Battery Passport vs Digital Product Passport what changes under Article 77 and ESPR

From 18 February 2027, Article 77 applies to each LMT battery, each industrial battery with capacity greater than 2 kWh, and each electric vehicle battery placed on the market or put into service.

ESPR is not battery-only. It is designed for product groups selected through ESPR work planning and delegated acts; the first working plan prioritises groups such as iron and steel, aluminium, textiles, furniture, tyres, detergents, paints, lubricants, chemicals, energy-related products, ICT products and other electronics.

A battery team should first classify the battery under Regulation (EU) 2023/1542. ESPR product-group analysis is a separate step for products containing batteries or adjacent product categories.

Battery passport duties are written directly into the Batteries Regulation. Article 77 creates the electronic record and Annex XIII lists battery-specific public, restricted and legitimate-interest data categories.

The ESPR DPP is a framework. Article 9 says delegated acts adopted for product groups specify the passport requirements, including data, access, update rights and the level of granularity.

Do not treat ESPR as a substitute source for battery passport obligations. Use the Batteries Regulation for battery passport scope and data, then use ESPR to understand the wider DPP architecture and cross-passport expectations.

The battery passport contains both model-level data and individual-battery data. Annex XIII includes public fields such as material composition, carbon footprint, due diligence, recycled content, capacity, voltage, power capability, lifetime, warranty, EU declaration of conformity and waste-management information, plus restricted data for legitimate-interest actors and authorities.

ESPR passport data is not fixed for all products. Annex III lists potential elements such as the unique product identifier, commodity codes, compliance documentation, instructions, manufacturer/importer/operator identifiers, facility identifiers and passport-service-provider reference; the delegated act selects what applies.

Reuse data infrastructure, not the whole data schema. A battery passport needs Annex XIII fields even when an ESPR product passport for another product group uses different identifiers or documentation fields.

Battery passport access is split by Annex XIII and Article 77: public data, data for notified bodies, market surveillance authorities and the Commission, and data for persons with a legitimate interest, including repair, remanufacturing, second-life, recycling and energy-market purposes where the Article 77 criteria are met.

ESPR access rights are set at product-group level in the applicable delegated act. Article 11 lists broad potential audiences, including customers, economic operators, repairers, independent operators, remanufacturers, recyclers, market surveillance and customs authorities, civil society organisations, trade unions and other relevant actors.

Build role-based access controls separately. A person who can see one ESPR DPP field is not automatically entitled to see restricted battery passport data.

The battery passport is accessed through the Article 13(6) QR code, which links to a unique identifier attributed by the economic operator placing the battery on the market. The QR code and unique identifier must comply with ISO/IEC 15459 standards or equivalent standards.

ESPR uses the broader concept of a data carrier connected to a persistent unique product identifier. The applicable delegated act specifies whether the data carrier is on the product, packaging or accompanying documentation.

Battery passport implementation starts with the Batteries Regulation QR-code rule. ESPR carrier choices can inform architecture, but they do not remove the battery QR and unique-identifier requirements.

Article 78 requires the battery passport to be fully interoperable with other digital product passports required by Union ecodesign law across technical, semantic and organisational aspects of end-to-end communication and data transfer.

ESPR Article 11 requires DPPs to be fully interoperable with other ESPR passports required by delegated acts, with open, structured, searchable and machine-readable data, security, privacy and fraud-resistance requirements.

The battery passport should be designed as part of the EU DPP ecosystem, but interoperability means compatible exchange and access controls. It does not mean identical data, identical scope or identical legal duties.

The economic operator placing the battery on the market must keep passport information accurate, complete and up to date. Responsibility transfers when a battery is prepared for reuse, repurposed, remanufactured or becomes waste, and the passport ceases to exist after recycling.

Under ESPR, the economic operator placing the product on the market must provide the relevant data carrier or unique product identifier to dealers and online marketplaces where needed and make a backup passport copy available through a DPP service provider. The passport remains available for the period set in the applicable delegated act.

Battery passport operations need status-change and end-of-life controls that are specific to batteries. ESPR service-provider and backup-copy controls are relevant architecture inputs, but they do not replace Article 77 lifecycle transfers.

Reuse shared infrastructure for identifiers, carrier resolution, access control, audit logs, security, privacy and machine-readable formats, but keep the Article 77 battery data model and Annex XIII access categories intact.

Reuse ESPR architecture patterns for cross-product DPP strategy, but wait for the relevant ESPR delegated act before fixing a non-battery product's mandatory DPP data, level, access rights or availability period.

The clean operating model is a crosswalk: one column for Article 77 and 78 battery requirements, one column for ESPR Articles 9 to 11, and a third column showing exactly which platform control satisfies both without changing the underlying legal scope.

Battery passport duties are written directly into the Batteries Regulation. Article 77 creates the electronic record and Annex XIII lists battery-specific public, restricted and legitimate-interest data categories.

The ESPR DPP is a framework. Article 9 says delegated acts adopted for product groups specify the passport requirements, including data, access, update rights and the level of granularity.

Do not treat ESPR as a substitute source for battery passport obligations. Use the Batteries Regulation for battery passport scope and data, then use ESPR to understand the wider DPP architecture and cross-passport expectations.