Digital Product Passports backed by 3E regulatory intelligence

EV batteries, light means of transport (LMT) batteries, and industrial batteries over 2 kWh need a battery passport when they’re placed on the EU market or put into service. Portable and SLI (starting, lighting, ignition) batteries don’t need one, but other parts of the EU Battery Regulation still apply to them.

The battery passport is required from Feb. 18, 2027. Other obligations phase in around it: due diligence starts Aug. 18, 2027, generally for operators with turnover of €40 million or more, and recycled content requirements begin from Aug. 18, 2028, or later.

Under the EU Battery Regulation, the operator that places the battery on the EU market or puts it into service is responsible for the battery passport. That can be the manufacturer, an EU importer, an own-brand importer or distributor, or a remanufacturer. With written authorization, another party, such as a non-EU manufacturer, can create or update the passport, but legal responsibility stays with the operator placing the battery on the market.

Often, yes. Under the EU Battery Regulation, the battery passport belongs to the finished battery, not its cells or modules, unless they’re sold for end use as batteries. Cell and module suppliers must still provide necessary information and documentation to manufacturers free of charge, and other component and material suppliers hold data their customers need to comply.

3E’s team can talk through your battery regulation requirements, the supplier data you’ll need, and how 3E Exchange supports supplier data collection and Digital Product Passports today.