Battery Passport Requirements for February 2027: What Can Wait
The EU battery passport becomes mandatory on 18 February 2027, but not every field does. The Commission's FAQ and its data point guidance (version 3.2) say carbon footprint, recycled content and due diligence information will not yet be required. Here is what a passport needs on day one, and which common claims to check.
On 10 November 2026 the automotive news site Gasgoo published a long piece on how Chinese battery makers are preparing for the EU: Battery Passport Countdown: A Major Test for Supply Chain Data. Its central point holds up: the hard part of a battery passport is getting data from upstream suppliers.
Some of its statements about day one do not match what the European Commission has published. The article describes a passport "verified at customs through a unique identifier", a layer of carbon footprint, recycled content and due diligence data, and "90 data points". The Commission's EU Digital Product Passport FAQ for Batteries (1st edition, manuscript completed in September 2026) and its data point guidance (version 3.2, 19 October 2026) give a narrower picture of what a passport must contain on 18 February 2027.
What is required in the battery passport on 18 February 2027?
From 18 February 2027, LMT batteries, industrial batteries above 2 kWh and electric vehicle batteries placed on the EU market need a battery passport (Regulation (EU) 2023/1542, Article 77). The passport is mandatory from that date, but not every field in it is.
The FAQ answers the question directly (Q7.1): "No. Some fields apply only to certain types of battery or only where technically relevant." Other fields are linked to obligations that will not yet apply in February 2027.
The Commission's guidance lists 71 data points and marks each one per battery category. In version 3.2, the points mandatory from February 2027 are:
| Battery category | Mandatory data points from February 2027 (of 71) |
|---|---|
| Electric vehicle batteries | 45 |
| LMT batteries (e-bikes, scooters) | 48 |
| Industrial batteries above 2 kWh | 31 |
Other points are optional or apply only in certain cases, for example to rechargeable batteries or to batteries with a battery management system. Earlier editions of the guidance were summarised with different numbers, so always check the version and date. The full count per point is in our article on battery passport data points.
Dynamic data, such as state of health and number of cycles, is expected to apply from February 2027 (FAQ Q8.1). For a new imported battery that has never been used, the FAQ (Q4.2) says the fields about use "may be empty" at registration, and this "does not prevent the Battery Passport from being registered".
Which battery passport requirements can wait?
The FAQ (Q7.2) is explicit: "Carbon footprint, recycled content and due diligence information will not yet be required." Those requirements have their own application dates, and passports created from February 2027 will contain that information only for batteries placed on the market after each obligation applies.
The guidance marks 8 data points as not to be filled or displayed as of February 2027, for every battery category:
| Data points (guidance 3.2) | Why not yet |
|---|---|
| 17 and 18: carbon footprint declaration and carbon footprint label | The format is still to be set in upcoming implementing acts |
| 19: information on responsible sourcing (due diligence report) | Required from August 2027, as foreseen by Article 48 of the Regulation |
| 20 to 23: recovered shares of cobalt, lithium, nickel and lead | They apply as foreseen by Article 8 and the related delegated act |
| 45: instructions for use | Application on hold pending the adoption of the Omnibus |
The share of renewable content (point 24) is a different field from recycled content, and it is mandatory for all three categories from February 2027.
The FAQ (Q7.3) adds that supply chain data "may need to be collected to calculate or substantiate the results", even though the full set of data does not go directly into the passport. Supplier data collected now will still be needed when these obligations apply.
Five battery passport claims to check against the FAQ
The statements below appear in articles and vendor pages, including the Gasgoo piece.
| Claim | What the Commission says |
|---|---|
| The passport is verified at customs through its identifier | FAQ Q4.1: the registration identifier is required in the customs declaration for ESPR passports, "it is not required for Battery Passports". The passport must still be registered in the DPP Registry. |
| Carbon footprint, recycled content and due diligence from day one | FAQ Q7.2: "will not yet be required". The due diligence report comes from August 2027 (Q7.3). |
| You have to fill in about 90 data points | The guidance 3.2 lists 71 data points; 31 to 48 are mandatory from February 2027, depending on the category. |
| Every cell needs its own identifier | Article 77(3) links the QR code to a unique identifier for the battery. One passport per battery; see does every battery cell need a passport? |
| Dynamic data must be captured in real time | FAQ Q8.4: "Real-time or very frequent communication is not necessarily required." The minimum is to make the information available when a change of status is considered. |
Why supplier data still decides the timeline
On supplier data, the Gasgoo piece is useful. It describes how CATL took part in all three Global Battery Alliance pilot rounds, how Sunwoda set up a dedicated battery passport team in November 2023 and connected its platform to the EU DPP Registry test environment by mid 2026, and how Sunwoda captures over 70% of its internal data automatically, with the rest coming from supplier reporting and manual entry. "The real black hole lies upstream," the article says.
That matches the Commission's text. The economic operator placing the battery on the market stays responsible for the passport and its data, even when another company creates or updates it with written authorisation (FAQ Q2.1). Who does what is covered in who is responsible for the EU battery passport.
What to do before 18 February 2027
- Find your category: EV, LMT or industrial above 2 kWh. Each has its own mandatory list.
- Work from the mandatory list in guidance 3.2, then add the conditional points that apply to your battery (rechargeable, battery management system, already in use).
- Leave the 8 "not yet" points empty, and keep the supplier data behind them: carbon footprint calculations, recycled content and sourcing records will be needed when those obligations start.
- Plan the registration in the EU DPP Registry. The identifier is not entered in the customs declaration.
- Put authorisations in writing if a supplier, a cell maker or a software provider will create or update the passport for you.
Digital product passport software for SMEs
When we rebuilt our battery template on guidance 3.2 at the end of October 2026, the 8 points marked "not to be filled as of February 2027" got no input field, so an empty carbon footprint box never looks like a gap. Hoken Pass is digital product passport software for SMEs, with a battery passport template built on that guidance.
Frequently asked questions
Is carbon footprint required in the battery passport in February 2027?
No. The Commission's FAQ (Q7.2) says carbon footprint, recycled content and due diligence information will not yet be required when battery passports are introduced in February 2027. The format of the carbon footprint declaration and label will be set in implementing acts.
How many data points are mandatory in the battery passport from February 2027?
According to the Commission guidance version 3.2 (19 October 2026), 45 of 71 data points are mandatory for electric vehicle batteries, 48 for LMT batteries and 31 for industrial batteries above 2 kWh. Some conditional points add to these depending on the battery.
When is the due diligence report required in the battery passport?
From August 2027, according to the Commission FAQ (Q7.3), in line with Article 48 of Regulation (EU) 2023/1542.
Does the battery passport identifier go in the customs declaration?
No. FAQ Q4.1 says this is required for passports under the ESPR but not for battery passports. The battery passport must still be registered in the EU DPP Registry.
Sources
- European Commission: EU Digital Product Passport FAQ for Batteries, 1st edition (September 2026)
- European Commission: Digital Batteries Passport, data points by category, version 3.2 (19/10/2026), PDF
- Regulation (EU) 2023/1542 on batteries and waste batteries (EUR-Lex)
- Gasgoo: Battery Passport Countdown, A Major Test for Supply Chain Data (10/11/2026)
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