EU Battery Passport 2027: Who Needs One? A Guide for Manufacturers
Article summary: From 18 February 2027, the EU Battery Regulation requires a Battery Passport for every electric vehicle (EV) battery, every light means of transport (LMT) battery, and every industrial battery with a capacity greater than 2 kWh placed on the EU market or put into service. This affects organizations across automotive, micromobility, material handling, industrial equipment, agriculture and potentially marine applications. This guide explains who is affected, what information companies need to prepare, what to look for in a Digital Product Passport solution, and how Battery Passports can become infrastructure for automation, circularity and new digital services, not just regulatory compliance.
Electrification is transforming far more than passenger cars. Other means of transport, such as electric bicycles and scooters, are reshaping urban mobility, while warehouses increasingly rely on battery-powered forklifts, automated guided vehicles and autonomous mobile robots. Construction and agricultural equipment is also becoming electrified, and the transition is extending onto the water: marine manufacturers are developing electric and hybrid vessels, including yachts and other watercraft equipped with high-capacity battery systems.
Behind these developments sits an increasingly important compliance question: Which batteries require an EU Battery Passport?
Under Article 77 of the EU Battery Regulation (Regulation (EU) 2023/1542), from 18 February 2027, every electric vehicle (EV) battery, every light means of transport (LMT) battery, and every industrial battery with a capacity greater than 2 kWh placed on the EU market or put into service must have a digital battery passport.
Importantly, the 2 kWh threshold applies specifically to industrial batteries. EV and LMT batteries are separately covered categories. For vehicle and equipment manufacturers, battery producers, importers and technology providers, this makes the Battery Passport an increasingly important component of bringing electrified products to the European market.
But compliance is only part of the opportunity. Implemented properly, a Digital Product Passport solution can connect regulatory information with ERP, PLM, supply-chain and battery-management data, automate information exchange, support repair and second-life applications, and create new digital services throughout the battery lifecycle.
Here are seven things manufacturers and other economic operators should understand as they prepare for Battery Passports.
1. Which Batteries Need A Battery Passport from 2027?
Here are the categories that extend Battery Passport requirements across a much wider mobility and industrial ecosystem than passenger EVs alone, as defined in the EU Battery Regulation.
Electric vehicle batteries
Automotive OEMs are perhaps the most visible organizations affected.
Battery-electric passenger vehicles, commercial vehicles and other vehicles whose traction batteries fall within the Regulation's EV-battery definition will need to be supported by Battery Passport infrastructure.
For automotive OEMs and battery manufacturers, this creates a significant data-management challenge.
Battery information can originate across:
cell and material suppliers;
battery pack manufacturing;
quality and compliance systems;
vehicle manufacturing;
ERP and PLM systems;
battery management systems;
telematics platforms;
maintenance and repair systems; and
downstream recycling and second-life operators.
The Battery Passport therefore cannot simply be treated as a static webpage connected to a QR code. It needs reliable, structured and maintainable data behind it.
The Battery Regulation sets out Battery Passport information requirements covering areas such as battery identification, composition, performance and durability, carbon-footprint information where applicable, and lifecycle-related data.
Light means of transport (LMT) batteries
The EU Battery Regulation defines an LMT battery as a sealed battery weighing 25 kg or less, specifically designed to provide traction power for wheeled vehicles that can be powered by an electric motor alone or by a combination of motor and human power, and which is not classified as an EV battery.
Depending on the regulatory classification, relevant applications can include:
e-bikes;
cargo e-bikes;
electric scooters; and
certain electric mopeds and other category-L vehicles.
For micromobility manufacturers, the compliance challenge is particularly connected to the supply chain. Cells, battery packs, battery management systems and finished products may come from several suppliers across multiple jurisdictions.
Yet products placed on the EU market still need to satisfy the applicable EU requirements.
LMT OEMs should therefore establish early who owns the necessary battery data, where it originates, how it is exchanged and how its integrity can be demonstrated.
Industrial batteries greater than 2 kWh
The third category expands the Battery Passport conversation beyond conventional road vehicles. Industrial batteries with a capacity greater than 2 kWh are also covered by the Battery Passport requirement.
Depending on regulatory classification, this can make Battery Passports relevant across applications such as:
Material handling and logistics: forklifts, warehouse vehicles, automated guided vehicles (AGVs) and autonomous mobile robots (AMRs).
Construction and heavy equipment: electrified excavators, loaders, lifting equipment and other off-road machinery.
