Compliance overview
This section of the Traceable documentation provides detailed reference material for the regulatory frameworks that govern Digital Product Passports (DPPs) for batteries and other products placed on the European Union market. It is structured to serve the practical needs of operators using the Traceable platform, legal and compliance teams assessing obligations, and integration developers building against the Traceable API.
The documentation in this section is provided for informational purposes only and does not constitute legal advice. Regulatory requirements are subject to change through delegated acts, implementing regulations, guidance issued by the European Commission, and decisions of national market surveillance authorities. You should consult qualified legal counsel for advice specific to your products, supply chain, and jurisdiction before making compliance decisions.
What This Section Covers
The Compliance & Regulatory Library covers three regulatory frameworks that directly affect operators using the Traceable platform:
| Regulation | Short Name | In Force |
|---|---|---|
| Regulation (EU) 2023/1542 | EU Battery Regulation | 18 February 2024 |
| Regulation (EU) 2024/1781 | ESPR | 18 July 2024 |
| Regulation (EU) 2016/679 | GDPR | 25 May 2018 |
GDPR is addressed within this library only insofar as it intersects with supply chain data management — specifically the handling of personal data that may appear in DPP supply chain records, supplier contact information, and user account data managed by Traceable.
Who This Section Is For
Compliance and legal teams who need to understand the regulatory obligations their organisation must meet, the specific data fields mandated by each regulation, and how Traceable's DPP platform maps to those obligations.
Battery manufacturers and operators placing batteries on the EU market who need to understand which DPP obligations apply to their product category, what data must be collected from their supply chain, and what deadlines are currently in force.
Integration developers building against the Traceable API who need to understand which fields carry regulatory significance, which are mandatory versus recommended, and how to interpret Traceable's DPP data model in a regulatory context.
Importers and authorised representatives of non-EU manufacturers who bear legal responsibility for ensuring batteries placed on the EU market comply with the Battery Regulation and carry a valid DPP.
Key Regulations
EU Battery Regulation 2023/1542
Regulation (EU) 2023/1542 is the primary legislative instrument governing batteries placed on the EU market. It establishes requirements across the full battery lifecycle: sustainability, safety, labelling, information provision, and end-of-life management. The Battery Regulation introduced the mandatory battery passport — a digital product passport specific to batteries — as one of its central instruments for market transparency and circular economy objectives.
The regulation applies to all battery categories (portable, SLI, LMT, EV, and industrial) placed on the EU market or put into service in the EU, regardless of whether the battery is sold as a standalone product or incorporated into another product. Enforcement is being phased in by battery category between 2024 and 2026.
Traceable's DPP platform is built around the requirements of EU Battery Regulation 2023/1542. Every DPP created on the platform maps its fields directly to the regulation's data requirements.
Read the full EU Battery Regulation documentation →
ESPR — Ecodesign for Sustainable Products Regulation 2024/1781
Regulation (EU) 2024/1781 (ESPR) entered into force on 18 July 2024. It replaces the 2009 Ecodesign Directive and establishes a broad framework under which the European Commission will issue product-specific delegated acts setting ecodesign and information requirements — including DPP mandates — for nearly all product categories sold in the EU.
Batteries are governed by the Battery Regulation as lex specialis and are therefore not subject to a separate ESPR delegated act. However, ESPR is directly relevant to Traceable users in two ways:
- Device manufacturers that incorporate batteries into products (electric vehicles, consumer electronics, industrial equipment) will need to comply with ESPR delegated acts for their product category in addition to — or instead of — the Battery Regulation.
- Traceable's multi-industry architecture (which supports textiles and tyres in addition to batteries) is designed to accommodate ESPR delegated acts as they are finalised.
GDPR and Supply Chain Data
Regulation (EU) 2016/679 (GDPR) applies to Traceable as a data processor and to operators as data controllers to the extent that DPP records contain personal data. In practice, this most commonly arises in the context of supplier contact information, user account data, and audit log records that may include identifiable individuals.
Traceable's data handling practices — including data residency, retention, and processor agreements — are available in the Data Processing Agreement, provided on request at privacy@traceable.digital.
How the Regulations Interrelate
The diagram below illustrates the regulatory hierarchy for battery manufacturers using Traceable:
EU Battery Regulation 2023/1542
└── Governs battery DPPs (lex specialis)
├── Article 8: Digital product passport mandate
├── Article 77: Battery passport (specific to batteries ≥2 kWh)
└── Annexes XIII–XVII: Data requirements by category
ESPR 2024/1781
└── Governs DPPs for all other product categories
├── Article 9: DPP mandate (delegated acts per product group)
└── Future delegated acts: textiles, electronics, furniture, tyres...
└── If product contains a battery → Battery Regulation governs
the battery DPP; ESPR governs the product DPP
GDPR 2016/679
└── Governs personal data processed in connection with DPPs
├── Operator = data controller for supplier/user data
└── Traceable = data processor under Article 28 DPA
For most battery manufacturers using Traceable, the EU Battery Regulation is the primary regulatory instrument. ESPR becomes relevant if you also manufacture products that contain batteries (such as electric vehicles or battery-integrated equipment) or if you expand into other regulated product categories on the Traceable platform.
Navigation
| Section | Contents |
|---|---|
| EU Battery Regulation → | Overview, scope, timeline, DPP requirements, Annex XIII, field mapping |
| Battery Categories → | EV, LMT, industrial, SLI, and portable battery requirements |
| ESPR → | ESPR overview and intersection with the Battery Regulation |