The battery passport is due 18 February 2027, and it is not ESPR

Almost every digital product passport (DPP) date in circulation is indicative. This one is not.

From 18 February 2027, an electric vehicle battery, a light means of transport battery, or an industrial battery above 2 kWh cannot be placed on the EU market without a battery passport. The date is fixed in law and it is the first hard DPP deadline anyone faces.

It sits under a different regulation, and that is the trap

The battery passport comes from Regulation (EU) 2023/1542, the Battery Regulation. It is not part of the Ecodesign for Sustainable Products Regulation, even though the mechanism is the same idea.

This catches companies out in a specific way. A team tracking ESPR delegated acts, waiting for their category to be scheduled, can be entirely on top of that process and still miss a binding obligation that arrives on a different legal track. If any part of your product contains a battery in scope, or if you sell into a supply chain that ends in one, the 2027 date is yours regardless of what the ESPR working plan says about your sector.

Who is covered

The obligation applies to electric vehicle batteries, light means of transport batteries, which covers e-bikes and scooters, and industrial batteries with a capacity above 2 kWh. Portable consumer batteries are not in this first wave.

The responsibility sits with the economic operator placing the battery on the EU market. In practice that means the battery manufacturer, or the importer bringing cells or packs into the EU, and it flows up the chain to anyone integrating those batteries into a finished product.

What comes immediately after

The February 2027 date is not the end of the sequence, and the dates behind it are close enough that they belong in the same plan.

18 August 2027: the carbon footprint declaration for electric vehicle batteries, and the battery due-diligence obligations, postponed from 18 August 2025 by Regulation (EU) 2025/1561.

18 February 2028: recycled content requirements for cobalt, lithium, nickel and lead.

Both depend on data you collect from suppliers, not data you generate. A company that builds its passport process for the 2027 deadline alone will be repeating the supplier exercise twice more inside twelve months.

Why the deadline is closer than it looks

The passport is a record of origin and materials, and that record has to be assembled from suppliers across a chain that frequently reaches outside the EU. Cell chemistry, cathode material provenance, recycled content percentages and manufacturing facility identification are not fields you can fill from your own ERP.

Working backward from 18 February 2027, a company that has not started collecting supplier evidence is already inside the window where the answer depends on how fast third parties reply. That is the part nobody controls.

Where to start on batteries

Identify every battery in scope across your product lines, including batteries embedded in finished goods you sell. Ask each battery supplier what passport data they will provide and in what format, in writing, because the answer determines whether you are integrating a feed or rebuilding a record by hand. Then decide who inside your company signs off that the data is correct, since accuracy is a liability question rather than a filing one, as set out in DPP penalties.

Sources

• Regulation (EU) 2023/1542 (Battery Regulation): battery passport mandatory 18 February 2027;
• carbon footprint declaration for EV batteries 18 August 2027; recycled content requirements
• 18 February 2028.
• Regulation (EU) 2025/1561 (Omnibus IV): battery due-diligence obligations postponed from
• 18 August 2025 to 18 August 2027.