Agriculture: electric tractors and other battery-powered agricultural machinery.
Marine and watercraft: certain electric and hybrid propulsion applications where the relevant battery meets the industrial-battery definition.
Special-purpose equipment: battery-powered mining, airport, municipal and other specialist machinery.
This is why Battery Passport readiness is not simply an automotive compliance issue. It is becoming an industrial digitalization issue. Manufacturers should nevertheless assess the precise classification of their batteries against Regulation (EU) 2023/1542 rather than assuming that a particular type of equipment automatically falls into scope.
2. Why Should Manufacturers Prepare for the Battery Passport Deadline Now?
Because Battery Passport compliance is fundamentally a data and integration challenge, and the necessary information can be distributed across many suppliers, systems and lifecycle partners. February 2027 can appear distant until organizations begin mapping the data required to create passports at scale.
An OEM may hold product information in PLM. Procurement and supplier information may sit in ERP or SCM systems. Performance and state-of-health information may come from the BMS or telematics platform. Sustainability information can originate with cell manufacturers and upstream suppliers. Repair, remanufacturing and recycling information may only emerge later in the lifecycle.
Companies therefore need to answer several practical questions:
Which of our batteries are subject to the Battery Passport requirement?
What data is required for each affected battery?
Where does that information currently reside?
Which suppliers and partners need to provide it?
How will its authenticity and integrity be established?
Who is permitted to access which information?
How will passports be created, updated and managed at scale?
How will our DPP solution connect to existing enterprise systems?
Battery Passport information is subject to different access levels. Some information is intended for the general public, while other information can be restricted to authorities, notified bodies or actors with a legitimate interest, including parties involved in repair, remanufacturing, second-life applications and recycling. A PDF or basic QR-code landing page cannot solve this governance and integration challenge on its own.
3. Why Should Companies Prepare for Digital Product Passports Across Batteries and Other Product Categories?
The Battery Passport is part of a much broader EU transition toward Digital Product Passports (DPPs) as infrastructure for product compliance, sustainability and circularity.
The EU's Ecodesign for Sustainable Products Regulation (ESPR) entered into force on 18 July 2024. It establishes a framework for ecodesign requirements covering virtually all categories of physical products, subject to specified exclusions and future product-specific requirements.
The European Commission describes the DPP as a “digital identity card for products, components, and materials.” You can find this description on the Commission's ESPR overview. This definition is important because it captures what a DPP is intended to become. It is not simply another regulatory document.
According to the European Commission, a DPP can provide structured information relating to areas such as:
technical performance;
materials and their origins;
sustainability characteristics;
repair activities;
recycling capabilities; and
lifecycle environmental impacts.
For more on why early DPP preparation matters, see Spherity's article on 5 reasons companies need a Digital Product Passport solution today.
4. What Does the EU DPP Registry Mean for Manufacturers?
It reinforces the need for interoperable Digital Product Passport software that can work within a decentralized European DPP ecosystem. The European Commission describes the DPP Registry as the indexing service for Digital Product Passports of products placed on the EU market.
The Registry is designed to store identifiers, registration data and high-level metadata rather than acting as one centralized database containing every piece of product information. According to the Commission's DPP Registry information, detailed product data remains under the responsibility of economic operators, which may host information themselves or use Digital Product Passport providers.
The emerging model therefore requires companies to think beyond simply “uploading data to the EU.” Organizations need DPP infrastructure capable of exchanging information across enterprise systems, suppliers, authorities, customers and other authorized ecosystem participants.
5. What Should Each Part of the Battery Ecosystem Prepare For?
Battery Passport compliance will affect organizations differently depending on their role in the value chain.
Vehicle and equipment OEMs
OEMs should focus on battery classification, product-level data mapping and the integration of Battery Passport processes into existing manufacturing and lifecycle systems. The goal should be to make passport creation part of normal product operations—not a parallel manual compliance workflow.
Battery pack producers and cell manufacturers
Battery manufacturers will increasingly be asked to supply structured information downstream. For them, data quality, interoperability and verifiability can become competitive capabilities. OEM customers will need accurate information to populate their Battery Passports, making efficient digital data exchange increasingly important to supplier relationships.
Importers and EU Authorized Representatives
Global supply chains do not remove obligations associated with placing products on the EU market. Importers and other responsible economic operators need processes for obtaining the necessary information from manufacturers and suppliers outside Europe and ensuring that required product information is available in the appropriate form.
