The European Green Deal is reshaping how product lifecycle information is managed, verified, and shared across sectors. In this broader regulatory landscape, battery manufacturing has become a central test case for integrating digital traceability into product regulation due to batteries’ environmental intensity, strategic material requirements, and extensive downstream use.

Under recent EU regulations, the EU is effectively accelerating early adoption of Digital Product Passports (DPPs) for batteries and other critical products. The integration of digital traceability into regulatory requirements makes it clear that voluntary pilots and isolated initiatives will not be sufficient: companies must act now to be prepared for the mandatory frameworks taking effect in the years ahead.

The Digital Product Passport (DPP) is evolving into a mandatory compliance tool that will play a defining role in transparency, circularity, and sustainability reporting for complex products. The early implementation of digital reporting requirements for batteries provides a working example of how broader industry compliance will unfold across multiple product categories.

Regulatory Framework: From Batteries to Broader Products

Battery Regulation (EU 2023/1542): First Mandatory DPP Use Case

The EU Battery Regulation (EU 2023/1542) requires that Electric Vehicle (EV), Light Means of Transport (LMT), and industrial batteries above 2 kWh host a Digital Battery Passport (DBP) by 18 February 2027. The DBP must disclose structured data covering lifecycle carbon footprint, material composition, recyclability attributes, safety parameters, and supply chain due diligence. This requirement represents the first real-world application of the Digital Product Passport concept for a major industrial product sector.

Ecodesign for Sustainable Products Regulation (ESPR): Scaling DPPs Across the Economy

While the Battery Regulation targets batteries specifically, the newly adopted Ecodesign for Sustainable Products Regulation (ESPR) replaces the old Ecodesign directive and extends digital passport obligations to a vastly wider range of physical goods placed on the EU market. The ESPR aims to ensure products are durable, repairable, recyclable, and transparent about their sustainability attributes.

Under the ESPR framework, a Digital Product Passport will become a standard requirement for several product categories, enabling public authorities, economic operators, and consumers to access structured sustainability data. This means that on top of battery-specific requirements, companies supplying goods such as electronics, appliances, textiles, or construction products will eventually need to integrate DPPs with detailed lifecycle information.

Technical Data Requirements: Structured, Interoperable, Machine-Readable

Technical specifications for Digital Product Passports, including DBPs, are being developed in coordination with European standardisation bodies such as CEN and CENELEC under the ESPR and related mandates. These technical standards will define how a DPP’s data is structured, communicated, and made interoperable across platforms and borders.

For batteries under the Battery Regulation, Article 78 of the regulation’s technical annexes outlines essential requirements for DBP design and operation. Data must be interoperable with other product passport systems, machine-readable, and stored securely to protect privacy and commercial confidentiality.

Beyond Compliance: What DPP Data Looks Like in Practice

The Digital Product Passport for batteries will include data elements aligned not only with product regulation but also with wider sustainability reporting needs. Core elements include:

Lifecycle and environmental data:

• Cradle-to-gate carbon footprint values aligned with EU methodology.
• Material composition and critical raw materials information.
• Recycled content declarations and end-of-life properties.

Product identity and performance metrics:

• Unique identifiers and model information linked to a QR code.
• Usage, Safety, and Performance Specifications.
• Compliance and certification status with relevant EU standards.

Supply chain and due diligence records:

• Traceability of material sources.
• Verification data for supplier compliance obligations.
• Risk assessment data under EU due diligence frameworks.

Data access rights will vary: some technical and safety information will be restricted to authorised bodies, while environmental and supply information may be publicly accessible or shared with stakeholders who have a legitimate interest.

Why Early Adoption Matters for Business Strategy

Meeting the 2027 mandate for battery passports is just the first step in a larger transformation. As the ESPR phases in broader DPP obligations, companies that build robust data management systems now will be better positioned to:

• Integrate traceability across multiple product lines.
• Leverage sustainability metrics for market differentiation.
• Reduce compliance risk as new delegated acts emerge.
• Enable reuse of data across regulatory and voluntary reporting frameworks such as CSRD.

Early work on batteries gives firms a runway to design data architectures and stakeholder processes that can be scaled to other categories under ESPR. This early compliance pathway effectively turns an impending regulatory deadline into a source of innovation momentum.

The BASE Project: Laying the Foundation for Practical DPP Implementation

The BASE Project is actively supporting industry actors in transitioning from conceptual planning to operational readiness. BASE focuses on developing an interoperable Digital Battery Passport framework aligned with EU regulatory timelines and technical expectations.

By building lifecycle data standards, embedding carbon footprint reporting, aligning due diligence indicators, and incorporating circularity metrics, BASE helps manufacturers, recyclers, and value-chain partners translate compliance requirements into scalable digital practice.

Crucially, BASE emphasises data integrity, governance, and interoperability in its technical architecture, elements that will be essential for broader DPP use cases beyond batteries as the ESPR expands implementation across multiple sectors.

Closing Thoughts

The EU’s regulatory agenda is no longer shaping digital product passports as a future ambition. Through early mandates for batteries and the broader Ecodesign DPP framework, the European Union intends to pressurise and encourage industry into early and serious adoption.

Companies that respond proactively will gain a head start in the transition to transparent, circular and low-carbon product ecosystems. The Digital Product Passport initiative, anchored in battery regulation and expanding outward, will remain a central pillar of sustainable market practices in Europe over the next decade and beyond.

Resources:

European Commission — Regulation (EU) 2023/1542 on batteries and waste batteries (DBP requirement): https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng

Ecodesign for Sustainable Products Regulation (ESPR) overview and DPP role: https://commission.europa.eu/energy-climate-change-environment/standards-tools-and-labels/products-labelling-rules-and-requirements/ecodesign-sustainable-products-regulation_en

Council press on Ecodesign Regulation establishing Digital Product Passports: https://www.consilium.europa.eu/en/press/press-releases/2023/05/22/ecodesign-regulation-council-adopts-position/

Hogan Lovells. Digital Product Passports in the EU – Comprehensive Expansion under the Ecodesign for Sustainable Products Regulation and what can be learnt from the Battery Passport Pilot: https://www.hoganlovells.com/en/publications/digital-product-passports-in-the-eu-comprehensive-expansion

Standardisation efforts for Digital Product Passports coordination (CEN/CENELEC SDPP project): https://www.dke.de/en/areas-of-work/industry/eismea-clc-sdpp