What applies?
From 18 February 2027, under Article 77 of Regulation (EU) 2023/1542, every LMT battery, every industrial battery over 2 kWh and every electric vehicle battery placed on the market or put into service needs a digital passport. The Commission continues to list this date as the start.
What is not settled yet
The act on access rights is still a draft. Some fields depend on obligations that do not yet apply in February 2027: the carbon footprint format is still to be set, and according to the Commission the due diligence report is only due from August 2027.
Your checklist
- Check whether you are affected: which products are covered, and who is the economic operator?
- Collect data: what is available in-house, and what must suppliers provide?
- Contact suppliers: make specific requests and include data delivery in contracts for new orders.
- Settle identifier and QR code: where does the code go on the battery, and who prints it?
- Clarify the registry: who registers passports in the DPP Registry?
- Do a test run: take one model with real serial numbers from data set to scan.
- Define processes: who maintains changes, and how does the passport stay current after a repair?
What this means for Batterypass
For the test run, you can use the obligation check and the free Pilot plan: one model, 25 passports, QR labels. Registration in the DPP Registry is included, but your company must verify itself in the Registry first.
Sources
This article reflects the status on its publication date and is not legal advice. The linked original texts are decisive.