Battery Passport vs Digital Product Passport what changes under Article 77 and ESPR
The battery passport is a battery-specific obligation in Regulation (EU) 2023/1542; the Ecodesign for Sustainable Products Regulation (ESPR) is a wider framework that becomes concrete through product-group rules.
This comparison helps avoid false equivalence: batteries have their own passport trigger, access model, QR link, data fields, and lifecycle rules even though the passport must interoperate with other EU digital product passports.
A battery passport is a legally defined type of , not a generic ESPR passport with a battery label. Articles 77 and 78 of the EU Batteries Regulation fix the covered batteries, data, access categories, responsible operators, QR-code link, and lifecycle rules. ESPR Regulation (EU) 2024/1781 supplies the shared DPP registry and technical framework, while other product groups get their specific DPP requirements through delegated acts or separate EU legislation.
Article 77 and ESPR comparison
Battery passport vs ESPR Digital Product Passport: where the rules align and where they do not
The battery passport borrows the same policy architecture as EU digital product passports, but it is already tailored to light means of transport (LMT), industrial and electric vehicle batteries. ESPR supplies the horizontal product-passport framework for other product groups and for future cross-passport interoperability.
A mandatory electronic record under Article 77 of Regulation (EU) 2023/1542 for LMT batteries, industrial batteries over 2 kWh, and electric vehicle batteries placed on the market or put into service.
Second framework
ESPR Digital Product Passport
A horizontal framework under Regulation (EU) 2024/1781 where product-group delegated acts specify when a passport is required, what data it contains, who can access it, and whether it is at model, batch or item level.
Battery passport vs ESPR Digital Product Passport: where the rules align and where they do not
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.
Article 77(1) identifies the battery categories that must have a battery passport.
From 18 February 2027
ESPR is not battery-only. It introduces DPPs progressively through product-specific delegated acts. The Commission's current DPP schedule covers iron and steel, energy-related products, textiles, tyres, aluminium, furniture, mattresses, ICT products, and horizontal recycled-content work; separate EU laws also connect other product groups to the DPP system. A working-plan listing or indicative schedule does not itself create a product's mandatory DPP fields.
Current Commission implementation schedule for product-specific DPP acts, including iron and steel, energy-related products, textiles, tyres, aluminium, furniture, mattresses, ICT products and recycled content.
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.
The economic operator that places the battery on the market must attribute its unique identifier and keep passport information accurate, complete, and up to date. After preparation for re-use, preparation for repurposing, repurposing, or remanufacturing, responsibility transfers to the operator that places that battery on the market or puts it into service. It later transfers to the producer, producer responsibility organisation, or selected waste operator when the battery becomes waste.
Article 77(3), (4) and (7) assigns the identifier and accuracy duties and sets the responsibility transfers after preparation for re-use, preparation for repurposing, repurposing, remanufacturing, or waste status.
accurate, complete and up to date
ESPR assigns duties across the product-law chain. Manufacturers must ensure an applicable DPP is available; importers and distributors must verify required DPP and data-carrier steps; dealers and online marketplaces must make the data carrier visible to customers; and the operator placing the product on the market or putting it into service uploads required registry data.
Articles 27 to 34 allocate manufacturer, authorised representative, importer, distributor, dealer, fulfilment-service-provider, and online-marketplace duties; Article 13 assigns registry upload to the operator placing the product on the market or putting it into service.
economic operator placing the product on the market
Assign an owner for the finished battery passport and separate owners for registry registration, source-data maintenance, access decisions, status changes, and end-of-life transfer. A cell or component supplier can provide evidence, but the operator placing the finished battery on the market remains responsible for the passport.
Supports assigning the finished battery passport to the responsible economic operator rather than treating component suppliers as the legal passport owner.
economic operator placing the battery on the market
Commission implementation page stating that the passport obligation lies with the operator placing the finished battery on the market, rather than suppliers of individual components or modules.
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.
Annex XIII lists the public and restricted information categories for the battery passport.
material composition of the battery
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.
