The countdown to the EU Digital Battery Passport is entering its final stages. While 18 February 2027 remains the legally binding compliance date for electric vehicle (EV) batteries, light means of transport (LMT) batteries and industrial batteries with a capacity above 2 kWh, the wider regulatory and technical framework is still taking shape.
Over the next 8 months, businesses across the battery value chain will see additional delegated acts, implementing acts, harmonised standards and guidance documents published by the European Commission. These measures will provide the practical rules needed to support the Battery Passport ecosystem and ensure consistent implementation across the European Union.
For battery manufacturers, OEMs, material suppliers, recyclers and Digital Battery Passport solution providers, understanding this evolving timeline is just as important as understanding the regulation itself. Organisations that begin preparing now will be better positioned to adapt as the remaining technical details are confirmed.
This article explains what still needs to be finalised before the Battery Passport goes live, outlines the key milestones expected between 2026 and beyond, and discusses what companies should prioritise today.
Understanding the Role of Delegated Acts Behind Digital Battery Passports
The Digital Battery Passport is established under Regulation (EU) 2023/1542, commonly referred to as the EU Battery Regulation (EUBR). While the regulation sets out the legal obligation to provide a Digital Battery Passport, it intentionally leaves many technical and operational details to delegated and implementing acts.
These secondary legal measures explain how the legislation will work in practice. They define the information that must be included in each Battery Passport, establish technical requirements for exchanging data, specify interoperability rules between different systems and clarify governance arrangements across the battery value chain. Together, they transform broad legal requirements into practical obligations that organisations can implement.
As a result, compliance is not determined by the Battery Regulation alone. Companies must also follow the growing collection of supporting legislation and technical standards that continue to emerge.
Why 2026 is an Important Year for Digital Battery Passport
Although Battery Passports do not become mandatory until February 2027, 2026 represents the most significant preparation period for the industry.
Many of the technical foundations that support Digital Product Passports are expected to mature during this year. Rather than introducing new legal obligations for every manufacturer immediately, 2026 focuses on building the infrastructure that will make Digital Battery Passports work consistently across Europe.
Several developments deserve particular attention.
Harmonised Standards Continue to Mature
One of the biggest milestones is the ongoing development of harmonised Digital Product Passport standards by CEN and CENELEC through Joint Technical Committee 24 (JTC 24).
These standards establish the common technical architecture that Digital Product Passports will rely upon. They address digital identifiers, QR codes, data carriers, information architecture, APIs, cybersecurity and interoperability between different digital systems. Having a harmonised framework allows manufacturers, software providers and regulators to exchange information using consistent technical specifications.
Although some original publication targets have shifted, this should not be viewed as unusual. European standards often undergo several rounds of technical review before publication, particularly when they introduce new digital infrastructure that must operate across multiple industries.
For organisations developing Digital Battery Passport solutions today, flexibility remains essential. Systems designed around modular architectures will be much easier to adapt as final standards become available.
Battery Due Diligence Guidance
Another important milestone arrives in July 2026, when the European Commission is expected to publish guidance supporting the Battery Regulation's due diligence requirements for critical raw materials.
These guidelines will help organisations understand expectations surrounding responsible sourcing, supplier engagement and risk management for materials such as lithium, cobalt, nickel and natural graphite. Although the mandatory due diligence obligations apply later, the guidance will provide valuable direction for companies that are already strengthening their supply chain governance.
Expanded Battery Labelling Requirements
Battery labelling requirements will also expand during 2026.
Manufacturers will need to provide additional information relating to battery characteristics, manufacturer identification and selected sustainability information. While these labels are not the Digital Battery Passport itself, they represent an important step towards greater product transparency and encourage businesses to strengthen their data collection processes ahead of full implementation.
Supporting Digital Infrastructure
The wider Digital Battery Passport ecosystem also depends on infrastructure that extends beyond legislation.
Work continues on elements such as the European Digital Product Passport registry, trusted identification mechanisms, authentication procedures, interoperability services and governance arrangements for digital service providers. These components will allow Battery Passport information to be exchanged securely and consistently across different organisations and national borders.
Because several of these systems are still under development, organisations should expect further clarification throughout 2026 rather than a single announcement that completes the framework.
What Still Needs to be Finalised Before February 2027?
Although the mandatory implementation date is fixed, several supporting elements remain under development.
Final Harmonised Standards
The harmonised standards being developed through JTC 24 remain one of the most closely watched areas.
Once completed, these standards will establish common technical specifications for Digital Product Passports throughout Europe. They are expected to improve interoperability between software platforms, reduce implementation uncertainty and support consistent data exchange across complex international supply chains.
Until publication is complete, businesses should continue designing flexible systems that can accommodate updates without requiring major redevelopment.
Carbon Footprint Methodologies
The Battery Regulation introduces mandatory carbon footprint declarations for certain battery categories. However, the detailed methodologies that determine how these calculations should be performed continue to evolve through the implementation of measures.
These methodologies will influence how manufacturers calculate emissions, verify reported values and ensure consistency between different organisations. Common calculation rules are essential if carbon footprint information is to remain reliable and comparable throughout the European market.
Governance of Digital Service Providers
Another area still being refined concerns the governance of organisations that will support the Digital Battery Passport ecosystem.
European institutions continue to develop trust frameworks, authentication procedures, identity management arrangements and interoperability governance. These measures will help define how different stakeholders interact while maintaining secure and reliable access to Battery Passport information.
As the ecosystem grows, clear governance will become increasingly important for ensuring confidence in shared digital data.
Digital Product Passport Infrastructure
Questions also remain regarding the broader Digital Product Passport infrastructure that will support Battery Passports.
