Battery Passports will become mandatory in the European Union from 18 February 2027 under the EU Battery Regulation (EU) 2023/1542. From that point, manufacturers placing electric vehicle (EV) and in-scope industrial batteries on the EU market must be able to provide ongoing, verifiable lifecycle data — not just one-off reports.
For many manufacturers, meeting this requirement on time depends on early coordination of data, systems, and processes across the supply chain. This guide sets out the key Battery Passport deadlines and explains what manufacturers need to prepare now to ensure batteries remain compliant and market-ready by 2027.
What Is a Battery Passport (and Why It Matters)
A Battery Passport is a digital record linked to each battery that contains verified lifecycle information. Battery Passports apply Digital Product Passport principles specifically to batteries under EU sustainability legislation.
Under the EU Battery Regulation, this includes:
- Battery identity and technical characteristics
- Carbon footprint and sustainability metrics
- Recycled content and material sourcing
- Performance, durability, and end-of-life information
Battery Passports are designed to improve traceability, transparency, and accountability across the battery value chain — from raw material sourcing to recycling.
Compliance Milestones
Understanding what to do and when is crucial to staying compliant. The EU Battery Regulation phases key requirements over several years to give manufacturers time to prepare.
Stage 1: Carbon Footprint Declaration
- EV Batteries: February 18, 2025 (already in effect)
- Industrial Batteries (>2 kWh): February 18, 2026
Action: Manufacturers must provide a carbon footprint declaration for each battery model per manufacturing plant. This ensures early data readiness and alignment with upcoming labeling and passport requirements.
Stage 2: Performance Classes (Labelling)
- EV Batteries: August 18, 2026
- Industrial Batteries (>2 kWh): August 18, 2027 (after Digital Battery Passports are already in place)
Action: Batteries must be labeled with a performance class (e.g., Category A, B, or C) based on their carbon intensity. Labeling for industrial batteries happens after their digital passport is implemented, ensuring all relevant data is already captured.
Stage 3: Digital Battery Passport
- All Industrial & EV Batteries: February 18, 2027
Action: Every battery must have a QR code linked to a digital passport containing verified data on: - Carbon footprint
- Recycled content
- Material composition
- Performance and durability
This stage highlights why spreadsheets often fail — digital systems are needed for ongoing audit-ready compliance.
Stage 4: Maximum Carbon Thresholds
- EV Batteries: February 18, 2028
- Industrial Batteries (>2 kWh): February 18, 2029
Action: Batteries exceeding specific thresholds (kg CO2e/kWh) will not be allowed on the EU market. Early passport implementation helps track these metrics continuously and avoid non-compliance.
Battery Passport Deadlines: What Happens When
The EU Battery Regulation (Regulation (EU) 2023/1542) introduces requirements in phases. Battery Passports are unavoidable and preparation must begin well before enforcement.
2025–2026: Foundation Phase
Before Battery Passports become mandatory, manufacturers are expected to:
- Establish battery identification systems
- Begin collecting lifecycle and supply chain data
- Align data formats with emerging Digital Product Passport frameworks
- Prepare for carbon footprint calculation and verification
This phase focuses on data readiness, not public disclosure.
2027: Battery Passports Become Mandatory
From 2027, Battery Passports are required for electric vehicle (EV) batteries and industrial batteries above defined capacity thresholds placed on the EU market.
Manufacturers must be able to:
- Assign a unique identifier (UID or QR code) to each battery
- Maintain a digital Battery Passport accessible to regulators and authorised stakeholders
- Provide verified data on:
- Environmental footprint
- Recycled content
- Material composition
- Performance and durability
This is the point where manual systems and spreadsheets typically fail — not just due to volume, but because of auditability and data integrity requirements.
Why 2027 Is a Hard Deadline — Not a Flexible Target
The 2027 requirement is explicitly stated in EU law. It is neither a pilot, a recommendation, nor a voluntary scheme. Many manufacturers discover too late that spreadsheets cannot support audit-ready compliance at scale.