Annex III lists the data elements that product-group delegated acts may require or allow in ESPR passports.
unique product identifier
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.
Article 77 and Annex XIII define public, point 2 and point 3 restricted, and legitimate-interest access categories for battery passport information.
persons with a legitimate interest
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.
Article 11 ties ESPR DPP access to the access rights specified in the applicable product-group delegated act.
respective access rights
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.
Article 77(3) links the battery passport to the Article 13(6) QR code and ISO/IEC 15459 unique-identifier standards.
accessible through the QR code
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.
Article 10 connects the ESPR DPP through a data carrier to a persistent unique product identifier.
data carrier
Battery passport implementation starts with the Batteries Regulation QR-code rule. The same unique identifier must also be uploaded to the ESPR registry. ESPR carrier choices can inform architecture for other products, but they do not remove the battery QR, identifier, or registry 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. The battery passport itself becomes mandatory for covered batteries on 18 February 2027.
Article 78 requires technical, semantic and organisational interoperability with other Union ecodesign digital product passports.
fully interoperable
ESPR Article 13 required a central registry for unique identifiers. The Commission launched the registry and testing environment on 20 July 2026. Commission Implementing Regulation (EU) 2026/1778 sets the registry's technical and operational rules and takes effect on 6 August 2026; detailed product data remains decentralised with the operator or its service provider.
Binding implementation arrangements for the DPP registry, published 17 July 2026 and effective from 6 August 2026, including registration, verification, identifiers, access management, semantic repository, API, and logging.
Commission announcement that the registry and testing environment launched on 20 July 2026, with complete product data kept in the decentralised DPP system.
Design the battery passport as part of the EU DPP ecosystem and test registry registration before 18 February 2027. Interoperability means compatible identifiers, exchange, security, and access controls. It does not make the data sets, scope, or legal duties identical.
Supports the wider DPP ecosystem requirements for open, interoperable passport operation and the central registry's storage of battery unique identifiers.
The economic operator placing the battery on the market must keep passport information accurate, complete and up to date. After preparation for re-use, preparation for repurposing, repurposing, or remanufacturing, responsibility transfers only when another operator places that battery on the market or puts it into service. Waste status causes a separate transfer, and the passport ceases to exist after recycling.
Article 77 allocates accuracy duties, sets lifecycle responsibility transfers after the specified second-life operations or waste status, and ends the passport after recycling.
accurate, complete and up to date
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.
Article 10 requires backup copies through a DPP service provider, and Article 11 sets availability and service-provider processing limits.
back-up copy
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.
Supports keeping battery-specific Article 77 data and access requirements separate from generic DPP architecture choices.
Annex XIII
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.
Supports waiting for product-group delegated acts before locking non-battery ESPR DPP content and access rights.
applicable delegated act
Keep a crosswalk with one column for Article 77 and 78 battery requirements, one for ESPR Articles 9 to 11, and one showing 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.
Article 77 establishes the battery passport and Annex XIII sets the battery-specific information and access categories.
battery passport
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.
Article 9 makes the ESPR DPP depend on product-group delegated acts rather than one universal data sheet.
delegated act adopted pursuant to Article 4
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.
Supports treating ESPR as a horizontal framework whose concrete DPP content is set by delegated acts.
product group
Scope boundary
Battery Passport
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.
Article 77(1) identifies the battery categories that must have a battery passport.
From 18 February 2027
ESPR Digital Product Passport
ESPR is not battery-only. It introduces DPPs progressively through product-specific delegated acts. The Commission's current DPP schedule covers iron and steel, energy-related products, textiles, tyres, aluminium, furniture, mattresses, ICT products, and horizontal recycled-content work; separate EU laws also connect other product groups to the DPP system. A working-plan listing or indicative schedule does not itself create a product's mandatory DPP fields.
Current Commission implementation schedule for product-specific DPP acts, including iron and steel, energy-related products, textiles, tyres, aluminium, furniture, mattresses, ICT products and recycled content.
Operational implication
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.
