If you import lithium-based LMT batteries, industrial batteries above 2 kWh, or EV batteries from a manufacturer outside the EU, this piece is written for you. Not for your manufacturer, and not for an enterprise compliance department you do not have.
Your position in one sentence
From 18 February 2027, each in-scope battery you place on the EU market must carry a digital battery passport under Regulation (EU) 2023/1542 — and because your manufacturer sits outside the EU, the economic operator placing those batteries on the market is you.
That sentence does more work than it appears to. "Placing on the market" is the moment a battery is first made available in the EU. Your manufacturer, however capable, does not place anything on the EU market. You do. The obligation attaches at that moment, and it attaches to you.
What the obligation actually requires
Three things, in practical terms:
The passport must exist. Each battery you place on the market from the binding date needs a passport containing the Annex XIII information — identification, composition, carbon footprint, performance and durability, supply-chain due diligence — accessible through a data carrier on the battery.
It must be accurate. The regulation does not grade effort. A passport with wrong chemistry data or an unsupported carbon-footprint figure is a non-compliant passport, and the operator who placed the battery on the market answers for it.
It must be accessible to the right audiences. Some Annex XIII fields are public to anyone who scans the carrier. Others are restricted to persons with a legitimate interest and to market surveillance authorities. Getting the tiering wrong in either direction — publishing what should be restricted, or walling off what must be public — is itself a defect.
What your manufacturer cannot do for you
Your manufacturer can do a great deal. They hold most of the data the passport needs: the bill of materials, the cell chemistry, the manufacturing-site carbon data, the performance test results. A cooperative manufacturer can prepare all of it in good order.
What they cannot do is hold your obligation. As we set out when we mapped who owns each battery-passport data field, the split is structural: the manufacturer holds the data; the operator placing the battery on the market holds the responsibility. You can delegate the work. You cannot delegate the accountability.
This is the uncomfortable part of the importer's position, and it is better confronted in 2026 than discovered in February 2027: you are answerable for the accuracy of information you did not generate.
The data conversation to have now
The practical consequence is a supplier conversation, and the leverage in that conversation is time. Before goods ship, you have a manufacturer who wants an order. After goods land, you have a compliance gap and a supplier with your money.
The request list is knowable today: model identification and specifications, chemistry and material composition including critical raw material shares, the carbon-footprint declaration with its supporting basis, performance and durability data, and the due-diligence information Annex XIII requires. If your manufacturer cannot yet produce the carbon-footprint element — the field block that causes the most trouble, for reasons we covered in our piece on collecting carbon-footprint data — you want to know that this year, while there is still time to fix it.
Put the passport data package into your purchase terms. A manufacturer who commits to it contractually in 2026 is solving your 2027 problem at the moment your leverage is highest.
What ready looks like
Ready is not a folder of PDFs from your supplier. Ready is: each battery model's data assembled against the Annex XIII structure, gaps identified and chased while the supplier relationship has leverage in it, tiered access configured correctly, and a passport that can be issued — with its data carrier — for every unit you place on the market from the binding date.
If you want to see what the destination looks like, we publish a live demo passport — the public view, exactly as an inspector or customer would see it after scanning the carrier. It is the clearest way to turn "digital battery passport" from an abstraction into a concrete deliverable: see the demo passport.
A note on timing
There is still no accredited scheme for DPP service providers — the delegated act has slipped to Q4 2026, as we covered in June. Some importers read that as permission to wait. It is the opposite: the binding date has not moved, and the data-gathering on your side — the slow part — does not depend on anything Brussels has yet to publish. The operators in the strongest position next February will be the ones who used 2026 to get their supplier data conversations finished, not the ones who waited for the last legal instrument to land.
You do not need an enterprise traceability programme to be compliant. You need your suppliers' data, organised against Annex XIII, issued as a passport on every battery you place on the market. That is a bounded, finishable job — if it starts now.
What changed in EU battery and product-passport regulation, what it means for operators, and the dates ahead.
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Ready to be compliant by 18 February 2027?
EU Digital Passport Processor creates, hosts, and submits EU Battery Passports for manufacturers and importers. Demo accounts are available on request.