| Scope boundary | 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 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. | 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. |
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| Covered actors | 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. | 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. | 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. |
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| Data fields and schema | 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. |
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| Core obligations | 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. |
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| Evidence record | 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. 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. |
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| Interoperability, registry and timing | 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. | 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. | 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. |
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| Enforcement | 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. | 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. |
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| Overlap and reuse | 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. | 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. |
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| Practical decision rule | 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. |
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