Battery DPP — Regulation (EU) 2023/1542

The battery passport is the most fully-specified DPP category in force today. Regulation (EU) 2023/1542 (the "EU Battery Regulation" or EUBR) prescribes the passport at Annex XIII in unusual specificity, with hard deadlines rather than the more common "delegated act to follow" pattern. Any brand placing batteries on the EU market needs a compliance plan grounded in that annex.

This guide walks the regulation's scope, the passport data Annex XIII lists, and the practical implementation on DPP Agent.

Regulatory anchor

The EUBR entered into force in August 2023 and covers all batteries placed on the EU market — portable, SLI (starter / lighting / ignition), LMT (light means of transport), industrial and electric-vehicle traction. Most articles apply across the whole regulation (removability under Article 11, recycled-content thresholds under Article 8, hazardous-substance rules), but the Digital Battery Passport requirement in Article 77 is narrower.

Article 77 passport scope

Article 77(1) puts the passport requirement on three categories only:

• LMT batteries — e-bikes, e-scooters, e-mopeds, and other light-means-of-transport packs
• Industrial batteries with capacity above 2 kWh
• EV traction batteries

Portable batteries (heated-gear packs, power tools, camera batteries, consumer electronics) and SLI batteries (automotive 12 V starter batteries) are outside Article 77's passport requirement. Brands may still issue DPPs for them for consumer trust or supply-chain traceability — DPP Agent supports them at any granularity — but there is no regulatory obligation to serialise every unit or to publish a passport at all.

Deadlines:

• 18 February 2027 — the Article 77 passport applies to the three in-scope categories above
• 2028 — expanded performance and durability disclosures under Annex VII come into effect

Critical implementation detail (in-scope batteries only): for the three categories in Article 77 scope, the passport is item-level, not model-level. Every individual battery placed on the market must have its own passport with a unique serial number. This is fundamentally different from textiles (typically SKU or batch-level) and drives the technical architecture of any in-scope battery-passport implementation. Portable and SLI batteries, being outside Article 77, may use model, batch or item granularity as the brand chooses.

The identifier, and which standard it follows

Article 77(3) is short and often misread. It requires the unique identifier to comply with ISO/IEC 15459, and the data carrier carrying it to comply with ISO/IEC 15418 and ISO/IEC 15434. It does not name GS1.

That distinction matters, because ISO/IEC 15459 is a registration standard with several issuing agencies. GS1 is one. ODETTE, the automotive industry's own body, is another; EHIBCC serves healthcare. A GTIN with a serial is conformant. So is an ODETTE-issued identifier. So is a manufacturer-assigned identifier under an agency code the manufacturer holds.

GS1 Digital Link is therefore a conformant route, not the prescribed one. It is the route most consumer-facing passports take, because a GS1 Digital Link URL is both an identifier and a working web address — one string does the resolving and the identifying. For a battery on a shelf with a QR code that is a real advantage. For a battery inside an industrial installation, exchanged machine-to-machine between an OEM and a recycler, it is not necessarily the deciding factor.

DPP Agent resolves seven address forms, and a tenant picks one:

"Item level only": an Identification Link without EN IEC 61406-2 data identifiers identifies individual items (EN 18219 §5.3.2.1). A battery passport is one per battery, so that fits; a model-level passport on such an address does not.

A brand that already has an issuing-agency code does not need to buy a GS1 prefix to publish a conformant passport. A brand with no scheme at all will usually find GS1 the shortest path, which is why it is the default rather than the requirement.

Passport data model

Battery DPPs use the bat.* namespace alongside the horizontal espr.* fields every category shares. Annex XIII enumerates the passport data explicitly, in four numbered points that also decide who may read each field.

Sixty-five fields, listed below exactly as the platform defines them. The Annex XIII column is the citation the field carries in our schema, so a mapping written against this table is a mapping the API accepts. Where a field is restricted, the audience is named — those fields are never rendered on the public page, whatever a template asks for.

Two conventions worth knowing before you read the table. bat.category takes one of the five Article 3 categories — PORTABLE, SLI, LMT, INDUSTRIAL, EV — and it decides whether Article 77 applies at all. And numeric fields carry their unit in the field name rather than in the value: send 28 to bat.rated_capacity_ah, not "28 Ah".

Battery Identification

Economic Operator

Materials

Specifications

Carbon Footprint

Performance & Durability

Supply Chain

End of Life

Compliance

Restricted — Legitimate Interest

Restricted — Authorities

Fields not listed here are not part of the battery schema. If you need one that is missing, say so rather than overloading a neighbouring field — a value in the wrong field scores as present and reads as false.