Supports the battery-specific classification step for LMT, industrial and electric vehicle batteries.
industrial battery with a capacity greater than 2 kWh
Covered actors
Battery Passport
The economic operator that places the battery on the market must attribute its unique identifier and keep passport information accurate, complete, and up to date. After preparation for re-use, preparation for repurposing, repurposing, or remanufacturing, responsibility transfers to the operator that places that battery on the market or puts it into service. It later transfers to the producer, producer responsibility organisation, or selected waste operator when the battery becomes waste.
Article 77(3), (4) and (7) assigns the identifier and accuracy duties and sets the responsibility transfers after preparation for re-use, preparation for repurposing, repurposing, remanufacturing, or waste status.
accurate, complete and up to date
ESPR Digital Product Passport
ESPR assigns duties across the product-law chain. Manufacturers must ensure an applicable DPP is available; importers and distributors must verify required DPP and data-carrier steps; dealers and online marketplaces must make the data carrier visible to customers; and the operator placing the product on the market or putting it into service uploads required registry data.
Articles 27 to 34 allocate manufacturer, authorised representative, importer, distributor, dealer, fulfilment-service-provider, and online-marketplace duties; Article 13 assigns registry upload to the operator placing the product on the market or putting it into service.
economic operator placing the product on the market
Operational implication
Assign an owner for the finished battery passport and separate owners for registry registration, source-data maintenance, access decisions, status changes, and end-of-life transfer. A cell or component supplier can provide evidence, but the operator placing the finished battery on the market remains responsible for the passport.
Supports assigning the finished battery passport to the responsible economic operator rather than treating component suppliers as the legal passport owner.
economic operator placing the battery on the market
Commission implementation page stating that the passport obligation lies with the operator placing the finished battery on the market, rather than suppliers of individual components or modules.
Data fields and schema
Battery Passport
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.
Annex XIII lists the public and restricted information categories for the battery passport.
material composition of the battery
ESPR Digital Product Passport
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.
Annex III lists the data elements that product-group delegated acts may require or allow in ESPR passports.
unique product identifier
Operational implication
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.
Supports using the ESPR field list as a product-group-dependent framework rather than a universal schema.
what data are to or can be included
Core obligations
Battery Passport
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.
Article 77 and Annex XIII define public, point 2 and point 3 restricted, and legitimate-interest access categories for battery passport information.
persons with a legitimate interest
ESPR Digital Product Passport
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.
Article 11 ties ESPR DPP access to the access rights specified in the applicable product-group delegated act.
respective access rights
Operational implication
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.
Supports separating ESPR product-group access rights from the Batteries Regulation Annex XIII access model.
product group level
QR code, data carrier and identifier
Battery Passport
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.
Article 77(3) links the battery passport to the Article 13(6) QR code and ISO/IEC 15459 unique-identifier standards.
accessible through the QR code
ESPR Digital Product Passport
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.
Article 10 connects the ESPR DPP through a data carrier to a persistent unique product identifier.
data carrier
Operational implication
Battery passport implementation starts with the Batteries Regulation QR-code rule. The same unique identifier must also be uploaded to the ESPR registry. ESPR carrier choices can inform architecture for other products, but they do not remove the battery QR, identifier, or registry requirements.
Supports the broader ESPR data-carrier framing for product groups outside the battery-specific Article 77 rule.
product, its packaging or on documentation
Interoperability, registry and timing
Battery Passport
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. The battery passport itself becomes mandatory for covered batteries on 18 February 2027.
Article 78 requires technical, semantic and organisational interoperability with other Union ecodesign digital product passports.
fully interoperable
ESPR Digital Product Passport
ESPR Article 13 required a central registry for unique identifiers. The Commission launched the registry and testing environment on 20 July 2026. Commission Implementing Regulation (EU) 2026/1778 sets the registry's technical and operational rules and takes effect on 6 August 2026; detailed product data remains decentralised with the operator or its service provider.
