February 18, 2027 is the hard deadline: every EV, industrial (>2 kWh), and light means of transport (LMT) battery sold in the EU must ship with a machine-readable Digital Product Passport. Miss it and the product cannot be placed on the market. This guide covers exactly what the regulation requires, which batteries are in scope, and what the 91 mandatory data fields look like in practice.
Which batteries are in scope
Regulation (EU) 2023/1542 covers three categories where the passport is mandatory from February 2027: electric vehicle batteries, industrial batteries above 2 kWh capacity, and light means of transport batteries (e-bikes, e-scooters, e-mopeds). Portable batteries (consumer electronics) and SLI (starter, lighting, ignition) batteries remain outside the passport requirement for now, though other parts of the regulation — labelling, collection targets, recycled-content minimums — still apply.
What's in the 91 mandatory fields
The passport is not a marketing datasheet. It's a structured dataset accessible via QR code on the physical product, with tiered access: public (anyone scanning), restricted (business partners with tokens), and authority (regulators, recyclers, market surveillance). The 91 fields break down roughly as follows:
- General info (18): manufacturer, model, production date, CE/compliance marks, conformity assessment body
- Composition & materials (22): active materials by mass, hazardous substances, critical raw materials (lithium, cobalt, nickel, natural graphite)
- Carbon footprint (12): per-kWh CO₂e across lifecycle stages, declared against the PEF methodology
- Performance & durability (17): expected lifetime, internal resistance, power, energy density, round-trip efficiency
- Supply chain due diligence (9): cobalt, natural graphite, lithium, nickel — country-of-origin + social/environmental risk assessment
- Repair, repurposing, recycling (13): state-of-health on removal, parts availability, dismantling instructions
Who is responsible
The economic operator — whoever places the battery on the EU market, which usually means the manufacturer or the importer. A distributor reselling batteries already carrying a passport does not create a new one; their obligation is to check that a passport exists before placing on the market. Where a component battery cell supplier provides the cells but the pack is assembled elsewhere, the pack manufacturer is the economic operator for the finished battery's passport.
Where to start today
If you place batteries on the EU market and February 2027 is inside your product-development horizon, start by inventorying the 91 fields against what your organisation already has. Most manufacturers find 60–70% of the data exists — scattered across datasheets, supplier certificates, EPD reports, and internal QA documents. The gap is usually recycled-content percentages, per-kWh carbon footprint (requires a PEF calculation), and supply-chain due-diligence evidence. That gap is where you'll spend the next 18 months, and it's why a platform like TracePass exists: to collapse the last-mile data-wrangling step so your compliance team isn't still emailing suppliers in January 2027.
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