EV batteries
Electric vehicle batteries are the battery category with the earliest and most comprehensive set of DPP obligations under Regulation (EU) 2023/1542. If you manufacture, import, or place EV batteries on the EU market, the DPP obligation is already in force.
This documentation is informational only and does not constitute legal advice. Consult qualified legal counsel for compliance decisions specific to your products and market.
Definition
EV batteries are defined in Article 3(14) of the regulation as batteries specifically designed to provide the primary power for the traction of a road vehicle, belonging to vehicle type-approval categories M, N, or O under EU type-approval legislation (Regulation (EU) 2018/858), and having an energy capacity of more than 2 kWh.
Vehicle categories in scope
| EU Vehicle Category | Description | Examples |
|---|---|---|
| M1 | Passenger cars (≤8 seats + driver) | Sedans, SUVs, hatchbacks, MPVs |
| M2 | Minibuses (>8 seats, ≤5 t GVW) | Minibuses, large vans with passenger seats |
| M3 | Buses and coaches (>8 seats, >5 t GVW) | City buses, coaches |
| N1 | Light commercial vehicles (≤3.5 t GVW) | Vans, small trucks |
| N2 | Medium commercial vehicles (3.5–12 t GVW) | Medium trucks |
| N3 | Heavy commercial vehicles (>12 t GVW) | HGVs, articulated lorries |
| O | Trailers and semi-trailers | Where batteries provide power for refrigeration or auxiliary systems |
The 2 kWh threshold excludes mild hybrid (MHEV) starter/recovery batteries, which typically carry below 2 kWh and are used for energy recovery rather than primary vehicle propulsion.
Enforcement Dates: What Is Already Mandatory
DPP — Mandatory from 18 August 2024
The EV battery DPP obligation is currently in force. Every EV battery placed on the EU market on or after 18 August 2024 must have a valid, accessible digital product passport (battery passport). The DPP must be:
- Created before the battery is placed on the EU market
- Accessible via a QR code permanently affixed to the battery
- Populated with all mandatory data fields for the EV battery category
- Available to market surveillance authorities on demand
Batteries placed on the EU market before 18 August 2024 are not retrospectively required to have a DPP, but batteries that remain in distributor stock and are placed on the market after that date must comply.
Carbon Footprint Declaration — Mandatory from 18 February 2025
From 18 February 2025, every EV battery DPP must include a carbon footprint declaration: the total lifecycle carbon footprint of the battery expressed in kg CO₂ equivalent per kWh of rated energy capacity. The declaration must:
- Be calculated using the methodology established in the Commission delegated act under Article 7(1), which is based on the Product Environmental Footprint (PEF) Category Rules for rechargeable batteries
- Cover all lifecycle stages: raw material extraction, cell manufacturing, battery assembly, transportation, use phase assumptions, and end-of-life processing
- Be supported by a technical study or LCA report retained by the operator for the battery's lifetime plus ten years
Carbon Footprint Performance Class — Mandatory from 18 February 2026
From 18 February 2026, every EV battery DPP must include a carbon footprint performance class: a letter rating from A (lowest footprint) to E (highest footprint), relative to thresholds set by Commission delegated act. The performance class must also appear on the physical battery label.
Batteries with a carbon footprint above the maximum threshold established by the Commission may be prohibited from being placed on the EU market from a date to be determined.
Recycled Content Requirements
Recycled content declarations must appear in the EV battery DPP from the DPP mandatory date (18 August 2024). The minimum thresholds below become legally enforceable from 2030 — batteries that fail to meet these thresholds may not be placed on the EU market after those dates.
| Material | Minimum from 1 January 2030 | Minimum from 1 January 2035 |
|---|---|---|
| Cobalt | 16% | 26% |
| Lithium | 6% | 12% |
| Nickel | 6% | 15% |
| Lead | 85% | 85% |
The recycled content percentages are expressed as a share of the total content of that material in the battery, by weight. Declarations must be independently verified by a third party — self-declaration alone is not sufficient.
Preparation note: Achieving the 2030 recycled content thresholds requires material procurement decisions made years in advance of the deadline. Operators should engage with their cell and material suppliers now to understand their recycled content roadmaps and obtain supply chain data.