Binding implementation arrangements for the DPP registry, published 17 July 2026 and effective from 6 August 2026, including registration, verification, identifiers, access management, semantic repository, API, and logging.
Commission announcement that the registry and testing environment launched on 20 July 2026, with complete product data kept in the decentralised DPP system.
Operational implication
Design the battery passport as part of the EU DPP ecosystem and test registry registration before 18 February 2027. Interoperability means compatible identifiers, exchange, security, and access controls. It does not make the data sets, scope, or legal duties identical.
Supports the wider DPP ecosystem requirements for open, interoperable passport operation and the central registry's storage of battery unique identifiers.
without vendor lock-in
Lifecycle responsibility and availability
Battery Passport
The economic operator placing the battery on the market must keep passport information accurate, complete and up to date. After preparation for re-use, preparation for repurposing, repurposing, or remanufacturing, responsibility transfers only when another operator places that battery on the market or puts it into service. Waste status causes a separate transfer, and the passport ceases to exist after recycling.
Article 77 allocates accuracy duties, sets lifecycle responsibility transfers after the specified second-life operations or waste status, and ends the passport after recycling.
accurate, complete and up to date
ESPR Digital Product Passport
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.
Article 10 requires backup copies through a DPP service provider, and Article 11 sets availability and service-provider processing limits.
back-up copy
Operational implication
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.
Supports the ESPR service-provider and delegated-act availability model.
digital product passport service provider
Overlap and reuse
Battery Passport
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.
Supports keeping battery-specific Article 77 data and access requirements separate from generic DPP architecture choices.
Annex XIII
ESPR Digital Product Passport
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.
Supports waiting for product-group delegated acts before locking non-battery ESPR DPP content and access rights.
applicable delegated act
Operational implication
Keep a crosswalk with one column for Article 77 and 78 battery requirements, one for ESPR Articles 9 to 11, and one showing which platform control satisfies both without changing the underlying legal scope.
Supports the ESPR side of a crosswalk covering product-group DPP requirements under Articles 9 to 11.
Articles 10 and 11
Practical decision rule
Battery Passport
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.
Article 77 establishes the battery passport and Annex XIII sets the battery-specific information and access categories.
battery passport
ESPR Digital Product Passport
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.
Article 9 makes the ESPR DPP depend on product-group delegated acts rather than one universal data sheet.
delegated act adopted pursuant to Article 4
Operational implication
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.
Supports treating ESPR as a horizontal framework whose concrete DPP content is set by delegated acts.
product group
Practical decision rule
How should teams decide whether a passport requirement is Battery Regulation or ESPR?
If the product is an LMT battery, industrial battery over 2 kWh, or electric vehicle battery, start with Regulation (EU) 2023/1542 Article 77 and Annex XIII.
If the product is outside the battery categories, check whether an ESPR delegated act covers the product group and specifies a DPP requirement.
If both regimes touch the same product ecosystem, reuse technical controls only after mapping each field, access right, carrier, owner and lifecycle rule to its own legal source.
Supports checking ESPR product-group delegated acts before treating a non-battery product passport as mandatory.
delegated act
1
Section 1
What this comparison is for
This page is relevant when a battery program, product-data platform or circularity roadmap calls everything a . The term is useful for architecture, but the legal analysis must separate Article 77 battery passport duties from ESPR product-group passport duties.
Interoperability does not create identical obligations. Article 78 requires the battery passport to interoperate with other Union ecodesign product passports; it does not erase the Batteries Regulation's own scope, Annex XIII data, access-right categories or lifecycle rules.
Use the battery passport column for LMT batteries, industrial batteries over 2 kWh and electric vehicle batteries.
Use the ESPR DPP column for product groups covered by ESPR delegated acts and for platform design choices that must work across product categories.
Keep a field-level crosswalk for data owners, data source, public or restricted access, update rights, retention or availability period, and the legal source that requires the field.
Supports the ESPR framework points on product-group delegated acts, data carriers, access rights and interoperability.
digital product passport
Recommended next step
Build a passport crosswalk before reusing DPP infrastructure
Map Article 77 and 78 battery passport fields against ESPR DPP architecture so shared systems preserve the right scope, access rights, data carrier, update owner and lifecycle controls.
