Commission Hosts Info Session on EU DPP Implementation for Batteries - Here's What You Missed

On May 27th, the EU Commission hosted an info session on implementation of the EU Digital Product Passport for batteries, focusing on key timelines, data requirements and interoperability. Here's what you need to know.

The DPP for batteries will apply from February 18 2027, but not all information will be required from day one. Carbon footprint, recycled content, and due diligence data will only apply once the relevant legal and technical specifications are in place. The DPP system will rely on a Central Registry, data carriers, and unique identifiers. Economic operators will register required information before placing batteries on the EU market.

Who can access the battery passport data, and who is responsible for keeping the data up to date?

The Commission explained that access to restricted passport data will be defined through an implementing act (to be approved by the Member States). This will specify which actors have a legitimate interest in accessing certain data and whether they may view, download, share or reuse it.

Responsibility for the passport will sit with the economic operator placing the finished battery on the EU market, typically the manufacturer, importer, or authorized representative. The passport applies to complete batteries, not individual modules or packs still requiring assembly.

Dynamic data, such as state-of-health information, may need to be updated during the battery lifecycle, but the Commission stressed that updates should remain proportionate and are not required where there is no meaningful change. State-of-health data applies only to relevant batteries with a battery management system.

On update frequency, some data only needs to be updated when the battery status changes. For state-of-health data, daily or more frequent updates may be required where relevant, but the Commission stressed that updates should remain proportionate and are not needed if there is no meaningful change.

Where can operators find the data requirements for the DPP for batteries?

The content of the passport is based on Annex XIII of the Batteries Regulation (EUBR). The Commission cannot meaningfully change this list now that the regulation has been adopted, except in limited cases linked to scientific and technical progress.

Some fields of the passport may remain empty, either temporarily because the relevant legal provisions do not yet apply, or permanently because they are not relevant to certain battery categories. This includes carbon footprint, recycled content, and due diligence requirements, which will only apply once the relevant obligations and technical specifications are in place.

Will the Commission develop technical guidance?

The Commission is developing technical guidance, including a semantic rulebook, to translate legal requirements into practical data requirements for industry.

What is the official timeline for the EU DPP?

• June 2026: Implementing Act on DPP Registry to be introduced

• July 2026: DPP Registry becomes operational (operators can register - note that passports will not be live or required by July, this just is when operators can register on the DPP Registry)

• Q3 2026: (EC proposal) European Product Act and Circular Economy Act

• Q4 2026: Adoption of ESPR Delegated Act iron & steel; Implementing Act for battery access rights

• Q1 2027: Delegated Act DPP service providers; Delegated Act for construction materials under CPR

• February 2027: DPP becomes mandatory for batteries

• Q2 2027: Implementing Act Digital identities; Delegated Act for unique identifiers; Horizontal Delegated Act for reparability

• Q3 - Q4 2027: Adoption of ESPR Delegated Act on textiles, aluminum and tires

• 2028: DPP becomes mandatory for packaging, iron & steel and Construction materials; Delegated Act for Furniture

• 2029: DPP becomes mandatory for ICT products, tires, aluminum, textiles, detergents; Delegated Act for mattresses; Horizontal Delegated Act for recycled content

• 2030: DPP becomes mandatory for toys that contain batteries

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