As Europe advances toward a climate-neutral circular economy, the EU is pushing one of the most transformative regulatory shifts in the battery industry.

At the centre of this change lies the Digital Battery Passport (DBP), the core feature of the EU Battery Regulation (Regulation EU 2023/1542).

This forward-thinking regulation lays the foundation for a smarter, greener, and more circular battery ecosystem by 2027, making sure that the batteries powering our transport, devices, and energy systems meet high sustainability, traceability, and performance standards.

In our previous blog, we explored how Digital Battery Passports set a new standard for transparency, going beyond traditional Digital Product Passports with smarter tech, stronger compliance, and deeper circular value. In this third instalment of the “Road to Circular Batteries” series, we turn our focus to the EU Battery Regulation & its 2027 deadline, who it impacts, and how the DBP is central to Europe’s push for a greener, more circular economy.

Understanding the EU Battery Regulation (EU 2023/1542)

Adopted in 2023, the EU Battery Regulation (EU 2023/1542) replaces the older Battery Directive 2006 with an updated framework, directly applicable across all EU Member States.

Unlike the 2006 directive, it takes a full-lifecycle approach, addressing sustainability, due diligence, supply chain transparency, and end-of-life recovery.

The regulation introduces mandatory requirements for Digital Battery Passports,  comprehensive, interoperable datasets that digitally trace a battery’s identity, materials, performance, and environmental footprint.

The DBP will become a legal requirement for key battery types placed on the EU market from February 2027.

Timeline to 2027: Key Implementation Milestones

The EU has outlined a clear, structured roadmap for a phased and practical implementation of the DBP system to ensure a smooth transition, leading up to the full DBP mandate in 2027:

With this timeline, manufacturers, supply chain partners, and regulatory bodies have the time to prepare, align data systems, test pilot programs, and adapt to the new digital traceability ecosystem.

Let’s dive deeper into the key milestones:

July 12, 2023 – EU Batteries Regulation Adopted

The European Parliament and Council formally adopted Regulation (EU) 2023/1542, establishing a new legal framework for sustainable battery design, labelling, data transparency, and recycling.

August 8, 2023 – Regulation Enters into Force

The regulation becomes law across all EU member states. From here, delegated and implemented acts begin to shape the structure of the Battery Passport and supporting infrastructure.

February 18, 2024 – Deadline: EV Battery Carbon Footprint Act

The European Commission must adopt a delegated act for calculating and verifying carbon footprints for EV batteries.

August 18, 2024 – Performance, Durability, and Health Data

Batteries over 2 kWh must include data on:

• Electrochemical performance
• Battery health
• Lifecycle expectations

This data must be embedded in Battery Management Systems (BMS).

February 18, 2025 – Industrial Battery Carbon Footprint Act

The Commission adopts a methodology for calculating the carbon footprint of industrial batteries.

August 18, 2025 – Reporting Data Format

Final date for the EU to publish implementing acts on:

• Data format
• Assessment procedures
• Waste battery handling protocols

August 18, 2026 – Labelling and Recycled Content Acts

All portable, LMT, and SLI batteries must be labelled with:

• Capacity
• Rechargeability
• Recycled content (if applicable)

The EU must define:

• Calculation methodology for recycled content
• Guidelines for accessing non-public Battery Passport data

February 18, 2027 – Mandatory Battery Passport

From this date, Digital Battery Passports are legally required for:

• Electric Vehicle (EV) Batteries
• Light Means of Transport (LMT) batteries
• Industrial batteries over 2 kWh
• Electric Vehicle (EV) batteries

Each Battery Passport must include:

• Battery identification data (serial number, manufacturer ID)
• Basic characteristics (type, chemistry, capacity, voltage)
• Origin of key raw materials
• Carbon footprint data from cradle to gate
• Durability, performance, and safety metrics
• Repairability and dismantlability information
• Recyclability rates and content of recycled materials
• Second-life application potential
• Environmental and social impact indicators

Beyond 2027: Long-Term Circular Goals

August 18, 2027 – 63% Waste Collection Target

Battery producers must meet a 63% collection target for portable batteries. Targets may evolve based on market trends and battery lifespan.

December 31, 2027 – Deposit Return System Feasibility

The EU will assess the feasibility of implementing deposit return systems for battery recycling.

August 18, 2028 – Recycled Content Reporting

EV and industrial batteries over 2 kWh must document the percentage of recycled cobalt, lead, lithium, or nickel.

