Regulation (EU) 2023/1542 replaces the old Battery Directive and introduces the first mandatory digital product passport in EU law. From 18 February 2027 every LMT battery, industrial battery above 2 kWh and EV battery must carry a passport reachable from a QR code on the battery itself.
The passport must expose, among other things: a unique per-unit identifier, battery chemistry and composition, carbon footprint with a performance class, recycled content of cobalt, lithium, nickel and lead, supply-chain due-diligence reporting (Articles 47–53), State of Health and expected lifetime.
Batteries are also the first and so far only product group the EU DPP Registry accepts — though registration cannot be completed yet, because the semantic catalogue for the group has not been defined. Enrolling your organisation is the part you can finish today.
18 February 2027 is the deadline for having a passport, not for starting one. The parts with a queue are the ones outside your control: a qualified electronic seal from a trust service provider, and verification of your organisation in the EU DPP Registry. Neither depends on your product data, and both can be running while you build.
Per-unit data is the other slow part. Chemistry, recycled content per substance, due-diligence audits and disassembly steps come from suppliers and test houses, not from a form. Collect them a supplier at a time now, and February 2027 is an administrative date rather than a project.
A unique identifier per physical cell or pack (ISO/IEC 15459) — not just per model — so each battery has its own lifecycle record.
A Bearer-token endpoint feeds real-time State of Health, cycle count and energy throughput straight from the battery management system (Article 14).
A–G class computed automatically from kg CO₂e/kWh, per battery category (EV / industrial / LMT / portable / SLI).
Per-substance audits for cobalt, lithium, nickel and graphite with OECD compliance and CAHRAS risk flags (Articles 47–53).
Recovery % per substance with auditor, methodology and issue/expiry dates (Article 8).
Step-by-step disassembly with tools, fasteners and warnings, plus user/professional removability (Annex XIII, Article 11).
VoltCore VC-75E — a 75 kWh NMC 811 EV pack with 10 materials, 5 substances, carbon-footprint class, due diligence and a per-unit SoH endpoint.
Not yet. Batteries are the first and so far only product group the Registry offers, but the Commission's own guide states that registration cannot complete, because the semantic catalogue for the group has not been defined. What you can finish today is enrolling your organisation and being verified — which is the part with the queue.
A qualified electronic seal first, because it has the longest lead time — you can order it through us, we are an authorised reseller; then a verified organisation in the EU DPP Registry; then the passports themselves. The first two have nothing to do with your product data, so they can run in parallel with building it.
Per unit. The regulation requires a unique identifier and per-unit data such as State of Health, so a model-level record is not enough on its own. dpp.gs supports both: a model passport for the shared data and serialised per-unit records with their own lifecycle.
Article 13(6) lets the code go on the packaging when the battery is too small, with accompanying documents as the last resort. It covers the labelling and the passport together, so you do not need a separate answer for each.
Your battery management system or fleet platform posts SoH, cycle count and energy throughput to a token-authenticated endpoint, and the passport shows the live value. That is what Article 14 asks for in practice.
No. You enter kg CO₂e/kWh and the battery category, and the A–G performance class is assigned using the thresholds the regulation sets for that category.
Be passport-ready before 18 February 2027 — and enrol in the EU Registry while you build.