Start with the finished battery, not the software platform. Confirm that it is an LMT battery, an industrial battery above 2 kWh, or an electric vehicle battery; identify the operator placing it on the market or putting it into service; then map every Annex XIII field to its source system, granularity, access category, owner, and update event.
Register and test the battery's unique identifier against the ESPR registry arrangements, while keeping the full passport data in the decentralised system maintained by the responsible operator or an authorised service provider. Commission Implementing Regulation (EU) 2026/1778 takes effect on 6 August 2026 and sets registry verification, registration, API, identifier, access-management, semantic-repository, and logging rules.
Do not freeze the legitimate-interest access matrix too early. Article 77(9) requires an implementing act specifying eligible persons, fields, and download, sharing, publication, and reuse rights by 18 August 2026. The Commission's current DPP timeline instead lists the battery access-right act for Q4 2026 and labels that timeline indicative. Use Annex XIII and Article 77's criteria for design, but treat the final published act as controlling.
Scope record: battery category, capacity where relevant, market-placement or putting-into-service event, responsible economic operator, and 18 February 2027 applicability.
Data map: each Annex XIII field, whether it is model-level or individual-battery data, the source record, data owner, update frequency, quality check, and public or restricted access category.
Identity and carrier: battery unique identifier, Article 13(6) QR code, registry registration, generated registration identifier, and a tested resolution path to the correct passport.
Lifecycle controls: new linked passport after preparation for re-use, preparation for repurposing, repurposing, or remanufacturing when the battery is then placed on the market or put into service; responsibility transfer when the battery becomes waste; and passport closure after recycling.
Change control: a release process for the Article 77(9) access-right act, later standards decisions, security changes, and any correction to source data.
Articles 77 and 78 and Annex XIII support the scope, QR code, identifier, data, access, lifecycle, interoperability, and 18 February 2027 implementation steps.
Current Commission implementation timeline, including the live registry, 18 February 2027 battery deadline, and indicative Q4 2026 timing for the battery access-right implementing act.
Primary source for Article 77 battery passport scope, QR-code access, responsible economic operator duties, access categories, Annex XIII data fields and Article 78 technical operation.
Supports the battery-specific scope, access and interoperability points used in this comparison.
Articles 77 and 78 and Annex XIII support the scope, QR code, identifier, data, access, lifecycle, interoperability, and 18 February 2027 implementation steps.
Show 19 more
Article 77(1) identifies the battery categories that must have a battery passport.
Supports the battery-specific classification step for LMT, industrial and electric vehicle batteries.
Article 77(3), (4) and (7) assigns the identifier and accuracy duties and sets the responsibility transfers after preparation for re-use, preparation for repurposing, repurposing, remanufacturing, or waste status.
Supports assigning the finished battery passport to the responsible economic operator rather than treating component suppliers as the legal passport owner.
Annex XIII lists the public and restricted information categories for the battery passport.
Supports keeping a battery-specific Annex XIII data map rather than copying a generic DPP field list.
Article 77 and Annex XIII define public, point 2 and point 3 restricted, and legitimate-interest access categories for battery passport information.
Supports treating battery passport access as a restricted rights model rather than an all-public label.
Article 77(3) links the battery passport to the Article 13(6) QR code and ISO/IEC 15459 unique-identifier standards.
Supports treating the battery QR code as a Batteries Regulation requirement, not a generic DPP design preference.
Article 78 requires technical, semantic and organisational interoperability with other Union ecodesign digital product passports.
Supports the statement that battery passport interoperability is a technical and organisational compatibility duty, not a merger of regimes.
Article 77 allocates accuracy duties, sets lifecycle responsibility transfers after the specified second-life operations or waste status, and ends the passport after recycling.
Supports battery-specific controls for status changes and recycling.
Supports keeping battery-specific Article 77 data and access requirements separate from generic DPP architecture choices.
