DPP Agent docs

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 VII 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 mandatory passport data, 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 — Article 77 passport mandatory for 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.

Passport data model

Battery DPPs use the bat.* namespace alongside espr.* canonical fields. Annex VII enumerates the mandatory data explicitly.

Identification (espr.pid.*, bat.pid.*)

  • espr.pid.gtin — GTIN with serial number (/01/GTIN/21/SERIAL)
  • bat.pid.battery_category — portable / LMT / industrial / EV traction / SLI
  • bat.pid.model_id — manufacturer's model identifier
  • bat.pid.date_of_placing — date the individual battery entered the market

Manufacturer + supply chain (espr.mfr.*, bat.mfr.*)

  • Battery manufacturer + cell manufacturer (may differ)
  • EORI for the economic operator
  • Supply-chain due-diligence report reference (mandatory under EUBR Article 49 for cobalt, lithium, nickel, natural graphite)

Cell chemistry and composition (bat.chem.*)

  • bat.chem.chemistry_type — Li-ion NMC / Li-ion LFP / Li-ion NCA / NiMH / lead-acid / etc.
  • bat.chem.cathode_active_material — with critical raw material breakdown
  • bat.chem.anode_active_material
  • bat.chem.electrolyte_composition
  • bat.chem.critical_raw_materials[] — cobalt, lithium, nickel, natural graphite content per cell mass
  • bat.chem.hazardous_substances[] — with SCIP identifier where applicable

Performance and durability (bat.perf.*)

  • bat.perf.rated_capacity — in Ah or Wh
  • bat.perf.rated_voltage
  • bat.perf.internal_resistance
  • bat.perf.expected_lifetime_cycles
  • bat.perf.state_of_health_algorithm — SoH calculation methodology
  • bat.perf.power_capability_curve
  • Cycle life at defined depth-of-discharge

Carbon footprint (bat.env.carbon_footprint.*)

  • Manufacturing-phase carbon footprint per kWh useful energy over service life
  • Methodology: PEFCR-battery (draft) or ISO 14067
  • Third-party verified per Annex II

Recycled content (bat.env.recycled_content.*)

  • Cobalt / lithium / nickel / lead recycled content percentages
  • Minimum thresholds mandatory from 2031: 16% cobalt, 6% lithium, 6% nickel, 85% lead. From 2036: 26% / 12% / 15% / 85%.

Safety and handling (bat.safety.*)

  • Safe use, transport (UN 38.3 compliance), storage
  • Hazard classification
  • First-aid guidance in event of thermal event
  • Fire suppression compatibility

End of life (bat.eol.*)

  • EPR scheme registration
  • Take-back locations and process
  • Disassembly instructions with tooling
  • Cell-level material recovery paths
  • Reuse and second-life eligibility

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.

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 GS1 Digital Link with serial (/01/GTIN/21/SERIAL)
  • 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
  • Annex VII — Digital Battery Passport information requirements
  • 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