EU Digital Product Passport for Batteries set to be introduced from 1st January 2026
The European Commission (EC) proposed the European Union (EU) Battery Regulation in 2020, as part of the wider EU Green Deal, which is likely to come into force August 2023. Introduction of digital product passports (DPP) have also been identified as a priority as part of the Ecodesign for Sustainable Products Regulation (ESPR) proposed in March 2022. Product passports will enable sharing of key product information essential for product sustainability and circularity. This will help accelerate the transition towards a circular economy, supporting material and energy efficiency, extending product lifetimes and optimising product design. DPP will enable new business opportunities, improve consumer choice, and enable environmental compliance through greater access to data. The EC hope for DPP to be impacting a selection of products by 2030, such as textiles, construction, consumer electronics or plastics, citing batteries as the first targeted product.
Article 65 of the EC’s draft Battery Regulation outlines that by 1 January 2026 industrial batteries and electric vehicles (EV) shall have an electronic record for each battery placed on the market. Batteries in scope include:
- Light Means Transport (LMT) Batteries – provide electric power for traction to wheeled vehicles that can be powered by the electric motor alone or by a combination of motor and human power.
- Industrial batteries with capacity above 2kWh – designed specifically for industrial use, intended for industrial uses after being subject to preparing for repurpose or repurposing or any battery that is above 5kg that is not LMT, EV or SLI battery.
- EV batteries – provide electric power for the traction to hybrid or electric vehicles.
Although the legislation will only target the EU market initially, there is hope for global alignment. The passport shall be provided through a ‘data carrier’ which has been confirmed as a QR code either printed or engraved clearly on the battery. This should be marked on all batteries 42 months after entry of battery regulation.
Primary responsibility sits with the economic operator (or an authorised representative) placing the battery on the market. This could either be:
The economic operator must ensure information in the battery passport is accurate, complete, and up to date. There are two scenarios where the responsibility of the battery passport needs to be transferred, where the battery is subject for re-use/re-purpose or re-manufacturing or where status is changed to waste. A battery passport shall cease to exist after the battery has been recycled.
The DPP battery requirements will fall within these broad categories.
- General battery and manufacturer information
- Compliance, labels, certifications
- Battery carbon footprint
- Battery materials and composition
- Circularity and resource efficiency
- Performance and durability
Access to the information will be varied depending on the active part from the supply chain. For instance, the consumer will have access to the majority of information such as renewable content, material composition or waste battery information. Whereas access of certain information such as detail composition or dismantle information will be available to natural or legal persons with a legitimate interest in accessing and processing information. Finally wider compliance data will be accessible to notified bodies, market surveillance authorities and the commission. For further information on required data for the battery DPP please see the suggestive comprehensive list here.
As the legislation continues to evolve and develop, impacted businesses should monitor guidance, support secondary legislation development, and collaborate with the wider supply chain to prepare. Battery Pass is a group of partners from industry and science, that have developed a consortium of leading experts that jointly advance the implementation and emerging EU Battery Regulations. Battery Pass are looking to bring together industry, steering legislation and supporting producers shedding clarity on guidance.
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