// SPOKE — BATTERY REGULATION
ESPR and the EU Battery Regulation — DPP Requirements for Batteries
The EU Battery Regulation (Regulation (EU) 2023/1542) is the first EU regulation to introduce Digital Product Passport requirements aligned with ESPR. It applies to all batteries placed on the EU market and sets DPP requirements that will enter into force from February 2027. This page explains the battery DPP requirements, the timeline, what data must be included, and what battery manufacturers and exporters must do to comply.
The EU Battery Regulation — Overview
The EU Battery Regulation (Regulation (EU) 2023/1542) entered into force on 17 August 2023, replacing the previous Battery Directive (2006/66/EC). It is the most comprehensive battery regulation in EU history and introduces requirements for sustainability, safety, labelling, and end-of-life management across all battery categories. The Battery Regulation is aligned with ESPR and introduces DPP requirements ahead of the ESPR delegated act programme, making batteries the first product group subject to EU DPP requirements.
The Battery Regulation applies to all batteries placed on the EU market, regardless of whether they are incorporated into products or sold separately. The regulation covers five battery categories: portable batteries, light means of transport (LMT) batteries (e.g., e-bike batteries), starting, lighting, and ignition (SLI) batteries, industrial batteries, and electric vehicle (EV) batteries. Different requirements apply to different battery categories, with the most stringent requirements applying to industrial batteries and EV batteries.
Battery DPP Requirements — Timeline
| Battery Category | DPP Required From | Key DPP Data |
|---|---|---|
| Industrial batteries ≥2 kWh (non-SLI) | 18 February 2027 | State of health, recycled content (Co, Li, Ni, Pb), carbon footprint, supply chain due diligence |
| Electric vehicle batteries | 18 February 2027 | State of health, recycled content, carbon footprint, supply chain due diligence, rated capacity |
| LMT batteries | 18 August 2027 | State of health, recycled content, carbon footprint |
| Portable batteries (general) | 18 August 2027 | Capacity, chemistry, recycled content |
| SLI batteries | 18 August 2027 | Capacity, chemistry, recycled content |
Battery DPP Data Requirements
The battery DPP must contain the data categories specified in Annex XIII of the Battery Regulation. The key data requirements are as follows.
State of health (SoH): For industrial batteries and EV batteries, the DPP must include real-time state of health data — the battery's current capacity as a percentage of its original rated capacity. This data must be updated throughout the battery's lifecycle. The SoH data enables recyclers to assess whether a battery is suitable for second-life applications before end-of-life processing.
Recycled content: The DPP must declare the percentage of recycled cobalt, lithium, nickel, and lead used in the active materials of the battery. The Battery Regulation sets minimum recycled content targets that will apply from 2031 (cobalt: 16%, lithium: 6%, nickel: 6%) and 2036 (cobalt: 26%, lithium: 12%, nickel: 15%). The DPP must declare the actual recycled content, enabling market surveillance authorities to verify compliance with these targets.
Carbon footprint: The DPP must include a carbon footprint declaration for the battery, expressed in kg CO2 equivalent per kWh of total energy provided by the battery over its expected lifetime. The carbon footprint must be calculated using the methodology specified in the implementing regulation. Carbon footprint performance classes will be introduced from 2026, and maximum carbon footprint thresholds will be set from 2028.
Supply chain due diligence: For industrial batteries and EV batteries, the DPP must include information about the supply chain due diligence policy applied by the manufacturer, including the sources of cobalt, lithium, nickel, and natural graphite used in the battery.
Battery DPP Technical Requirements
The battery DPP must be linked to the battery via a QR code that conforms to ISO/IEC 18004. The QR code must be placed on the battery or its label and must link to the DPP record in the registry. For batteries that are too small to carry a QR code directly, the QR code may be placed on the packaging. The DPP data must be accessible via a standardised API and must be available in JSON-LD format. The DPP must be accessible to market surveillance authorities, customs authorities, consumers, and recyclers throughout the battery's lifecycle.
