Information on repairability and disassembly
- Take-back information and recycling rates
Standards Framework: EN 18216 through EN 18223 Set the Technical Baseline
On June 25, 2026, CEN and CENELEC hosted a public webinar introducing the first six published European standards (EN 18216 through EN 18223), developed by Joint Technical Committee JTC 24. These standards define the product-agnostic framework for implementing the EU Digital Product Passport — that is, the cross-cutting requirements that apply to all product categories, not just batteries.
The standards address, among other areas:
- Interoperability: How data is exchanged between different systems and stakeholders
- Data consistency: Minimum requirements for data quality and currency
- System architecture: How decentralized and centralized components interact
In parallel, ISO/IEC JTC 5 is active at the international level, developing a globally harmonized standards framework for DPPs. GS1 China was recently appointed as the Chinese mirror committee for JTC 5 — a signal that DPP standardization is no longer a purely European affair.
This is relevant for manufacturers who market their products outside the EU: if you are now building on EU-compliant architectures, you should verify whether they are compatible with the emerging ISO/IEC structures.
Implementation Status: Two Core Problems Dominate in Practice
Data Fragmentation Along the Supply Chain
The Minespider Implementation Report 2026 analyzes the current state of compliance and identifies two problems that run across the entire value chain.
The first is data fragmentation: raw material data sits with the mine operator, processing data with the refinery, cell data with the cell manufacturer, and pack data with the OEM. None of these actors currently has a complete view of all the fields required for the DBP. Aggregating this data into a coherent passport object requires either bilateral data-sharing agreements or a shared platform infrastructure.
Dynamic Data Updates as a Technical Hurdle
The second problem is dynamic data updates. While static product data (model, chemistry, manufacturer) can be captured once, SoH values, charge cycles, and repair histories must be continuously updated throughout the battery's entire service life. This presupposes that all actors who handle a battery over its lifetime — repair shops, leasing companies, recyclers — either receive write access to the passport object or can at least transmit data to the passport holder.
BatteryPass-Ready launched a public test environment in June 2026, allowing companies to validate their DBP solutions against regulatory requirements. This is a useful tool — but it does not solve the underlying data sourcing problem.
The Central DPP Registry: Open Questions on Infrastructure
The European Commission is working on a central DPP registry through which passports will be registered and made discoverable. The industry association Orgalim has published recommendations calling for, among other things, high-volume automated registration processes and fault tolerance.
The context: the battery segment alone produces millions of units annually. A registry that requires manual entries or synchronous API calls without error tolerance would not be operationally viable. Orgalim therefore calls for asynchronous registration mechanisms, clear SLA requirements, and fallback scenarios in the event of registry outages.
It remains unclear how the registry will be technically implemented and which identifiers it will accept as primary keys. For systems built on GS1 Digital Link and GTINs, native support for these standards would be highly desirable — they are already well established in logistics and enable machine-readable product identification via QR codes.
Verification and Labeling: New Solutions Entering the Market
Beyond data management, the physical linkage between a product and its passport is a challenge in its own right. Securikett has introduced its Codikett 2.0 platform, a tamper-evident labeling solution that combines cryptographic signatures with the physical label. The approach is designed to make counterfeiting and retroactive manipulation of the passport link significantly more difficult.
Bureau Veritas and Circulor have announced a strategic partnership that combines inspection services with supply chain traceability. The model: Bureau Veritas handles physical inspection and certification, while Circulor provides the digital data management and passport infrastructure.
What Companies Should Do Now
A DIN/DKE survey conducted as part of the 14th German Standards Panel found that companies have a significant need for clear guidance — the complexity of the legal requirements frequently exceeds internal capacity for interpretation.
In concrete terms, the following approach is recommended for manufacturers and importers:
- Data inventory: Which mandatory fields can already be populated today from existing systems (ERP, PLM, MES) — and which cannot?
- Review supply chain contracts: Are suppliers contractually obligated to provide batch-specific CO₂ data and raw material documentation?
- Define the technical architecture: Centralized vs. decentralized data model, interfaces to the future EU registry, write access for third parties in the second-life market.
- Ensure standards compliance: The EN 18216–18223 series defines minimum requirements — systems should be validated against these standards, ideally using test environments such as BatteryPass-Ready.
- Clarify your identifier strategy: GTIN-based identification via GS1 Digital Link is currently the most widely adopted standard for machine-readable product identification and is likely to be supported by the EU registry.
February 18, 2027 is closer than it appears — and implementation projects that have not yet started will have a hard time finishing on time.
