EU Battery Regulation 2027: What Brands Need to Do Now
The EU Battery Regulation requires Digital Product Passports for all batteries by February 2027. Here's the data you need and how to prepare.
February 2027 is the first hard deadline in the EU's Digital Product Passport rollout. Every battery — and every product containing a battery — placed on the EU market will need a DPP. That's less than 12 months away.
This article covers what the regulation actually requires, who it affects, and what you need to do to comply.
Feb 2027
Compliance deadline
2 kWh+
Portable battery threshold
10 years
Data retention
What is the EU Battery Regulation?
Regulation (EU) 2023/1542 replaces the old Battery Directive and introduces comprehensive lifecycle requirements for batteries sold in the EU. The Digital Product Passport is a central part of this regulation.
The regulation applies to all batteries placed on the EU market, regardless of where they're manufactured. It covers:
- Electric vehicle (EV) batteries — including those in e-bikes, scooters, and electric cars
- Industrial batteries — energy storage systems, backup power, data center batteries
- Portable batteries — above 2 kWh capacity
- Light means of transport (LMT) batteries — e-bikes, e-scooters
What data must the battery DPP contain?
Battery DPPs are the most detailed in the ESPR framework. The regulation requires specific data points that go well beyond basic product information:
Mandatory fields
- Battery chemistry — cell type, cathode/anode composition
- Capacity & performance — rated capacity, energy density, expected cycle life
- Carbon footprint — total CO2e per kWh, assigned carbon footprint class
- Recycled content — percentage of recycled cobalt, lithium, nickel, and lead
- Supply chain due diligence — confirmation of responsible sourcing
- Collection & recycling — end-of-life handling instructions, recycling efficiency targets
- Safety information — hazard classifications, handling instructions
- Unique identifier — GS1 Digital Link URL with QR code
Carbon footprint class is new
Starting February 2027, batteries must declare their carbon footprint per kWh and be assigned a carbon footprint performance class (A–E). This requires lifecycle assessment data that many manufacturers don't currently collect. Start working with your suppliers now.Who is affected?
| Affected? | Must create DPP? | |
|---|---|---|
| Battery manufacturers | Yes | Yes — primary responsibility |
| EV / e-bike brands | Yes | Yes — for battery in final product |
| Power tool brands | If battery > 2 kWh | Depends on battery capacity |
| Energy storage companies | Yes | Yes — for each battery model |
| Battery importers | Yes | Yes — responsible as market placer |
Key dates and milestones
June 2023
Regulation published
Regulation (EU) 2023/1542 published in the Official Journal.
August 2024
Due diligence obligations begin
Supply chain due diligence requirements become applicable.
February 2025
Carbon footprint declaration required
EV and industrial batteries must declare carbon footprint.
August 2025
Carbon footprint class labels
Batteries must display carbon footprint performance class (A–E).
February 2027
Digital Product Passport mandatory
All covered batteries must carry a DPP with QR code. Full compliance required.
2031
Recycled content minimums enforced
Mandatory minimum recycled content percentages for cobalt, lithium, nickel, lead.
How to prepare: a practical checklist
If you sell batteries or battery-containing products in the EU, here's what to do now:
- Map your battery supply chain — Identify every battery model in your product range. Know who manufactures each cell.
- Request data from suppliers — You need chemistry breakdowns, carbon footprint data, and recycled content percentages. Start the conversation now — suppliers often need months to compile this.
- Calculate carbon footprint — If your supplier can't provide lifecycle assessment data, you may need to engage a third-party assessor.
- Choose a DPP platform — You need a system that generates QR codes with GS1 Digital Link support, hosts passport pages, and lets you update data without reprinting labels.
- Generate pilot passports — Create DPPs for your top-selling battery products first. Identify data gaps before the deadline.
- Integrate into production — Plan how QR codes will be printed on batteries and packaging. Test scanning with different devices.
Start with what you have
You don't need perfect data to start. Create a draft passport with available information, then fill gaps over time. The passport URL stays the same — you can update the data without changing the QR code.Penalties for non-compliance
The EU Battery Regulation includes enforcement mechanisms at the member state level. Non-compliant batteries can be:
- Blocked at customs — border authorities can scan QR codes and verify DPP data
- Recalled from market — market surveillance authorities can order product withdrawals
- Subject to fines — penalties vary by member state but can be significant
The regulation also introduces a Battery Pass consortium concept, where industry participants share standardized data formats. Being part of this ecosystem early demonstrates good faith to regulators.