Battery DPP

The Battery Regulation (EU 2023/1542) is the first product-group regulation to require a Digital Product Passport in production. Article 1(3) applies it to five categories of battery, and only five: portable, starting-lighting-ignition (SLI), light means of transport (LMT), electric vehicle (EV) and industrial. The list is closed on purpose: where a battery could fall under more than one category, the strictest requirements apply, and that rule only works over a closed list. Stationary energy-storage systems are not a sixth category; the Regulation places them under industrial. The regulation is already in force, and some of its staged dates have already passed.

Which batteries need a passport

Not all five. Art. 77(1): from 18 February 2027, each LMT battery, each industrial battery with a capacity greater than 2 kWh and each electric-vehicle battery placed on the market or put into service must have a battery passport. Portable and SLI batteries, and industrial batteries of 2 kWh or less, do not. Under Art. 77(8) the passport ceases to exist once the battery has been recycled.

What the regulation requires

Article 77 sets up the battery passport, and Annex XIII lists the information it must carry: the carbon footprint over the battery’s lifecycle, the materials composition (in particular critical and recycled content), the State of Health (SoH) and remaining capacity for second-life evaluation, the chemistry classification, the party responsible for end-of-life management, and the supply-chain due-diligence statement.

Supply-chain due diligence

The regulation requires the economic operator to identify, prevent and address risks in their cobalt, lithium, nickel and natural-graphite supply chains, in line with the OECD Due Diligence Guidance, with annual reporting, third-party verification and public disclosure. Regulation (EU) 2025/1561 postponed the start of the Art. 48(1) duty to 18 August 2027.

Odal does not do the due-diligence work; that is the operator’s responsibility. The passport holds the record of it: a link to the operator’s published due-diligence report.

How Odal carries it

A battery passport records the Annex XIII fields with the constraints the regulation sets. It is versioned, so a change in the regulation becomes a new version without invalidating existing passports. The battery rules run as a sandboxed plugin, the same way as every other product group’s. A repurposed or remanufactured battery’s new passport links back to the passport, or passports, of the batteries it came from, as Art. 77(7) requires.

What is checked today

The Battery Regulation is in force, but its requirements start in stages, and Odal only gives a verdict on what already applies:

Enforced now: the restrictions on mercury and cadmium in Art. 6 and Annex I, and cross-field checks, such as a battery’s operating-temperature range being consistent.
Declared now, binding later: the minimum recycled-content shares for cobalt, lithium, nickel and lead, set by Art. 8(2) and 8(3) and cross-referenced to Annex VIII. (Annex X is the due-diligence raw-materials list and has nothing to do with recycled content.) These are final law but only take effect in 2031, rising again in 2036, so today they are shown as advisory rather than as a pass or fail.
Waiting for a delegated act: minimum electrochemical performance and durability values, empowered by Art. 10(5), and the carbon-footprint performance class under Art. 7(2). Art. 7(2) requires the label to declare a class but leaves the classes themselves to an act that has not been adopted, and requires the scale to be revised every three years. Neither the classes nor how many there will be is settled, and we do not guess.

The passport itself becomes mandatory on 18 February 2027. As each later requirement takes effect, the battery checks are extended to cover it, and passports already issued stay valid. Every product group follows the same approach of giving a binding verdict only where the law applies; see ESPR Overview.

Who may read which part

Art. 77(2) splits the passport between the public, authorities and persons with a legitimate interest, and the split is not a ladder: authorities see conformity test reports that nobody else sees, and only a person with a legitimate interest sees the individual battery’s own history. The implementing act under Art. 77(9), due by 18 August 2026, is to name who counts as a person with a legitimate interest for points 2 and 4; we hold no adopted text of it. See Access control.