The requirements split by battery type, not only by category

The Commission published a guidance document on 15 August 2026 — Digital Batteries Passport: data points by category, version 2.0 — which lists 71 data points and states, for each one, whether it is to be filled, optional, applicable only in certain cases, or not to be filled as of February 2027, in a separate column for EV, LMT and industrial batteries. The requirement levels in the tables above follow that document, and the dp numbers in the Status column are its data point numbers. "Listed" means the data point is to be filled for that battery type. It is guidance, not law: it does not extend the Regulation, and where the two appear to disagree the Regulation governs.

Three of its columns are worth stating plainly, because they cost work that does not have to be done yet:

• The carbon footprint declaration and label (dp 17–18), the four recycled content shares (dp 20–23) and the material composition repetition (dp 16) are not to be filled or displayed as of February
  2027. The formats come in implementing acts that do not exist yet.
• Responsible sourcing (dp 19) is to be filled from August 2027, not February.
• For industrial batteries, cycle-life figures, round-trip efficiency and C-rate apply only to some of them — those whose lifetime can be expressed in cycles. A stationary storage system that cannot is not failing by leaving them empty.

Two places in the Regulation ask different things of different battery types, and both are easy to miss because every one of them is still a battery.

Annex VII Part A, reached through Article 14 and Annex XIII 4(b), divides in the text itself:

For electric vehicle batteries: state of certified energy (SOCE).

For stationary battery energy storage systems and LMT batteries: the remaining capacity; where possible, the remaining power capability; where possible, the remaining round trip efficiency; the evolution of self-discharging rates; where possible, the ohmic resistance.

State of certified energy is therefore the electric-vehicle parameter. A stationary energy-storage system reports five different ones, and asking it for SoCE asks for a figure its own regulation does not define for it. The three qualified by "where possible" stay encouraged even for the types they apply to; the other two do not carry that qualifier and are to be filled.

Annex XIII 1(k), the capacity threshold for exhaustion, says "only for electric vehicle batteries" in its own text.

The platform reads bat.category — one of PORTABLE, SLI, LMT, INDUSTRIAL, EV from Article 3 — and resolves each field's requirement level against it. Set it when the passport is created. It is not only a label: it decides whether Article 77 applies at all, and which of these parameters you will be measured against. A passport created without it is scored against the base level, which is deliberately the one that never demands a type-specific field.

One caveat we cannot resolve from the data alone: "stationary battery energy storage system" is not one of the five Article 3 categories. A stationary system is an industrial battery, so INDUSTRIAL is what the platform treats as stationary. An industrial battery that is not stationary falls outside Article 14 entirely, and that distinction is not readable from bat.category — if that is your case, read Article 14(1) rather than trusting the level shown.

The machine-readable passport

Three JSON representations are served by content negotiation, and which one you want depends on what you are building.

The third is the one to build against for a battery. Its blocks follow Annex XIII rather than a generic product model, each block names the annex point it answers, and each field carries its own citation:

{
  "@schema": "eubr-2023-1542",
  "regulation": "Regulation (EU) 2023/1542",
  "batteryCategory": "INDUSTRIAL",
  "articleScope": "Article 77 passport applies",
  "materials": {
    "@citation": "Annex XIII 1(b) · 1(e) · 1(f)",
    "bat.chemistry": { "value": "NMC", "citation": "Annex XIII 1(b)" }
  },
  "specifications": {
    "@citation": "Annex XIII 1(g) · 1(h) · 1(i)",
    "bat.rated_capacity_ah": { "value": 28, "unit": "Ah", "citation": "Annex XIII 1(g)" }
  }
}

Four properties are deliberate:

batteryCategory and articleScope come first. The Article 3 category decides whether Article 77 applies at all and which Annex VII parameters are measured, so it is not buried in a block.

A field with no published value is absent, not null. An empty field is a work item; a null in a public document also tells a reader that a value exists somewhere they cannot see it.

Units belong to the field. The Annex specifies them — capacity in Ah, power in watts — so they are carried as unit, never folded into a string.

Annex XIII points 2, 3 and 4 are not served here. The public resolver authenticates nobody, so there is no reader whose legitimate interest it could assess — and without that assessment any disclosure is the wrong one. See the next section.

Mapping this to IDTA 02035's seven AAS submodels is close to mechanical, because those submodels are organised around the same annex.

Who may read what

Article 77(2) is the part of the battery passport that has no equivalent in a product page: the passport has three audiences, and most of Annex XIII is not public.

