DPP requirements
This page explains what the EU Battery Regulation requires every battery DPP to contain, the data carrier requirements, and how DPP data is divided into public and restricted access tiers.
This documentation is informational only and does not constitute legal advice. Consult qualified legal counsel for advice specific to your products and compliance situation.
Regulatory Basis
The battery digital product passport (DPP) is mandated by two articles of Regulation (EU) 2023/1542:
- Article 8 establishes the general DPP obligation: every battery within scope must have a digital product passport before it is placed on the EU market.
- Article 77 establishes the battery passport as the specific form of DPP required for rechargeable industrial and EV batteries (and by extension LMT batteries under implementing acts). The battery passport is the primary instrument for the lifecycle data required under the regulation.
The minimum data requirements for each battery category are set out in the Annexes to the regulation, with further detail to be added by Commission delegated acts. Annex XIII covers industrial batteries (see Annex XIII for the full field reference).
Data Categories Required in Every Battery DPP
The following ten data categories represent the minimum scope of information that a compliant battery DPP must contain. Not every category applies to every battery type — the applicable fields by category are noted below.
1. General Information
Applies to: All battery categories.
| Field | Description |
|---|---|
| Battery manufacturer | Name and registered address of the battery manufacturer |
| Manufacturer contact | Contact information for enquiries and market surveillance |
| Manufacturing location | Country and facility identifier |
| Battery model identifier | The unique model or type identifier assigned by the manufacturer |
| Battery category | EV / LMT / Industrial / SLI / Portable |
| Battery chemistry | Active electrode materials (e.g. NMC, LFP, NCA, lead-acid) |
| Battery capacity | Rated capacity in ampere-hours (Ah) at defined test conditions |
| Voltage | Nominal voltage and operating range |
| Serial number or batch identifier | Unique identifier for the specific battery unit or production batch |
| Date of manufacture | Month and year of manufacture |
| EU Battery Database registration number | Producer registration number with the EEA database |
| Authorised representative (where applicable) | Name and address of EU authorised representative for non-EU manufacturers |
2. Carbon Footprint
Applies to: EV batteries (from 18 Feb 2025), Industrial batteries (from 18 Aug 2025). Not required for: LMT, SLI, Portable.
| Field | Description |
|---|---|
| Carbon footprint value | Total lifecycle carbon footprint in kg CO₂ equivalent per kWh of capacity |
| Carbon footprint performance class | Class A–E relative to market benchmarks (from 18 Feb 2026 for EV; from 18 Aug 2026 for Industrial) |
| Carbon footprint study reference | Reference to the supporting lifecycle assessment or PEF study |
| Verification status | Whether the carbon footprint has been third-party verified |
| Verifier identification | Name and accreditation number of the verifying body (where verified) |
3. Recycled Content
Applies to: EV and Industrial batteries (declarations from DPP mandatory date; minimum thresholds from 2030). Not required for: LMT, SLI, Portable (though voluntary declarations are permitted).
| Field | Description |
|---|---|
| Cobalt — recycled content (%) | Share of cobalt in the battery derived from pre- or post-consumer recycled material |
| Nickel — recycled content (%) | Share of nickel derived from recycled material |
| Lithium — recycled content (%) | Share of lithium derived from recycled material |
| Lead — recycled content (%) | Share of lead derived from recycled material (particularly relevant for SLI) |
| Verification status | Whether recycled content figures have been third-party verified |
| Verification report reference | Reference to the verification documentation |
4. Renewable Content
Applies to: All battery categories (where renewable materials are used).
The regulation anticipates that future batteries may incorporate biobased or renewable materials. Where such materials are used, the share of renewable content must be declared. For most current battery chemistries, this field will be zero or not applicable.
5. Performance and Durability
Applies to: EV, Industrial, LMT batteries. Limited requirements for SLI and Portable.
| Field | Description |
|---|---|
| Initial rated capacity | Rated capacity at beginning of life (Ah) at standard test conditions |
| Capacity threshold for end of life | The capacity value (% of rated) at which the battery is considered end of life |
| Cycle life | Number of full charge/discharge cycles to end-of-life threshold under defined conditions |
| Calendar life | Expected operational life in years under defined conditions (critical for industrial BESS) |
| Operating temperature range | Minimum and maximum temperature for rated operation |
| State of health (SoH) methodology | Description of the method used to determine SoH (supports second-life assessment) |
| Power capability | Rated maximum continuous and peak power output (kW) |
| Internal resistance | Initial internal resistance (mΩ) at defined test conditions |
6. Hazardous Substances
Applies to: All battery categories.
The DPP must identify hazardous substances present in the battery above the threshold levels established in Annex XIII of the regulation (by reference to the CLP Regulation, Regulation (EC) No 1272/2008).
| Field | Description |
|---|---|
| Hazardous substance name | Chemical name and CAS number of each hazardous substance present above threshold |
| Location within the battery | The battery component in which the substance is present |
| Concentration | Concentration (% by weight) or range |
| Safety data sheet reference | Reference to the relevant Safety Data Sheet (SDS) |
7. Supply Chain Due Diligence
Applies to: EV and Industrial batteries. Not required for: LMT, SLI, Portable.
| Field | Description |
|---|---|
| Geographic origin — cobalt | Country or region of extraction of cobalt |
| Geographic origin — natural graphite | Country or region of extraction of natural graphite |
| Geographic origin — lithium | Country or region of extraction of lithium |
| Geographic origin — nickel | Country or region of extraction of nickel |
| Due diligence policy reference | Reference to the operator's supply chain due diligence policy |
| Third-party audit reference | Reference to the most recent third-party supply chain audit (where available) |
The requirement to declare geographic origin applies to the raw material extraction stage, not the processing or refining stage. Where the same material passes through multiple processing countries, the country of extraction is the relevant origin.
