As the 18 February 2027 deadline for mandatory Digital Battery Passports approaches, companies importing batteries into the European Union need to consider a new part of the compliance process: customs controls linked to the Digital Product Passport (DPP) system.
Under Regulation (EU) 2023/1542, from 18 February 2027 every electric vehicle (EV) battery, light means of transport (LMT) battery and industrial battery with a capacity greater than 2 kWh placed on the EU market or put into service must have a Battery Passport. The regulation also requires the economic operator placing the battery on the market or putting it into service to upload its unique identifier to the EU DPP Registry.
The practical question is no longer simply whether an imported battery has a Battery Passport. Importers need to understand how the passport, its registration information and customs processes will work together.
In our previous article, we looked into making battery passports audit ready for battery manufacturers. Today, we’ll discuss the connection between Battery Passport registration, customs declarations and the release of goods for free circulation for importers.
How Will Customs Checks Work?
The EU's DPP framework establishes a central registry that acts as an indexing service for Digital Product Passports. It stores unique identifiers and, for products intended for release for free circulation, the relevant commodity code. The detailed product information remains in the decentralised Digital Product Passport rather than being stored entirely in the central registry.
This distinction is important for importers.
When a product covered by the applicable DPP requirements is intended to be released for free circulation, the person placing it under that customs procedure must provide or make available the product's unique registration identifier to customs authorities.
Customs authorities can then verify that the unique registration identifier and the relevant commodity code correspond to the information held in the DPP Registry. Under the ESPR, this verification is intended to take place electronically and automatically once the registry is interconnected with the EU Customs Single Window Certificates Exchange System, known as EU CSW-CERTEX.
The Commission's current DPP information confirms that the registry is designed to support customs authorities by allowing them to verify whether an imported product has a valid registered DPP and whether the relevant commodity code has been provided.
This does not mean that a successful customs release automatically proves that the battery complies with all applicable EU legislation. The ESPR explicitly states that release for free circulation is not, by itself, proof of compliance.
What Does This Mean For Battery Importers?
The first step is understanding who carries responsibility for the Battery Passport.
Under the Batteries Regulation, the economic operator placing the battery on the market is responsible for ensuring that the information in its Battery Passport is accurate, complete and up to date. The operator can authorise another operator to act on its behalf.
For an importer bringing batteries from outside the EU, this means Battery Passport responsibilities need to be incorporated into the import and compliance workflow rather than treated as a separate digital exercise.
Importers should establish early on:
- which batteries entering the EU are within scope;
- who is responsible for creating or maintaining the Battery Passport;
- how the battery's unique identifier is generated and managed;
- how the relevant commodity code is identified;
- who will provide the registration information required for customs;
- and how the importer will verify that the information is available before the goods arrive.
The exact customs process will depend on the applicable DPP legislation and the operational rollout of the registry and its customs interconnection. Importers should therefore monitor the European Commission's implementing guidance as the system develops.
Get The Product And Commodity Data Right
One of the most important preparation steps is ensuring that the information connecting the physical battery, the Battery Passport and the customs declaration is consistent.
The DPP framework relies on persistent unique product identifiers and requires relevant commodity codes to be stored in the registry for products intended for release for free circulation.
This creates a practical data chain:
Physical battery → Unique identifier → Digital Battery Passport → DPP Registry → Commodity code → Customs declaration
If these elements do not correspond, the importer may face difficulties during the customs process.
For this reason, importers should review how product identifiers and commodity codes are currently managed across ERP, customs, logistics and product information systems. Manual processes that rely on copying identifiers between systems can create avoidable risks.
This is also where interoperability becomes important. The Batteries Regulation requires Battery Passport information to be based on open standards and to use an interoperable, machine-readable and structured format that can be transferred through an open interoperable data exchange network.
Prepare Your Data Before The Shipment Arrives
Importers should avoid treating Battery Passport registration as something to address at the point of customs clearance.
A better approach is to establish a pre-import verification process.
Before a shipment arrives, the importer should be able to confirm that the relevant Battery Passport exists, that the battery's unique identifier is correctly associated with it, and that the information required for registration and customs is consistent with the shipment documentation.
This is particularly important for organisations importing large volumes or multiple battery models. A process that works for a handful of shipments may become difficult to manage when thousands of batteries and multiple suppliers are involved.
The European Commission's DPP Registry is intended to support registration and management of DPPs, and its current implementation information provides tools for economic operators to enrol organisations and register DPPs.
