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 group the Annex XIII information with related information that operators commonly record. A battery passport must contain the Annex XIII information "to the extent applicable to the category or sub-category of battery concerned" (Article 77(2)); rows marked as not an Annex XIII item or not required by the Regulation are not required in the battery passport.
1. General Information
Applies to: the battery passports of LMT batteries, industrial batteries with a capacity greater than 2 kWh and electric vehicle batteries (Article 77(1)).
| 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 |
| Authorised representative (where applicable) | Name and address of the authorised representative, where the manufacturer has designated one by written mandate (Art. 40(1)); not an Annex XIII item |
2. Carbon Footprint
Applies to: EV batteries (declaration from 18 February 2025 or 12 months after the date of entry into force either of the delegated act or of the implementing act respectively referred to in the fourth subparagraph, points (a) and (b), whichever is the latest), rechargeable industrial batteries >2 kWh except those with exclusively external storage (from 18 February 2026 or 18 months after the date of entry into force either of the delegated act or of the implementing act respectively referred to in the fourth subparagraph, points (a) and (b), whichever is the latest), rechargeable industrial batteries >2 kWh with external storage (from 18 August 2030 or 18 months after the date of entry into force either of the delegated act or of the implementing act respectively referred to in the fourth subparagraph, points (a) and (b), whichever is the latest), LMT batteries (from 18 August 2028 or 18 months after the date of entry into force either of the delegated act or of the implementing act respectively referred to in the fourth subparagraph, points (a) and (b), whichever is the latest); Art. 7(1), second subparagraph. Not required for: SLI, portable. These dates derive from Article 7(1) and depend on when the delegated act and the implementing act referred to in its fourth subparagraph, points (a) and (b), enter into force.
| Field | Description |
|---|---|
| Carbon footprint value | Total lifecycle carbon footprint in kg CO₂ equivalent per one kWh of the total energy provided by the battery over its expected service life |
| Carbon footprint performance class | Classes set by Commission delegated act, with category A being the best class (Annex II point 8); the performance class requirements apply under Article 7(2), third subparagraph, to EV, rechargeable industrial >2 kWh and LMT batteries (LMT from 18 February 2030 or 18 months after the date of entry into force either of the delegated act or of the implementing act respectively referred to in the fourth subparagraph, points (a) and (b), whichever is the latest) |
| Carbon footprint study reference | Reference to the supporting lifecycle assessment or PEF study |
| Verification status | Whether the carbon footprint has been third-party verified; not an Annex XIII item (conformity with Article 7 is assessed under Module D1 or Module G, Article 17(2)) |
| Verifier identification | Name and accreditation number of the verifying body (where verified); not an Annex XIII item |
3. Recycled Content
Applies to: industrial batteries >2 kWh, EV, LMT and SLI batteries (Article 8). The recycled-content declaration applies from 18 August 2028 or 24 months after the date of entry into force of the delegated act referred to in the third subparagraph, whichever is the latest, 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 present in active materials that has been recovered from battery manufacturing waste or post-consumer waste (Art. 8(1)) |
| Nickel — recycled content (%) | Share of nickel present in active materials that has been recovered from battery manufacturing waste or post-consumer waste (Art. 8(1)) |
| Lithium — recycled content (%) | Share of lithium present in active materials that has been recovered from battery manufacturing waste or post-consumer waste (Art. 8(1)) |
| 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; not an Annex XIII item |
| Verification report reference | Reference to the verification documentation; not an Annex XIII item |
4. Renewable Content
Applies to: the battery passports of LMT batteries, industrial batteries with a capacity greater than 2 kWh and electric vehicle batteries (Article 77(1)); Annex XIII, point 1(f), requires the share of renewable content.
Annex XIII, point 1(f), includes the share of renewable content in the battery passport, without any condition on whether renewable materials are used.
5. Performance and Durability
Applies to: the battery passports of EV batteries, industrial batteries with a capacity greater than 2 kWh and LMT batteries (Annex XIII, points 1(g) to 1(p) and 4(a)). SLI and portable batteries have no battery passport.
| 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; electric vehicle batteries only (Annex XIII, point 1(k)) |
| 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); Annex XIII, point 4(b), requires information on the state of health pursuant to Article 14, which covers stationary battery energy storage systems, LMT batteries and electric vehicle batteries |
| 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: the battery passports of LMT batteries, industrial batteries with a capacity greater than 2 kWh and electric vehicle batteries (Article 77(1)). Separately, from 18 August 2026 or 18 months after the date of entry into force of the implementing act referred to in paragraph 10, whichever is the latest, the label of every battery carries the hazardous substances present in it (Article 13(1); Annex VI, Part A, point 8).
The battery passport must include, as part of the material composition of the battery, the hazardous substances present in the battery, other than mercury, cadmium or lead (Annex XIII, point 1(b)). Annex XIII sets no threshold level; a hazardous substance is a substance classified as hazardous pursuant to Article 3 of Regulation (EC) No 1272/2008 (Article 3(1), point (52)).
| Field | Description |
|---|---|
| Hazardous substance name | Name of each hazardous substance present in the battery, other than mercury, cadmium or lead; the Regulation does not require a CAS number |
| Location within the battery | The battery component in which the substance is present; not an Annex XIII item (producers provide the location of hazardous substances to waste management operators upon request, Article 74(3)) |
| Concentration | Concentration (% by weight) or range; not required by the Regulation |
| Safety data sheet reference | Reference to the relevant Safety Data Sheet (SDS); not required by the Regulation |
7. Supply Chain Due Diligence
Applies to: all battery categories, including portable batteries; Article 48(1) binds economic operators that place batteries on the market or put them into service. 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 Article 47, first paragraph, under which Chapter VII does not apply to economic operators that had a net turnover of less than EUR 40 million in the financial year preceding the last financial year and that are not part of a group which, on a consolidated basis, exceeds the limit of EUR 40 million. For batteries without a battery passport, the report referred to in Article 52(3) is accessed through the QR code (Article 13(6), point (b)).
