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 provided for informational purposes only. It is not legal advice and does not constitute a compliance guarantee, certification, or attestation of conformity with Regulation (EU) 2023/1542. Operators remain solely responsible for their own compliance and should consult qualified regulatory counsel.
Regulatory Basis
The battery passport (the battery-specific form of digital product passport) is established by Article 77(1) of Regulation (EU) 2023/1542:
- Article 77(1) requires that, 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 has a battery passport. SLI and portable batteries have no Article 77 battery-passport obligation at any date.
- The information the battery passport must contain is set out in Annex XIII (via Article 77). Commission delegated and implementing acts may add further detail.
Note that Article 8 governs a separate obligation — minimum recycled content — and does not itself establish the battery passport. 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 |
| Producer registration number | Registration number in the national producer register of each Member State where batteries are placed (Article 55) |
| Authorised representative (where applicable) | Name and address of EU authorised representative for non-EU manufacturers |
2. Carbon Footprint
Applies to: EV batteries (declaration from 18 Feb 2025), industrial batteries >2 kWh (declaration from 18 Feb 2026), LMT batteries (declaration from 18 Aug 2028). Not required for: SLI, portable. These dates derive from Article 7(1)–(3) and depend on Commission delegated acts, so they may shift.
| 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; performance class is phased in under Article 7(2) for EV, industrial >2 kWh and LMT (LMT from 18 Feb 2030), on dates set by Commission delegated act |
| 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: industrial batteries >2 kWh, EV, LMT and SLI batteries (Article 8). The recycled-content declaration applies from 18 Aug 2028 for industrial (>2 kWh, except exclusively external storage), EV and SLI batteries, and from 18 Aug 2033 for LMT batteries. The first-tier minimum shares apply from 18 Aug 2031 (LMT excluded); the second-tier minimum shares apply from 18 Aug 2036 (all four categories, including LMT). Not required for: portable batteries (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, industrial, LMT and SLI batteries. The due-diligence obligations arise under Article 48 (Chapter VII, Articles 47–53) from 18 Aug 2027 (as amended by Regulation (EU) 2025/1561), subject to the small- and medium-sized-enterprise exemption in Article 47, first paragraph. Not required for: portable batteries.
| 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 13(6) and Annex VI Part C of the regulation establish the following requirements for the data carrier (such as a QR code) that links to the battery passport:
- 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.
Battery-Passport Access Tiers
Article 77 and Annex XIII organise battery-passport information into three access tiers according to who is entitled to access each element:
Tier (a): Public
Information accessible to the general public, without authentication — for example by scanning the data carrier (Annex XIII point 1). Intended to support consumer information, market surveillance, and environmental transparency.
Public-tier information includes (per Annex XIII):
- Manufacturer identification and contact details
- Battery category and model
- Battery chemistry / composition (as specified for the public tier)
- Rated capacity and nominal voltage
- Carbon footprint of the battery and its performance class (where applicable)
- Share of recycled cobalt, lithium, lead and nickel (where applicable)
- Renewable content (where applicable)
- Separate-collection and end-of-life information
- CE marking and Declaration-of-Conformity reference
Tier (b): Notified bodies, market-surveillance authorities and the Commission
Information accessible to notified bodies, market-surveillance authorities and the Commission (Annex XIII points 2 and 3; Article 77(2)(b)) — for conformity assessment and enforcement purposes.
This tier typically includes:
- Technical-documentation references
- Conformity-assessment and notified-body details
- Information supporting verification of the declared values
Tier (c): Persons with a legitimate interest
Information accessible to persons with a legitimate interest (Annex XIII points 2 and 4; Article 77(2)(c); the Commission will specify who qualifies by implementing act adopted by 18 August 2026 under Article 77(9)) — for example repairers, remanufacturers, second-life operators and recyclers, to the extent of their legitimate interest.
This tier typically includes:
- Detailed composition and materials data beyond the public tier
- State of health and expected-lifetime parameters
- Information needed for repair, repurposing, remanufacturing and recycling
- Dismantling and safety information
Traceable implements role-based access so operators can structure which fields are exposed to each tier. The Regulation defines who is entitled to each tier; Traceable helps you capture and publish the data at the tier the Regulation assigns.
Battery-Passport Availability and Retention
Article 77(4) requires that the battery passport remains available and up to date for as long as the battery is placed on the market, and that the information can be modified to reflect changes over the battery's life. Separately, technical documentation supporting conformity must be kept for 10 years after the battery is placed on the market (Article 38 and Annex VIII). The Regulation does not impose a "lifetime plus ten years" or 30-year passport-retention period.
Operators using Traceable should review Traceable's data-retention commitments, available on request from privacy@traceable.digital, and consider what happens to their passport records if they cease to use the Traceable platform — the operator's obligation to keep the passport available does not end when a platform subscription ends.