Importers should therefore begin familiarising themselves with the registry environment and determine how their internal systems and suppliers will interact with it.
Work With Overseas Suppliers Early
For many importers, the biggest challenge may sit outside the EU.
The importer may not manufacture the battery or control the systems in which its underlying data is generated. It may depend on a manufacturer or supplier in another country to provide the information required for the Battery Passport.
This makes supplier data management an important part of customs readiness.
Importers should establish clear responsibilities with suppliers covering:
- Battery identification
- Required Battery Passport Information
- Data Updates
- Supporting Documentation
- Registration Responsibilities and
- Change Management
The earlier these responsibilities are agreed, the easier it becomes to identify missing information before a shipment is prepared.
It is also worth checking whether suppliers can provide data in structured and interoperable formats rather than relying exclusively on spreadsheets or PDF documents. A structured approach can make it considerably easier to connect supplier information with internal systems and the Battery Passport.
Keep Customs And Compliance Teams Connected
Battery Passport implementation should not sit exclusively with sustainability, product compliance or IT teams.
Customs teams will have an important role because the DPP framework specifically connects product registration with the release of covered imports for free circulation.
This means organisations should bring together their customs, compliance, supply chain, IT and product data teams when designing their implementation process.
The objective should be to create a workflow in which customs information and Battery Passport information reinforce each other rather than being managed as separate datasets.
For example, the team responsible for customs classification should understand which commodity code is associated with the registered product, while the team responsible for Battery Passport data should understand how that information is used during import processes.
What Should Importers Do Now?
The regulatory framework is still being operationalised, so importers should avoid building processes around assumptions about technical details that have not yet been finalised.
There are, however, several practical steps that can begin now.
First, map your imported battery portfolio and identify which products will fall within the Battery Passport requirements.
Second, identify the data owner for every critical identifier and data field. This should include the battery manufacturer, importer and any authorised representative or service provider involved in the process.
Third, review your customs data flows. Determine where commodity codes, product identifiers and shipment information are created and how they move between systems.
Finally, test your supplier data process. Ask whether you could receive a shipment from an overseas supplier and reliably connect every relevant battery to the correct Battery Passport and registration information before customs clearance.
These steps can expose data gaps while there is still time to address them.
How BASE Can Help
The BASE project is developing and validating Digital Battery Passport solutions designed to support trusted, interoperable and lifecycle-oriented battery information.
The connection between Battery Passports, product identifiers, data standards and wider digital infrastructure is particularly relevant as the EU moves towards greater integration between product information and customs processes. BASE's work contributes to this broader ecosystem by exploring practical approaches for managing and exchanging Battery Passport data across the battery value chain.
For organisations preparing for implementation, BASE's resources on Battery Passport Data Attribute Longlist v1.3, DIN DKE SPEC 99100 Explained: The Technical Standard Behind Battery Passport Data Fields and JTC 24 Standards Explained For Battery Passport Teams: What They Mean In Practice provide useful background on the data and standards that underpin interoperable Battery Passport systems.
Preparing For Battery Passport Customs Checks
For importers, Battery Passport compliance will increasingly become connected to the wider process of placing batteries on the EU market.
The key preparation task is to establish a reliable connection between the physical battery, its unique identifier, the Battery Passport, registry information and customs data.
Importers that begin mapping these connections now will be in a stronger position to manage the transition when the relevant systems and processes become operational.
The objective is straightforward: when a battery reaches the EU border, the information needed to identify and verify it should already be accurate, consistent and ready to exchange.
The BASE project has received funding from the Horizon Europe Framework Programme (HORIZON) Research and Innovation Actions under grant agreement No. 101157200.
References & Resources
Regulation (EU) 2023/1542 concerning batteries and waste batteries: https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1779247713965&uri=CELEX:32023R1542
Regulation (EU) 2024/1781, Ecodesign for Sustainable Products Regulation, EUR-Lex: https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng
European Commission - The DPP Registry: https://single-market-economy.ec.europa.eu/single-market/digital-product-passport/dpp-registry_en
European Commission - Digital Product Passport FAQs: https://single-market-economy.ec.europa.eu/single-market/digital-product-passport/explore-our-faqs_en
European Commission - Digital Product Passport Standards: https://single-market-economy.ec.europa.eu/single-market/goods/european-standards/harmonised-standards/digital-product-passport-dpp_en
European Commission - The EU Single Window Environment for Customs: https://taxation-customs.ec.europa.eu/customs/customs-controls/eu-single-window-environment-customs_en