December 31, 2030 – Future Assessments

The EU Commission will evaluate:

• Extension of carbon footprint rules to smaller batteries
• Potential phase-out of non-rechargeable batteries

June 30, 2031 – Full Battery Passport Evaluation

The EU will review the regulation’s performance and may introduce updates or amendments based on outcomes and new technologies.

New Developments: Extended Due Diligence Timeline

On 3 June 2025, the European Commission proposed extending the Due Diligence deadline from August 2025 to August 2027, to help Member States accredit oversight bodies and give economic operators more preparation time. Final guidance is expected by July 2026.

The substance of the obligations remains unchanged—only the timeline is adjusted.

What Still Applies:

• Risk-based due diligence aligned with OECD (Organisation for Economic Co-operation and Development) standards
• Chain of custody and traceability for cobalt, lithium, nickel, and natural graphite
• DBP requirement kicking in February 2027

What Companies Should Do Now:

• Study the OECD Due Diligence guidelines
• Map supply chains and assess risks
• Implement custody and traceability controls
• Conduct phased due diligence based on emerging risks

Use the extra time wisely! It’s not a delay but an opportunity to build strong, compliant systems.

How the DBP Connects with Broader EU Green Initiatives

The DBP is not just working alone, but it directly supports and aligns with Europe’s flagship sustainability frameworks:

EU Green Deal

The DBP supports the European Green Deal’s goal of making Europe the first climate-neutral continent by 2050 by:

• Promoting responsible sourcing and material efficiency
• Reducing GHG emissions in manufacturing and supply chains
• Encouraging recycling and reuse to cut down raw material imports

Circular Economy Action Plan

The Digital Battery Passport supports the Circular Economy Plan by:

• Enabling circular business models like battery leasing and second-life use
• Providing the data needed for eco-design and extended producer responsibility
• Improving resource recovery and waste reduction

Digital Product Passport (DPP) Initiative

The DBP is a sector-specific implementation of the broader Digital Product Passport envisioned in the EU's Sustainable Product Initiative (SPI). It serves as a blueprint for digital traceability and environmental transparency across other sectors like electronics, textiles, and construction.

Together, these initiatives form a cohesive policy ecosystem, integrating environmental responsibility, digital innovation, and economic resilience, with the DBP playing a vital operational role.

How DBP is setting a New Global Benchmark

The Digital Battery Passport goes far beyond typical product passports by incorporating real-time IoT data, blockchain-based integrity, and advanced lifecycle intelligence.

This digital tool is designed to encourage better decisions, unlock circular business value, and support compliance across a global supply chain.

Initiatives like the BASE Project are already laying the foundation for this future. BASE is pioneering transparent, science-based methodologies to calculate battery health, carbon footprints, and circularity metrics, creating standards that will make DBPs not only compliant but operationally useful for the entire ecosystem.

With harmonisation, data traceability, and actionable intelligence, BASE is helping to normalise DBPs and prepare industries for the 2027 mandate and beyond.

Driving Innovation, Standardisation, and Global Influence

The EU Battery Regulation is acting as both a compliance framework and driving innovation, and we can already see its impact in the industry:

• Encouraging the development of next-generation Battery Management System (BMS) and IoT devices to collect real-time battery data
• Stimulating software innovation for Distributed Ledger Technology (DLT) based platforms and Environmental, Social, and Governance (ESG) data analytics
• Promoting cross-sector collaboration between the automotive, electronics, and renewable energy sectors
• Setting global standards that other regions (e.g., North America, Asia) are beginning to explore and adopt

As digital infrastructure and sustainability expectations rise, the regulation is creating a level playing field and building trust across complex value chains. Digital Battery Passports help make smarter decisions across the battery lifecycle, reducing emissions. Promoting resource efficiency and enhancing the performance and safety of batteries powering the green transition. 

With coordinated action from manufacturers, policymakers, data experts, and projects like BASE, Europe is on track to lead the global shift toward a cleaner and more circular battery economy.

BASE is a 3-year-long project being under the call ”HORIZON-CL5-2023-D2-02-03: Creating a digital passport to track battery materials, optimise battery performance and life, validate recycling, and promote a new business model based on data sharing (Batt4EU Partnership).” This project has received funding from the Horizon Europe Framework Programme (HORIZON) Research and Innovation Actions under grant agreement No 101157200.

(Image Credit: Technovative Solutions Ltd)