Who Must Comply with Battery DPP Requirements
Battery DPP requirements apply to manufacturers of batteries placed on the EU market. For non-EU battery manufacturers (including manufacturers in China, South Korea, Japan, and the United States, which together account for the vast majority of batteries placed on the EU market), the formal compliance obligation falls on the EU importer. However, the practical burden falls on the manufacturer, who must provide the DPP data, implement the data carrier, and ensure that the DPP system meets the technical requirements.
Battery manufacturers who supply batteries to EU vehicle manufacturers, electronics manufacturers, or industrial equipment manufacturers will face pressure from their customers to demonstrate DPP compliance before the February 2027 deadline. EU OEMs will not be able to comply with their own ESPR obligations if their battery suppliers cannot provide DPP-compliant batteries.
Frequently Asked Questions
Industrial batteries and EV batteries require DPPs from 18 February 2027. LMT batteries, portable batteries, and SLI batteries require DPPs from 18 August 2027.
For industrial batteries and EV batteries, the DPP must include real-time state of health (SoH) data — the battery's current capacity as a percentage of its original rated capacity. This data must be updated throughout the battery's lifecycle.
The DPP must declare the percentage of recycled cobalt, lithium, nickel, and lead used in the active materials. Minimum recycled content targets apply from 2031 and 2036.
Yes. The Battery Regulation applies to all batteries placed on the EU market, including batteries incorporated into products such as smartphones, laptops, and electric vehicles.
Battery DPPs can be registered through the EU Product Database (when available) or through accredited third-party registries such as digitalproductpassports.co.za.
The EU Battery Regulation — Full Scope and Requirements
The EU Battery Regulation (Regulation (EU) 2023/1542) is the most comprehensive battery regulation in the world. It applies to all batteries placed on the EU market, regardless of where they are manufactured. The regulation covers four categories of batteries: portable batteries (batteries weighing up to 5 kg, used in consumer electronics and small appliances); light means of transport (LMT) batteries (batteries used in e-bikes, e-scooters, and other light electric vehicles); industrial batteries (batteries used in industrial applications, including stationary energy storage); and electric vehicle (EV) batteries (batteries used in electric cars, trucks, and buses).
The regulation establishes requirements across the full battery lifecycle: design requirements (minimum recycled content for cobalt, lithium, lead, and nickel; carbon footprint declaration and limits; performance and durability requirements); supply chain due diligence (responsible sourcing of cobalt, lithium, nickel, and natural graphite); end-of-life requirements (collection targets; recycling efficiency targets; recovered material targets for cobalt, copper, lithium, and nickel); and the Battery Passport (a Digital Product Passport for industrial batteries, EV batteries, and LMT batteries).
Battery Passport Requirements in Detail
The Battery Passport is mandatory for industrial batteries with a capacity above 2 kWh, EV batteries, and LMT batteries. The Battery Passport must be created before the battery is placed on the EU market and must be linked to the battery via a QR code or other data carrier. The Battery Passport must contain: battery model information (chemistry, manufacturer, manufacturing location, manufacturing date); performance and durability data (rated capacity, power capability, energy roundtrip efficiency, expected lifetime, state of health); carbon footprint data (carbon footprint per kWh of total energy throughput, calculated using the methodology specified in the regulation); recycled content data (percentages of recycled cobalt, lithium, lead, and nickel); supply chain due diligence data (sourcing information for cobalt, lithium, nickel, and natural graphite); and end-of-life data (disassembly instructions, hazardous substance locations).
The Battery Passport must be updated throughout the battery's lifecycle. When a battery is repaired, refurbished, or repurposed, the Battery Passport must be updated to reflect the new state of health and any changes to the battery's composition. This lifecycle updating requirement means that the Battery Passport registry must be capable of receiving and storing updates to DPP records over a period of 10–20 years.