• Annex XIII point 1 — the general public. Article 77(2)(a). Identification, chemistry, capacity, voltage, weight, recycled content, carbon footprint, collection information.
• Annex XIII point 2 — notified bodies, market surveillance authorities and the Commission and anyone with a legitimate interest. Article 77(2)(b) and (c) both reach it. Detailed composition, part numbers, dismantling instructions, safety measures.
• Annex XIII point 3 — notified bodies, market surveillance authorities and the Commission only. Article 77(2)(b). Test reports.
• Annex XIII point 4 — legitimate interest only. Article 77(2)(c). The individual battery's state of health, status, completed cycles, negative events, operating conditions, and the Article 10(1) performance values.

"Legitimate interest" is defined narrowly by the Article's third subparagraph: dismantling and detailed composition where that is essential for repairers, remanufacturers, second-life operators and recyclers; or, for an individual battery, where it is essential to the purchaser making it available to energy aggregators or market participants. It is not a self-declared status, and the operator placing the battery on the market carries Article 77(4) responsibility for the record either way.

In DPP Agent every battery field carries the tiers entitled to it, taken from the Annex XIII point it cites. Restricted fields are filtered before the page is rendered rather than hidden in it, so a restricted value is never in a document that could be cached or printed.

Sourcing the data

Battery data typically comes from four sources:

• Cell / pack manufacturer — chemistry, performance, safety data. Often the same entity that produced the battery for the brand or in a tight OEM relationship.
• Brand PLM — model-level metadata, pack integration, product-family lineage
• MES (manufacturing execution system) — per-unit serial and manufacturing telemetry (production date, calibration curves, initial state-of-health baseline)
• Third-party lab — carbon footprint verification, cycle-life testing, UN 38.3 certification

The MES-to-passport connection is the hardest and the most valuable. DPP Agent's item-level DPP architecture (async serialization ingestion, up to 100k+ items per sync, quantity-driven serialization for whole production runs) is designed to handle it. Common integration patterns: MES emits a per-battery JSON via webhook on completion of quality-check station; DPP Agent's inbound webhook receiver validates against bat.* schema and creates or updates the item-level DPP.

Item-level architecture for in-scope batteries

For batteries in Article 77 scope (LMT, industrial >2 kWh, EV traction), a model-level passport does not satisfy the regulation. Article 77 requires per-unit state-of-health, recycled-content data traceable to individual cells, and lifecycle events tied to a specific serial. Brands that try to shortcut with a shared passport per model will fail conformity assessment on these categories.

Portable and SLI batteries are outside this requirement. Brands can choose model, batch or item granularity based on their own traceability needs — a small heated-gear brand may pick model-level with the option to switch to batch when a specific production run has different sourcing or certification.

DPP Agent's item-level DPP subsystem is category-designed for the in-scope cases. Each battery gets its own row keyed on (GTIN, batch, serial). Async ingestion handles the volume: a mid-size battery pack manufacturer producing 500 units per shift generates hundreds of thousands of DPPs per year. The batch print-run system emits QR labels bound to serials at the point of packaging.

Consumer-facing considerations

Battery consumers — e-bike riders, EV owners, industrial operators, second-life buyers — want:

• What is the current state of health?
• Is this battery safe to charge / transport / dispose of?
• Where do I take it when it's done?
• If I'm buying second-hand, is the history genuine?

The DPP Agent battery template surfaces state-of-health at the top (fresh from MES ingestion or read from a BMS on scan where available), safety and transport guidance in a scannable card, EOL routing with the nearest take-back location, and the full manufacturing + lifecycle timeline for the "is this second-hand claim real" question.

AAS, IDTA 02035 and Catena-X

A European automotive or industrial battery programme is unlikely to describe its passport as a web page. It will describe it as an Asset Administration Shell.

The AAS is the Industry 4.0 model for a digital twin: an asset carries a shell, the shell holds submodels, and each submodel is a standardised block of properties with its own identifier. IDTA 02035 is the Digital Battery Passport specification in that model — published March 2026 by the Industrial Digital Twin Association, it defines the battery passport as seven AAS submodels covering identification, technical data, carbon footprint, materials, performance, due diligence and end of life.

Catena-X is the automotive data space those shells move through. It supplies the identity layer (BPN, Business Partner Number, for each participant), the connector (EDC, Eclipse Dataspace Connector) and the governance under which one company grants another access to a specific submodel of a specific asset. Manufacturing-X is the same pattern generalised beyond automotive.