Supports the battery side of a crosswalk covering Article 77 and Article 78 obligations.
Article 77 establishes the battery passport and Annex XIII sets the battery-specific information and access categories.
Supports using the Batteries Regulation as the controlling source for battery passport duties.
Supports using Article 77 and Annex XIII as the first source for covered battery passport decisions.
"battery passport"
More quoted passages
"fully interoperable with other digital product passports"
"From 18 February 2027"
"industrial battery with a capacity greater than 2 kWh"
"accurate, complete and up to date"
"economic operator placing the battery on the market"
"material composition of the battery"
"information relating to the battery model"
"persons with a legitimate interest"
"access to information"
"accessible through the QR code"
"Article 13(6)"
"fully interoperable"
"end-to-end communication and data transfer"
"shall cease to exist after the battery has been recycled"
Primary source for ESPR digital product passport framework rules, including product-group delegated acts, data carriers, unique product identifiers, access rights, service providers and interoperability.
Supports the ESPR framework points on product-group delegated acts, data carriers, access rights and interoperability.
Articles 4, 9 and 18 establish the delegated-act and work-planning process for product-specific ESPR requirements.
Show 15 more
Articles 27 to 34 allocate manufacturer, authorised representative, importer, distributor, dealer, fulfilment-service-provider, and online-marketplace duties; Article 13 assigns registry upload to the operator placing the product on the market or putting it into service.
Annex III lists the data elements that product-group delegated acts may require or allow in ESPR passports.
Supports using the ESPR field list as a product-group-dependent framework rather than a universal schema.
Article 11 ties ESPR DPP access to the access rights specified in the applicable product-group delegated act.
Supports separating ESPR product-group access rights from the Batteries Regulation Annex XIII access model.
Article 10 connects the ESPR DPP through a data carrier to a persistent unique product identifier.
Supports the broader ESPR data-carrier framing for product groups outside the battery-specific Article 77 rule.
Supports the wider DPP ecosystem requirements for open, interoperable passport operation and the central registry's storage of battery unique identifiers.
Article 10 requires backup copies through a DPP service provider, and Article 11 sets availability and service-provider processing limits.
Supports the ESPR service-provider and delegated-act availability model.
Supports waiting for product-group delegated acts before locking non-battery ESPR DPP content and access rights.
Supports the ESPR side of a crosswalk covering product-group DPP requirements under Articles 9 to 11.
Article 9 makes the ESPR DPP depend on product-group delegated acts rather than one universal data sheet.
Supports treating ESPR as a horizontal framework whose concrete DPP content is set by delegated acts.
Supports checking ESPR product-group delegated acts before treating a non-battery product passport as mandatory.
"digital product passport"
More quoted passages
"product groups"
"economic operator placing the product on the market"
Binding implementation arrangements for the DPP registry, effective from 6 August 2026, including verification, registration, APIs, identifiers, access management, the semantic repository and logging.
Registry implementation arrangements effective 6 August 2026, including user verification, registration, APIs, unique registration identifiers, access management, semantic repository, and logging.
Binding implementation arrangements for the DPP registry, published 17 July 2026 and effective from 6 August 2026, including registration, verification, identifiers, access management, semantic repository, API, and logging.
Current implementation schedule for product-specific DPP acts and the indicative Q4 2026 timing shown for the battery access-right implementing act.
Current Commission implementation timeline, including the live registry, 18 February 2027 battery deadline, and indicative Q4 2026 timing for the battery access-right implementing act.
Current Commission implementation schedule for product-specific DPP acts, including iron and steel, energy-related products, textiles, tyres, aluminium, furniture, mattresses, ICT products and recycled content.
Current Commission status source for the 20 July 2026 registry and testing-environment launch and the decentralised storage model.
Commission announcement that the registry and testing environment launched on 20 July 2026, with complete product data kept in the decentralised DPP system.
Commission implementation page stating that the passport obligation lies with the operator placing the finished battery on the market, rather than suppliers of individual components or modules.