Waiting until 2027 often leads to:
- Missing historical data that cannot be recreated
- Supplier resistance when data requests arrive too late
- Rushed implementations that increase cost and operational risk
Manufacturers that start early can pilot, test, and refine — rather than react under pressure.
What “Being Ready” for 2027 Actually Means
Being ready does not mean having every data point perfect today. It means having the right systems and processes in place to scale.
1. Digital Traceability Infrastructure
Battery Passports require continuous updates, not one-time declarations. Systems must support:
- Versioned data
- Timestamped changes
- Clear data ownership
2. Supplier Data Integration
Much of the required information comes from Tier 1 and Tier 2 suppliers. Early alignment avoids last-minute data gaps.
3. Alignment With Digital Product Passport Standards
Battery Passports apply Digital Product Passport principles specifically to batteries under EU sustainability legislation. Systems built today should remain compatible beyond batteries alone.
How Battery Passports Support Long-Term Compliance
Beyond meeting regulatory requirements, Battery Passports enable:
- Faster regulatory reporting
- Easier audits and inspections
- Better control over recycled-content claims
- Support for second-life and recycling markets
In practice, they become a long-term data asset, not just a compliance checkbox.
Practical Next Steps for Manufacturers
To stay ahead of the 2027 Battery Passport deadline and ensure smooth compliance, manufacturers should take these steps now:
- Map Applicable Products
- Identify which batteries fall under the EU Battery Regulation (EV vs industrial >2 kWh).
- Note the deadlines for carbon footprint declarations, labeling, and digital passport implementation.
Audit Existing Data- Review current lifecycle, sustainability, and performance data.
- Highlight missing or incomplete information to address gaps before mandatory deadlines.
Engage Suppliers Early- Many required data points come from Tier 1 and Tier 2 suppliers.
- Set clear expectations for data sharing and traceability to avoid last-minute delays.
Implement Digital Traceability Systems- Move from spreadsheets to auditable digital systems that support:
- Versioned data and timestamped updates
- Unique battery identifiers (UIDs or QR codes)
- Supplier integration and continuous updates
Pilot Battery Passport Workflows- Test how your digital passport captures carbon footprint, recycled content, and durability.
- Simulate audits and regulatory access to identify weaknesses before 2027.
Plan for Performance Labelling- For industrial batteries, ensure labeling workflows are ready by August 18, 2027, after digital passport data is in place.
- Verify that labels accurately reflect carbon intensity and other performance metrics.
Use Ready-Made Tools or Templates - Consider using a Digital Battery Passport software or template system to structure and track all required data.
- Early adoption of a verified tool ensures compliance readiness and reduces manual workload.
Monitor Regulatory Updates- The EU Battery Regulation may expand scope or refine calculation methods over time.
- Staying informed helps maintain compliance and adapt workflows proactively.
Tip: Starting these steps now avoids rushed implementations, reduces operational risk, and turns your Battery Passport into a long-term data asset, not just a compliance checkbox.
Final Takeaway
Battery Passports are not an emergency — but they are inevitable.
The 2027 deadline is firm, and preparation is the difference between smooth compliance and last-minute disruption. Manufacturers that act now gain clarity, flexibility, and control, while those who wait risk complexity, cost, and regulatory stress later.
FAQs
When do Battery Passports become mandatory under the EU Battery Regulation?
Battery Passports are required from 2027 for industrial and electric vehicle batteries placed on the EU market.
Which batteries require a Battery Passport in the EU?
The requirement initially applies to industrial batteries and EV batteries, with possible expansion in later phases.
Can spreadsheets meet Battery Passport compliance requirements?
Spreadsheets may help during early preparation, but they cannot support ongoing updates, audits, or regulatory access at scale.
Are Battery Passports part of the Digital Product Passport framework?
Yes. Battery Passports apply Digital Product Passport principles specifically to batteries under EU sustainability legislation.
Sources
EU Batteries Regulation (Regulation (EU) 2023/1542)
EU Commission guidance on Battery Passports
Digital Product Passport framework under ESPR
https://publications.jrc.ec.europa.eu/repository/handle/JRC141282
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