For many organizations, the next major European Union (EU) compliance deadline may already be sitting inside their products, equipment, or supply chains.
Beginning February 18, 2027, certain batteries placed on the EU market or put into service will need Digital Product Passports (DPPs) under the EU Batteries Regulation (EU) 2023/1542. The requirement is designed to make information about batteries more accessible throughout their lifecycle, supporting greater transparency, traceability, responsible sourcing, and circularity via a product QR code.
The deadline is approaching quickly, but the greater concern is the work required before a DPP can be created. Organizations may need to bring together information held across suppliers, sustainability functions, compliance systems, and information technology (IT) platforms. But the challenge will be locating, validating, governing, and maintaining the information behind the QR code. Supplier engagement, data ownership, traceability, and internal accountability must be addressed before technology can deliver an effective battery DPP.
What is an EU battery DPP?
A battery DPP is a digital record associated with an individual battery. It provides access to information about the battery’s identity, composition, performance, sustainability characteristics, and lifecycle.
From February 18, 2027, battery DPPs will be required for:
- Electric vehicle (EV) batteries.
- Light means of transport (LMT) batteries, such as those used in e-bikes and e-scooters.
- Industrial batteries with a capacity greater than 2 kilowatt-hours (kWh).
The DPP will be accessible through a QR code linked to a unique identifier.
Not every battery will require a DPP. Portable batteries, conventional starting, lighting, and ignition batteries, and industrial batteries at or below 2 kWh, fall outside the battery DPP requirement. However, separate QR code requirements under the Batteries Regulation will apply more broadly.
Determining which batteries are in scope, which legal entities place them on the EU market, and which obligations apply is an important first step toward readiness.
A battery DPP is more than a QR code
It would be easy to view the requirement as a labelling or technology project, but that misses the larger challenge.
The QR code is simply the doorway to the information.
Depending on the battery and applicable requirements, DPP information can include details relating to manufacturing, battery chemistry, material composition, carbon footprint, responsible sourcing, recycled content, performance, expected lifetime, state of health, repair and disassembly, and end-of-life management.
Some information will be publicly available, while other data will have restricted access.
This creates a broader operational challenge: Where does the information come from? Who owns and validates it? How will it be protected, updated, and maintained throughout the battery’s lifecycle?
For many organizations, the answer will cross several functions.
Supply chain visibility will be critical
Organizations responsible for battery DPP compliance may not own all of the information required to support it.
Battery manufacturers can depend on cell, module, material, and other upstream suppliers for critical data. The EU Batteries Regulation also requires relevant suppliers to provide manufacturers with information and documentation needed to demonstrate compliance.
This makes supplier readiness an important part of DPP readiness.
Organizations should consider whether they can consistently connect supplier evidence to the correct battery, model, material, and version. They should also determine whether suppliers understand future data expectations and can provide information in a reliable, consistent, and usable format.
Late supplier engagement may leave organizations with limited time to resolve missing information, unclear ownership, inconsistent formats, or unsupported claims.
For companies with complex or global supply chains, February 2027 is as much a traceability challenge as it is a digital one.
Who is responsible for the battery DPP?
Under the regulation, responsibility sits with the economic operator placing the battery on the EU market or putting it into service. That operator is responsible for ensuring the DPP information is accurate, complete, and up to date, although another party may be authorized to act on its behalf.
This distinction matters for organizations outside the EU as well.
A non-EU-based company may not consider itself directly affected by European regulations, but if its batteries or battery-containing products enter the EU market, the organization should understand its role in the value chain and the information its European partners may require. The broader Ecodesign for Sustainable Products Regulation (ESPR) framework applies to products placed on the EU market, whether produced within or outside the EU.
Using a technology provider to host or manage DPP information also does not remove the need for reliable product data, supplier traceability, strong governance, and clear accountability. Technology can help deliver the DPP, but it cannot resolve unidentified data gaps or unclear ownership on its own.
Why organizations should start preparing now
The EU has moved from policy development into implementation. The DPP Registry became operational on July 20, 2026, and acts as the indexing service for DPPs of products placed on the EU market. It stores unique identifiers, registration data, and high-level metadata rather than the complete product information contained in each DPP.
Organizations do not need every technical detail to begin preparing. Waiting for every requirement to be finalized could leave insufficient time to engage suppliers, evaluate data quality, establish governance, resolve traceability gaps, and align internal systems and stakeholders.
A practical starting point is to ask:
- Which batteries in our portfolio fall within scope?
- Which legal entities place those batteries on the EU market?
- What information will we need?
- Where does that information currently reside?
- Which data depends on suppliers?
- Who owns and validates the information internally?
- Can our existing systems support ongoing updates and controlled access?
Battery DPPs are only the beginning
The battery DPP is also an early indication of a broader shift in EU product regulation.
Under the ESPR, DPPs are expected to expand into additional product groups as product-specific requirements are adopted.
For business leaders, battery DPP readiness is a preview of what’s coming across other products and sectors:
- Iron and steel in 2026: The Commission is targeting the fourth quarter of 2026 to adopt product-specific requirements.
- Textile apparel, aluminum, and tyres (tires) in 2027: Product-specific delegated acts are currently targeted for the third and fourth quarters of 2027.
- Furniture in 2028: Product-specific requirements are scheduled for indicative adoption in 2028.
- Mattresses and information and communication technology (ICT)/electronics in 2029: The Commission’s roadmap points to mattresses and measures covering ICT and electrical and electronic products in 2029, although final scope and DPP requirements remain to be determined.
- Construction products in 2027 under a separate regulatory track: The Commission is targeting the second quarter of 2027 for the delegated act establishing the construction-product DPP system. The exact compliance date will follow that act.
As a result, organizations should develop these capabilities now: better product data, stronger supplier traceability, clearer ownership, and more consistent data governance to be ready for expanding digital product requirements.
The February 2027 deadline is a test of whether organizations can provide trusted, traceable, and compliant product information across their products, suppliers, and value chains when regulators, customers, and business partners require it.
BSI Consulting helps organizations assess DPP requirements, identify product and supplier data gaps, strengthen traceability and governance programs, engage suppliers, and develop practical implementation roadmaps that support both compliance and broader sustainability objectives.
