โš–๏ธ Legal & Compliance

EU Battery Regulation 2023/1542: What It Requires

Updated 2026-04Essential reading

The EU Battery Regulation 2023/1542 requires every EV battery, industrial battery above 2 kWh, and light means of transport (LMT) battery placed on the EU market to carry a Digital Product Passport (DPP) from 18 February 2027.

What the regulation covers

The Battery Regulation replaces the old Batteries Directive (2006/66/EC) and introduces new obligations across the entire battery lifecycle โ€” from raw material sourcing through manufacturing, use, and end-of-life recycling. The DPP is the regulation's primary enforcement mechanism: a digital record that travels with the battery and makes compliance data accessible to customs authorities, market surveillance bodies, and recyclers.

Article 77 of the regulation establishes the battery passport requirement. Article 78 creates the EU DPP Registry โ€” a central database operated by the European Commission where every passport must be registered.

Who it affects: four economic operator roles

The regulation assigns obligations to four types of economic operator. Your obligations depend on which role you hold.

RoleWho this isKey DPP obligation
ManufacturerThe company that produces the battery or has it produced and markets it under their nameCreates and maintains the DPP. Responsible for accuracy of all Annex XIII data. Must register the passport with the EU registry.
ImporterA company established in the EU that places a battery from a non-EU manufacturer on the EU marketMust verify that the battery has a valid, registered DPP before placing it on the market. If the manufacturer has not created one, the importer becomes responsible.
Authorised RepresentativeA company established in the EU, mandated by a non-EU manufacturer to act on their behalfCan create and manage DPPs on behalf of the manufacturer. Acts as the EU-based point of contact for market surveillance authorities.
DistributorA company in the supply chain that makes the battery available on the market but is neither the manufacturer nor importerMust verify the battery carries a valid DPP and QR code before making it available. Cannot modify passport data.
โ„น๏ธYour role in DPP Cloud

Your economic operator role is set at account level in DPP Cloud. It determines which fields are required and how your organisation appears on registered passports. You can override the role on individual passports if needed โ€” for example, if you manufacture some batteries and import others.

What data goes into the passport

The regulation's Annex XIII defines the mandatory data fields for battery passports. These fall into four groups:

  1. Identity and origin โ€” manufacturer name, manufacturing location, manufacturing date, battery model, GTIN, and passport number.
  2. Performance โ€” rated capacity, voltage, energy density, cycle life, and expected lifetime under reference conditions.
  3. Sustainability โ€” carbon footprint (kg COโ‚‚e per kWh), recycled content percentages for cobalt, lithium, nickel, and lead, and supply chain due diligence declarations.
  4. Supply chain โ€” the economic operators involved, including raw material suppliers, cell manufacturers, and recyclers.

DPP Cloud structures the passport creation wizard around these four groups. Each field maps directly to an Annex XIII requirement.

Key dates

The regulation's obligations phase in over several years. The three dates that matter most right now:

  • 18 August 2025 โ€” Phase 1: carbon footprint declarations and supply chain due diligence required for LMT and industrial batteries above 2 kWh. This date has passed.
  • 19 July 2026 โ€” The EU DPP Registry goes live. DPP Cloud switches from mock submission mode to live registry submission automatically.
  • 18 February 2027 โ€” Phase 3: the battery passport mandate. Every in-scope battery placed on the EU market must have a registered DPP. No passport means the battery cannot clear EU customs.
โš ๏ธFebruary 2027 is a hard deadline

Batteries placed on the EU market after 18 February 2027 without a registered Digital Product Passport cannot legally be sold in the EU. Customs authorities will have direct access to the EU registry to verify passport status at the border.

What DPP Cloud does

DPP Cloud is a battery passport platform that handles the full compliance workflow: creating passports with Annex XIII data, generating GS1 Digital Link QR codes for battery labels, and submitting passports to the EU DPP Registry. It does not replace your obligation to gather the underlying data (carbon footprint assessments, recycled content calculations, supply chain records) โ€” but it gives you the digital infrastructure to turn that data into a compliant, registered passport.

Start building your Digital Product Passports

EU Battery Regulation compliance โ€” 18 February 2027 deadline.

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