Most Digital Product Passport dates you read about are estimates, milestones for the Commission, or consultant-manufactured urgency. One is none of those things: 18 February 2027, when the battery passport becomes mandatory under the Battery Regulation (EU) 2023/1542. It is written into law, it survived the 2025–26 omnibus simplification packages untouched, and as of today it is about seven months away.
Seven months is comfortable if you start now and tight if you start in December — mostly because the slow part is prying data out of cell suppliers, not building the passport itself. Here is the practical checklist.
Who is covered — and who is not
The passport requirement applies to batteries placed on the EU market from 18 February 2027 in three categories:
- ✓EV batteries — traction batteries for electric vehicles.
- ✓LMT batteries — light means of transport: e-bikes, e-scooters and similar.
- ✓Industrial batteries above 2 kWh — stationary storage, forklifts, and other industrial applications.
Note the trigger: placed on the market. Stock already on the EU market before 18 February 2027 does not retroactively need a passport. Units you place on the market from that date do — which is why production and labelling processes, not just data, have to be ready in time.
What data Annex XIII actually requires
The passport content is defined in Article 77 and Annex XIII of the regulation. The list looks long, but it groups naturally into five buckets:
A note on the carbon footprint
The carbon-footprint declaration only bites once the Commission’s methodology acts are adopted — and the draft delegated act for EV batteries, published back in April 2024, is still unadopted as of July 2026. So carbon-footprint declarations are not yet in force. The honest advice is two-sided: you cannot finalise a compliant declaration today, but the underlying inputs — supplier energy data, material origins, transport legs — take months to collect, so gather them now and calculate when the methodology lands.
A note on recycled content
From February 2027 you declare the recycled-content shares. The minimum thresholds — 16% cobalt, 6% lithium, 6% nickel, 85% lead — only apply from 18 August 2031. In 2027 you are reporting reality, not hitting targets. Do not let a supplier’s low recycled-content number stop you shipping a passport; let a supplier’s refusal to give you the number worry you instead.
One passport per battery, not per model
This is the requirement that surprises teams most. The battery passport is item-level: each individual battery gets its own passport with a unique identifier, accessed through a QR code on the unit. A single shared page per model — the pattern most brands know from product pages — is not enough.
Practically, that means your serial-number scheme, your label printing and your passport platform have to talk to each other. Model-level data (chemistry, design, dismantling info) is shared across units; unit-level data (serial number, manufacturing date) is stamped per battery. Getting this wiring right is a production-line task as much as a data task, which is why it sits in the middle of the plan below, not the end.
Your month-by-month plan to February 2027
The pattern to notice: the first three months are data work, and only then does software enter the picture. Teams that invert this — buy a tool in January, discover in February that the cell supplier won’t confirm recycled-content shares — are the ones that miss the date.
An honest note on who this is for
If you are a major EV manufacturer, you have an enterprise systems team and an integration project already running; a SaaS blog post is not your compliance plan. productpasses.com is built for the other end of the market: e-bike and scooter brands, and small industrial-battery makers — companies with real Annex XIII obligations and no compliance department. That is our sweet spot, and it is exactly the segment the February date catches least prepared. Our battery passport guide walks through the required fields in detail, and if you want the wider context on how battery passports fit into the EU’s DPP infrastructure, start with what the DPP registry launch actually changes and our plain-language DPP explainer.
The short version
- ✓The date is real: 18 February 2027, confirmed, untouched by the omnibus packages (only due diligence moved, to August 2027).
- ✓Scope is narrow: EV, LMT and industrial >2 kWh. No phones, no laptops, no portable cells.
- ✓Item-level, QR-linked: one passport per battery, unique identifier per unit.
- ✓Start with suppliers, not software: the recycled content, chemistry and carbon inputs are the long pole. See plans and pricing when you are ready to put the data somewhere.