The applicable obligations should always be assessed against the roles and responsibilities defined in the EU Battery Regulation.
Battery remanufacturers, refurbishers and repairers
Battery Passport data can become an operational resource for circularity. The Battery Regulation anticipates access to relevant information for actors with a legitimate interest, including organizations involved in dismantling, repair, remanufacturing, second-life applications and recycling. Better lifecycle information can help these organizations make faster and more informed decisions about batteries entering their processes.
BMS, telematics and enterprise software providers
For software providers and system integrators, the opportunity lies in connecting operational data with the passport. Battery lifecycle information becomes significantly more useful when it can move securely between BMS, ERP, PLM, SCM, ESG and DPP environments instead of being manually copied between disconnected systems.
6. What Should Companies Look For In A Digital Product Passport Solution?
Effective Digital Product Passport software should combine compliance functionality with interoperability, verifiable data, access control, enterprise integration and lifecycle management.
A DPP should not become another data silo. Imagine an OEM producing thousands of battery-powered machines. If its DPP solution is disconnected from existing systems, every new passport and compliance update creates additional administrative work.
With an API-connected Digital Product Passport solution, information can instead flow from the systems where it already exists.
For example:
ERP can provide manufacturing, procurement and supplier information.
PLM can provide technical product information.
ESG systems can provide sustainability information.
BMS and telematics platforms can provide permitted lifecycle and performance information.
Service platforms can contribute maintenance and repair events.
DPP software can structure, manage and provide appropriate access to the resulting information.
When comparing Digital Product Passport providers, organizations should therefore look for capabilities including:
Regulatory data templates that help structure required information.
Static and dynamic lifecycle data support rather than static documents alone.
Verifiable and standardized information to strengthen data trust.
Granular access control for public, restricted and commercially sensitive information.
API connectivity with ERP, PLM, CRM, BMS and other enterprise systems.
Interoperable data exchange across supply-chain and industry ecosystems.
Scalable passport creation and management for large product volumes.
QR-accessible stakeholder experiences for customers, service providers and other authorized actors.
For a more detailed framework, read Spherity's guide: Choosing the right Digital Product Passport software: Why VERA by Spherity is the solution for compliance and business value.
7. How Can Battery Passports Create Business Value Beyond Compliance?
A Battery Passport can turn mandatory product data into reusable digital infrastructure for automation, service, traceability and circular business models.
This may ultimately be the most important reason not to treat the Battery Passport as another compliance document. Once a physical battery or product has a persistent digital identity connected to trustworthy lifecycle information, businesses can build processes and services around that information.
7 practical opportunities created by Battery Passport data
1. Automate compliance workflows
Instead of manually gathering the same information for different regulatory processes, connected systems can make approved data available to the passport automatically.
2. Improve supply-chain traceability
Structured product information can make it easier to understand where relevant battery data originates and how information moves through the value chain.
3. Support maintenance and repair
Battery and product information can give authorized service providers better context for diagnostics, maintenance and repair decisions.
4. Enable remanufacturing and second-life applications
Lifecycle and performance information can help organizations determine whether batteries should be repaired, reused, repurposed, remanufactured or recycled.
5. Improve recycling processes
Reliable information about battery composition and other relevant characteristics can support downstream recovery and recycling activities.
6. Strengthen customer experiences
A QR-accessible Digital Product Passport can provide customers with trusted product information through a digital interface connected directly to the physical product.
7. Create new data-driven services
Verified product identity and lifecycle information can support future applications around service history, residual value, warranties, circularity and other digital product services.
Prepare for Battery Passports with Spherity’s Digital Product Passport Platform
VERA is Spherity’s production-ready Digital Product Passport solution for creating, managing and integrating trusted product and battery data at scale. It combines regulatory templates, static and dynamic data management, verifiable information, granular access control, QR-based experiences and API integration with various systems. Using technologies including W3C Decentralized Identifiers and Verifiable Credentials, VERA supports secure, machine-readable and interoperable data exchange across the product lifecycle, helping organizations move from DPP pilots to scalable compliance and business integration.
Want to find out whether your batteries, vehicles or equipment are affected by the 2027 Battery Passport requirements?
Contact Spherity to discuss your use case with our Battery Passport experts. We can help you assess your requirements, identify your Battery Passport data and integration needs, and demonstrate how our Battery Passport solution, VERA, can turn regulatory compliance into scalable digital infrastructure.
