The EU Battery Passport: a 90-day readiness checklist

The EU Battery Regulation's passport requirement applies from 18 February 2027 to every industrial battery above 2 kWh, every LMT battery, and every EV battery placed on the EU market. The data set is the most extensive of any DPP regime confirmed so far.

Most producers we speak to underestimate three things: the carbon footprint workstream, the recycled-content evidence chain, and the cell-level identifier persistence requirement.

Days 0–30: scope and data inventory

Map every battery model that will be in market on or after the deadline. For each, list the attribute owners — internal and supplier. Most programmes find at least four distinct data sources that have never been integrated.

Lock in the identifier scheme now. The regulation expects a unique identifier per battery, persistent through second-life and recycling. GS1 SGTIN within a GS1 Digital Link URL is the path of least resistance.

Days 30–60: carrier and resolver

Decide on QR-plus-NFC or QR-only per model family. Industrial batteries almost always justify NFC for the workshop and recycler workflows. Validate the resolver can serve role-based views — consumer, recycler, customs — from a single scan.

Days 60–90: live pilot

Issue passports for one production batch end-to-end. Walk a recycler partner through the recycler view. Walk a workshop technician through the repair view. Almost every gap surfaces in this step, and almost none of them surface in a desk review.