Supply Chain Due Diligence
EV battery manufacturers and importers must implement a supply chain due diligence policy covering the sourcing of the following materials from conflict-affected and high-risk areas:
- Cobalt and cobalt compounds
- Natural graphite
- Lithium and lithium compounds
- Nickel and nickel compounds
The due diligence obligation under Article 72 requires operators to:
- Adopt a supply chain due diligence policy consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas
- Implement a supply chain management system identifying suppliers and sub-suppliers at each material stage
- Conduct risk assessments for sourcing from conflict-affected and high-risk areas
- Engage with third-party auditors to verify supply chain practices
- Disclose due diligence information, including material geographic origins, in the DPP
Traceable fields for EV battery supply chain
In the Traceable DPP Builder, the following fields capture supply chain due diligence data for EV batteries:
| Field | What to Enter | Where to Find It |
|---|---|---|
| Cobalt — country of extraction | ISO country code(s) of the country/countries where cobalt was mined | From your cell supplier's material disclosure documentation |
| Natural graphite — country of extraction | ISO country code(s) | From cell supplier or anode material supplier |
| Lithium — country of extraction | ISO country code(s) of mining or brine extraction location | From cell supplier or lithium material supplier |
| Nickel — country of extraction | ISO country code(s) | From cell supplier or precursor material supplier |
| Due diligence policy URL | Public URL to your supply chain due diligence policy document | Your legal/compliance team |
| Third-party audit reference | Document reference for the most recent independent audit | From your external auditor |
Where a single battery contains materials from multiple countries of extraction (e.g. cobalt sourced from both the DRC and Australia), all relevant countries must be declared.
State of Health Reporting
Article 14 of the regulation requires that EV battery DPPs contain information about the battery's state of health (SoH) — a measure of the battery's current condition relative to its original rated performance. SoH data is critical for:
- Second-life assessment (determining whether a retired EV battery can be repurposed for stationary energy storage)
- End-of-life decision-making by recyclers
- Consumer transparency regarding battery degradation
What must be declared
The DPP must include:
- SoH methodology: A description of the parameters and calculation method used to determine SoH (e.g. capacity-based SoH, resistance-based SoH, or an internal BMS model)
- SoH at time of supply (where applicable): For batteries not being placed on the market at beginning of life (e.g. reconditioned batteries or batteries from dismantled vehicles), the current SoH value must be declared
BMS data access for second-life operators
Article 15 requires that authorised second-life operators and recyclers can access the battery management system (BMS) data necessary to assess the battery's suitability for second-life use. In practice, this means:
- The DPP must include technical documentation enabling authorised parties to access or interpret BMS data
- Data items include: historical capacity fade, cycle count, estimated remaining useful life, and temperature history
- Access is controlled through the authorised-party access tier of the Traceable DPP — see DPP Requirements
Second-Life Battery Provisions
Where an EV battery is retired from vehicle service and repurposed for a second application (such as a stationary battery energy storage system), the following obligations apply:
- The original DPP must remain accessible and continue to carry all originally declared data
- A second-life operator who repurposes the battery becomes a manufacturer of a new product (the repurposed battery) and must create a new or updated DPP reflecting the battery's second-life configuration and current condition
- The SoH at the time of second-life commissioning, the repurposing operator's details, and the new application type must be added to the DPP record
- The second-life battery must meet the performance and safety requirements applicable to its new application
Traceable supports second-life DPP updates: authorised operators can add a second-life record to an existing EV battery DPP without overwriting the original data.
EV Battery Template in Traceable
The Traceable EV Battery DPP template is pre-configured with all mandatory fields for EV batteries. The template covers:
- Battery Details: Identity, specifications, chemistry, manufacturer
- Carbon Footprint: Value, lifecycle stage breakdown, performance class, study reference
- Recycled Content: Cobalt, lithium, nickel, lead — declared and verification status
- Performance & Durability: Capacity, cycle life, calendar life, SoH methodology, power
- Supply Chain: Geographic origin fields for all four regulated materials, due diligence policy
- Safety: UN 38.3 status, applicable standards, fire risk
- Compliance: DoC reference, notified body, CE marking, harmonised standards
- End of Life: Collection scheme, EPR registration, dismantling instructions, second-life suitability
All mandatory fields are marked with a red asterisk in the DPP Builder. Fields that are not yet mandatory but are recommended for regulatory readiness are marked with an advisory indicator.