The two worlds are not competitors and a battery programme usually needs both. The AAS answers how does a recycler's system read the dismantling submodel of this specific pack. The Digital Link URL answers what happens when a person scans the label. The same Annex XIII data sits underneath.

What DPP Agent does and does not do here

Stated plainly, because the difference matters when you are comparing platforms:

What works today. The full Annex XIII field set, with the Article 77(2) audience tiers enforced at render time rather than in the page. Item-level passports at production volume. GS1 Digital Link and five other identifier schemes. The REST API below, which returns the same data an AAS submodel would carry, in JSON.

What does not exist. There is no AAS serialisation, no IDTA 02035 submodel export, no EDC connector and no BPN handling in DPP Agent today. A Catena-X participant cannot point their connector at us and receive a shell. What they can do is read the REST API and map it — every Annex XIII field is exposed and the mapping to the seven submodels is mechanical, but it is work that currently lands on the customer's side.

If a battery programme's requirement is written as "must publish AAS submodels into Catena-X", DPP Agent does not meet it as it stands. If the requirement is "must produce a conformant Article 77 passport, and feed our own data layer", it does. Ask which one you are looking at before comparing.

The EU DPP Registry

Batteries are not one product group among several in the EU's DPP Registry — as of today they are the only one. The Registry opened on 20 July 2026 under Regulation (EU) 2026/1778, and the Batteries product group is the only one live, with Item pre-selected as the granularity.

Today the Registry onboards and verifies economic operators. Registering a passport is not yet possible for anyone: the Helpdesk has said the Registry's APIs and semantic validation are planned for Q4 2026. Getting your company verified now is the step worth taking, because it has a lead time you do not control.

See the EU Registry status guide for what we have verified about registration, what the Helpdesk has confirmed, and the DPP service provider question — which, note, may never apply to batteries at all: the service-provider role exists under ESPR and is not a defined actor in the Battery Regulation.

Common pitfalls

• Assuming Article 77's passport requirement covers portable or SLI batteries — it does not. Only LMT, industrial >2 kWh, and EV traction.
• Model-level passport for an in-scope battery instead of per-unit — disqualifying for the whole product line
• Missing SCIP identifiers for regulated substances
• Recycled-content declared but not verified per Annex II
• Carbon footprint calculated but not third-party verified
• Second-life eligibility flagged inconsistently between the passport and the BMS
• SoH algorithm not disclosed — second-life buyers can't trust the score
• Chemistry-string errors (e.g. "NMC" without specifying cathode ratio — NMC-111 vs NMC-622 differ materially)

Practical checklist (in-scope batteries)

The following applies to LMT, industrial >2 kWh, and EV traction batteries under Article 77. Portable and SLI batteries do not need to satisfy this checklist, though brands may still choose to.

• Every in-scope battery has a unique identifier conformant with ISO/IEC 15459, carried per ISO/IEC 15418 / 15434 — a GS1 Digital Link with serial (/01/GTIN/21/SERIAL) is the usual form, but see the identifier section before assuming it is the only one
• Manufacturing serial + production date recorded at MES level and propagated to the DPP
• Cell chemistry expressed with cathode-ratio precision (NMC-622, LFP, NCA)
• Critical raw material declarations (Co / Li / Ni / natural graphite)
• Carbon footprint per kWh useful energy, third-party verified
• Recycled content per raw material, methodology declared
• Safety and transport section covers UN 38.3, thermal-event first-aid
• EPR registration + take-back path present per member state
• Second-life eligibility clearly declared with SoH baseline
• Item-level DPP resolution has been tested at production volume (async ingestion path)

Regulatory reference

• Regulation (EU) 2023/1542 — EU Battery Regulation
• Article 77(3) — ISO/IEC 15459 for the identifier, ISO/IEC 15418 / 15434 for the carrier
• ISO/IEC 15459 — unique identification, and the issuing agencies under it (GS1, ODETTE, EHIBCC)
• IDTA 02035 — Digital Battery Passport as seven AAS submodels (March 2026)
• Regulation (EU) 2026/1778 — the EU DPP Registry
• Annex XIII — Digital Battery Passport information requirements (the four points, and their audiences)
• Annex VII — parameters for determining state of health and expected lifetime
• Annex IV — electrochemical performance and durability parameters, referenced by Article 10(1)
• Article 49 — Supply-chain due-diligence
• Article 77 — Battery Passport requirements
• Article 8 — Recycled content thresholds
• UN 38.3 — Transport of dangerous goods
• ISO 14067 — Carbon footprint methodology
• PEFCR-battery (draft) — Category-specific carbon footprint rules