| Field | Description |
|---|---|
| Geographic origin — cobalt | Country of origin of cobalt (Article 49(2), point (c), documentation; not an Annex XIII item) |
| Geographic origin — natural graphite | Country of origin of natural graphite (Article 49(2), point (c), documentation; not an Annex XIII item) |
| Geographic origin — lithium | Country of origin of lithium (Article 49(2), point (c), documentation; not an Annex XIII item) |
| Geographic origin — nickel | Country of origin of nickel (Article 49(2), point (c), documentation; not an Annex XIII item) |
| 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) |
Annex XIII does not require geographic origin in the battery passport; point 1(d) requires information on responsible sourcing as indicated in the report on battery due diligence policy referred to in Article 52(3). The supporting documentation under Article 49(2) covers the country of origin of the raw material and the market transactions from the raw material's extraction to the immediate supplier (point (c)) and, where point (f) applies, locations where the raw material is consolidated, traded and processed.
8. Extended Producer Responsibility
Applies to: producers of all battery categories (Chapter VIII); Annex XIII, point 1(s), brings the Article 74(1), points (a) to (f), information into the battery passport.
| Field | Description |
|---|---|
| EPR registration number | Producer's registration number in the register of producers of each Member State (Article 55); not an Annex XIII item |
| 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: the battery passports of LMT batteries, industrial batteries with a capacity greater than 2 kWh and electric vehicle batteries (Article 77(1)); the labels and markings themselves are required on batteries under Article 13.
The battery passport includes the information specified in Part A of Annex VI (Annex XIII, point 1(a)) and the marking requirements laid down in Article 13(4) and (5) (point 1(q)); rows marked as not an Annex XIII item are not required in the passport.
| Field | Description |
|---|---|
| Separate collection symbol | Confirmation that the crossed-out wheelie bin symbol is present on the battery |
| Capacity label | The capacity (Annex VI, Part A, point 6); the separate capacity label under Article 13(2) applies to rechargeable portable, LMT and SLI batteries, with specifications set by implementing act (Article 13(10)) |
| CE marking | Confirmation of CE marking; not an Annex XIII item (the passport includes the EU declaration of conformity, point 1(r)) |
| Hazardous substance symbols | CLP hazard pictograms (where applicable); not an Annex XIII item |
| 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; not an Annex XIII item (Article 13(6) and (7) govern the QR code) |
10. Compliance and Conformity
Applies to: the battery passports of LMT batteries, industrial batteries with a capacity greater than 2 kWh and electric vehicle batteries (Article 77(1)).
| 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 | The statement in the EU declaration of conformity that the compliance with the requirements laid down in Articles 6 to 10 and Articles 12, 13 and 14 has been demonstrated (Article 18(1)) |
Data Carrier Requirements
Article 13(6) to (8), Article 77(3) and Annex VI Part C of the regulation establish the following requirements for the QR code that gives access to the battery passport:
- Type: A QR code as described in Part C of Annex VI, which all batteries must bear from 18 February 2027 (Article 13(6)). The QR code and the unique identifier must comply with ISO/IEC 15459-1:2014, 15459-2:2015, 15459-3:2014, 15459-4:2014, 15459-5:2014 and 15459-6:2014 or their equivalent (Article 77(3)). Alternative types of smart labels can be provided for only by Commission delegated act (Article 13(8))
- Placement: Printed or engraved visibly, legibly and indelibly on the battery; only where this is not possible or not warranted on account of the nature and size of the battery, affixed to the packaging and to the documents accompanying the battery (Article 13(7))
- Readability: In high contrast to the background colour and readable by a commonly available QR reader (Annex VI Part C), and printed or engraved indelibly (Article 13(7))
- Language: Article 77 and Annex XIII set no language requirement for the battery passport
- Minimum size: Of a size that is easily readable by a commonly available QR reader, such as those integrated in hand-held communication devices (Annex VI Part C)
- Content: The QR code links to a unique identifier that the economic operator placing the battery on the market attributes to the battery (Article 77(3)); a unique identifier is "a unique string of characters for the identification of batteries that also enables a web link to the battery passport" (Article 3(1), point (66))
Traceable generates a QR code for each passport once it passes the publish gate. When the product has a GTIN, the code encodes a model-level GS1 Digital Link web address (/01/{GTIN}) that resolves to the public passport (codes for units or batches are produced separately); otherwise it encodes the passport's /dpp/{slug} address. 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
- EU declaration of conformity (point 1(r))
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:
- Results of test reports proving compliance with the requirements laid down in the Regulation or its delegated or implementing acts (Annex XIII, point 3)
- The information in Annex XIII, point 2: detailed composition, part numbers and sources for replacement spares, dismantling information and safety measures
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 assigns each field an access tier in its category configuration: public, persons with a legitimate interest, or authority. The tiers follow the platform's data model and may differ from the tier Annex XIII assigns. Check each field's tier against Annex XIII before you publish.
Battery-Passport Availability and Retention
Article 77(4) requires the economic operator placing the battery on the market to ensure that the information in the battery passport is accurate, complete and up to date. The battery passport must remain available after that economic operator ceases to exist or ceases its activity in the Union (Article 78, point (e)), and it ceases to exist after the battery has been recycled (Article 77(8)). 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.