Carbon Footprint Requirements for Batteries
The EU Battery Regulation introduces phased carbon footprint requirements for EV batteries and rechargeable industrial batteries. From February 2025, manufacturers must declare the carbon footprint of EV batteries and rechargeable industrial batteries using the methodology specified in the regulation. From February 2027, batteries must display a carbon footprint performance class (A, B, C, D, E, or F) based on their declared carbon footprint. From a date to be specified in a future implementing act (expected 2028–2030), batteries above a maximum carbon footprint threshold cannot be placed on the EU market.
The carbon footprint calculation must cover the full lifecycle of the battery: raw material extraction and processing; battery component manufacturing; battery assembly; distribution; use phase (including charging energy); and end-of-life treatment. The calculation must use the methodology specified in Commission Regulation (EU) 2023/1542 Annex II and the associated implementing regulation on carbon footprint calculation methodology. Manufacturers who do not have the data infrastructure to calculate battery carbon footprints to this standard will need to invest in lifecycle assessment capabilities or engage specialist consultants.
Recycled Content Requirements for Batteries
The EU Battery Regulation introduces mandatory minimum recycled content requirements for cobalt, lithium, lead, and nickel in batteries. From 2030, batteries must contain minimum percentages of recycled cobalt (12%), recycled lithium (4%), recycled lead (85%), and recycled nickel (4%). From 2035, the minimum percentages increase to 20% for cobalt, 10% for lithium, 85% for lead, and 12% for nickel. These requirements apply to all batteries placed on the EU market, regardless of where they are manufactured.
Meeting these recycled content requirements requires significant changes to battery supply chains. The current supply chain for lithium-ion batteries is dominated by virgin materials — recycled lithium and cobalt are available but at limited scale. Meeting the 2030 and 2035 targets will require substantial investment in battery recycling infrastructure and in supply chain relationships with recyclers. Manufacturers who are not engaging with recyclers and secondary material suppliers now will struggle to meet the 2030 targets.
State of Health Reporting Requirements
The EU Battery Regulation introduces mandatory state of health (SoH) reporting for EV batteries and rechargeable industrial batteries. State of health is a measure of a battery's current capacity and power capability relative to its rated capacity and power capability when new. A battery with a SoH of 80% has 80% of its original capacity remaining. SoH reporting is important for the second-life battery market — batteries that are no longer suitable for their original application (such as an EV battery that has degraded to 80% capacity) may still be suitable for less demanding applications (such as stationary energy storage).
The Battery Regulation requires that EV batteries and rechargeable industrial batteries above 2 kWh include a battery management system (BMS) that can calculate and report the battery's state of health. The SoH data must be accessible via the Battery Passport and must be updated throughout the battery's lifecycle. The regulation specifies the parameters that must be included in the SoH report: remaining capacity, power fade, internal resistance increase, number of charge-discharge cycles, and estimated remaining useful life.
Due Diligence Requirements for Battery Raw Materials
The EU Battery Regulation introduces mandatory supply chain due diligence requirements for cobalt, lithium, nickel, and natural graphite — the key raw materials used in lithium-ion batteries. From February 2025, manufacturers of industrial batteries above 2 kWh and EV batteries must implement a supply chain due diligence policy that covers: identifying and assessing risks of adverse impacts in the supply chain (including human rights violations, environmental damage, and corruption); implementing a risk management plan to address identified risks; conducting independent third-party audits of the supply chain; and reporting publicly on the due diligence policy and its implementation.
The due diligence requirements are based on the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. Manufacturers who already comply with the OECD Guidance for other purposes (such as the EU Conflict Minerals Regulation) will find that the Battery Regulation's due diligence requirements are broadly aligned. However, the Battery Regulation extends due diligence to lithium and natural graphite — materials not covered by the Conflict Minerals Regulation — and applies to a broader range of supply chain risks.
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Register Your Digital Product Passport
Compliance with ESPR begins with a registered, machine-readable Digital Product Passport. The DPP Registry at digitalproductpassports.co.za provides the infrastructure to mint, host, and verify DPP records for manufacturers and exporters supplying the EU market.
Register Your Digital Product Passport →