European initiatives continue to examine how information should be exchanged across borders, how digital identities should be managed and how interoperability can be maintained between different systems.
Rather than relying on a single technology platform, the emerging approach is expected to prioritise interoperability, allowing different solutions to communicate through shared technical standards and common governance principles.
For businesses investing in Digital Battery Passport solutions today, this reinforces the importance of open architectures and standards-based development rather than proprietary approaches that may prove difficult to integrate in future.
Practical Data Exchange Across The Value Chain
One of the biggest implementation challenges extends beyond legislation.
Collecting reliable information across complex international supply chains remains a significant operational task.
Battery manufacturers may require information from raw material suppliers, cell manufacturers, module producers, pack assemblers, logistics providers, repair organisations and recyclers before a complete Digital Battery Passport can be established.
Maintaining that information throughout the battery's operational life introduces additional complexity.
Repairs, software updates, changes in ownership, state-of-health assessments, second-life applications and end-of-life treatment all generate valuable lifecycle information that may need to be reflected within the passport.
Developing practical and scalable approaches for managing this data remains one of the industry's most important priorities.
February 2027: Battery Passports Become Mandatory
The most significant milestone remains 18 February 2027, when Digital Battery Passports become mandatory under the EU Battery Regulation.
From this date, qualifying batteries placed on the European market must include a QR code that provides access to a Digital Battery Passport.
The requirement applies to:
- Electric vehicle batteries
- Industrial batteries with a capacity above 2 kWh
- Light means of transport batteries
Each passport will provide access to information covering battery identification, technical characteristics, sustainability performance, lifecycle data, circularity information and, where applicable, responsible sourcing details.
The Battery Passport represents the first mandatory Digital Product Passport introduced through EU legislation and will serve as an important reference point for future product categories.
What Happens After 2027?
Battery Passports mark the beginning of Europe's wider Digital Product Passport rollout rather than its conclusion.
Following batteries, additional product groups covered by the Ecodesign for Sustainable Products Regulation (ESPR) are expected to receive their own delegated acts over the coming years. Current priorities include iron and steel, textiles, tyres, aluminium, furniture, selected energy-related products and, later, consumer electronics such as mobile phones and tablets.
The ESPR Working Plan 2025-2030, adopted by the European Commission in April 2025, outlines the expected sequence for these future product categories. While individual timelines may evolve, the overall direction is clear. Product transparency, lifecycle traceability and digital product information will become increasingly common across European manufacturing.
The European Commission will also carry out a mid-term review of the Working Plan in 2028, providing an opportunity to assess implementation progress and adjust future priorities where necessary.
Why Waiting Could Be Costly
Many organisations are understandably waiting for every delegated act, implementing measure, and technical standard to be published before investing in Digital Battery Passport systems.
However, this approach carries significant risk.
Preparing for Digital Battery Passports involves much more than meeting a legal deadline. Companies need time to engage suppliers, improve traceability, identify missing information, integrate data across multiple business systems and establish internal governance procedures. QR code implementation, data quality assurance and employee training also require careful planning, particularly within large international organisations.
Even if certain supporting measures are delayed, early preparation is unlikely to be wasted. Better data quality, stronger supplier relationships and improved traceability provide immediate operational benefits while reducing the risk of last-minute compliance challenges.
How BASE Supports Battery Passport Readiness
The BASE Project is helping prepare the industry for this transition by developing and validating a trusted, interoperable Digital Battery Passport framework that supports the objectives of the EU Battery Regulation.
Working alongside partners from across the battery value chain, BASE is addressing many of the practical challenges that organisations face in implementation approaches. These include secure data sharing, interoperability, lifecycle traceability, sustainability assessment, ESG indicators and circular economy principles. By testing Digital Battery Passport solutions in real-world environments, the project helps generate practical knowledge that can support businesses as delegated acts, technical standards and governance arrangements continue to mature.
Looking Beyond the Timeline
The Battery Passport delegated acts timeline demonstrates that implementation is not defined by a single compliance date. Instead, it is a gradual process involving legislation, technical standards, digital infrastructure and industry collaboration.
While several supporting measures still require finalisation before February 2027, the overall direction is already well established. Organisations should not interpret ongoing regulatory development as a reason to delay preparation. Rather, it provides an opportunity to build flexible systems, strengthen data management practices and improve supply chain transparency before mandatory compliance begins.
As Europe moves towards a more transparent and circular battery economy, businesses that invest in readiness today will be better equipped to adapt to future regulatory developments and support the long-term goals of sustainability, traceability and responsible resource management.
The BASE project has received funding from the Horizon Europe Framework Programme (HORIZON) Research and Innovation Actions under grant agreement No. 101157200.
Reference
European Parliament and Council - Regulation (EU) 2023/1542 concerning batteries and waste batteries: https://eur-lex.europa.eu/eli/reg/2023/1542/oj
European Commission - Waste and Recycling: Batteries: https://environment.ec.europa.eu/topics/waste-and-recycling/batteries_en
European Commission - Implementing the Ecodesign for Sustainable Products Regulation: https://green-forum.ec.europa.eu/implementing-ecodesign-sustainable-products-regulation_en
European Commission - Digital Product Passport: https://cirpassproject.eu/digital-product-passport/
CEN-CENELEC – Digital Product Passport Standards (JTC 24): https://standards.cencenelec.eu/ords/f?p=205:7:::::FSP_ORG_ID:3342699&cs=152A83699C987EFA564209B7AC7311C86
European Commission - Raw materials, metals, minerals and forest-based industries: https://single-market-economy.ec.europa.eu/sectors/raw-materials_en