8. Extended Producer Responsibility
Applies to: All battery categories (extent of information varies by category).
| Field | Description |
|---|---|
| EPR registration number | Producer's registration number in the relevant EU member state EPR scheme(s) |
| Take-back scheme identifier | Name and identification of the collective take-back scheme the producer participates in |
| Collection point information | Information on how end users can return the battery for recycling (particularly for portable and SLI batteries) |
9. Labelling Information
Applies to: All battery categories.
The DPP must include or reference the information that appears on the physical battery label, to ensure consistency and enable verification.
| Field | Description |
|---|---|
| Separate collection symbol | Confirmation that the crossed-out wheelie bin symbol is present on the battery |
| Capacity label | Consumer-facing capacity declaration (where applicable: mAh for portable, kWh for larger categories) |
| CE marking | Confirmation of CE marking |
| Hazardous substance symbols | CLP hazard pictograms (where applicable) |
| Carbon footprint performance class label | Performance class letter (where applicable) |
| QR code presence | Confirmation that the DPP QR code is physically present on the battery |
10. Compliance and Conformity
Applies to: All battery categories.
| Field | Description |
|---|---|
| Declaration of Conformity reference | Document reference number and date of the EU Declaration of Conformity |
| DoC issuing entity | Name and address of the entity that issued the DoC |
| Notified body identification | Name, country, and notified body number (where third-party conformity assessment was required) |
| Applicable standards | List of harmonised EU standards applied in the conformity assessment |
| Regulation compliance statement | Confirmation that the battery complies with all applicable requirements of Regulation (EU) 2023/1542 |
Data Carrier Requirements
Article 8(4) and Annex VI of the regulation establish the following requirements for the data carrier (QR code) that links to the DPP:
- Type: A two-dimensional QR code (ISO/IEC 18004)
- Placement: Permanently attached to the battery (or, for batteries incorporated in a device, to the device at minimum) and to any packaging
- Readability: Must remain legible and scannable for the operational lifetime of the battery
- Language: The QR code itself carries no language requirement — the DPP it links to must be available in the language(s) required for the market
- Minimum size: Defined in Commission implementing acts (consistent with product labelling regulations)
- Content: Must link directly to the DPP record for that specific battery — a single QR code linking to a manufacturer's website without a direct link to the specific battery DPP does not comply
Traceable generates a unique QR code for every DPP. The QR code encodes the direct URL to the battery's public DPP viewer page. Operators are responsible for ensuring that the QR code is printed and physically affixed to each battery unit before it is placed on the EU market.
Public, Authorised, and Operator Access Tiers
Article 77(3) of the regulation recognises that not all DPP data should be available to the general public. Battery DPP data is divided into three access tiers:
Tier 1: Public Access
Data accessible to any person who scans the QR code, without authentication. Intended to support consumer information, market surveillance, and environmental transparency.
Typical public-access data includes:
- Manufacturer name and contact information
- Battery model and category
- Battery chemistry
- Rated capacity and voltage
- Carbon footprint value and performance class (where applicable)
- Recycled content declarations
- Hazardous substance summary
- Separate collection and end-of-life instructions
- CE marking status
- Declaration of Conformity reference
Tier 2: Authorised Party Access (PoLI — Proof of Legitimate Interest)
Data accessible to parties who can demonstrate a legitimate interest in accessing it. The regulation anticipates that certain sensitive commercial or operational data should not be publicly available but must be accessible to authorised market surveillance authorities, repair operators, recyclers, and second-life operators.
Access under this tier is controlled by the Proof of Legitimate Interest (PoLI) mechanism. Traceable implements role-based access to DPP data, allowing operators to designate which fields are accessible to which authorised roles.
Typical authorised-access data includes:
- Supply chain due diligence documentation
- Third-party verification reports
- Detailed geographic origin data
- State of health data and BMS parameters (for second-life operators)
- Internal component identifiers
- Notified body assessment details
Tier 3: Operator-Only Access
Data accessible only to the battery manufacturer or operator and their authorised users within the Traceable platform. This data is maintained for internal compliance purposes and is not exposed through the public or authorised DPP access.
Typical operator-only data includes:
- Internal production batch records
- Supplier contracts and commercial terms
- Internal quality control records
- Draft DPP versions prior to publication
DPP Lifetime Requirements
Article 8(5) requires that DPP data remains accessible for the lifetime of the battery plus ten years. For EV and industrial batteries with operational lives of 15–20+ years, this means DPP records must remain accessible for up to 30 years.
Operators using Traceable should review Traceable's data retention commitments , available on request from privacy@traceable.digital and consider what happens to DPP records if they cease to use the Traceable platform — the regulatory obligation to maintain accessibility does not end when a platform subscription ends.