⚖️ Legal & Compliance

Which Batteries Need a Passport?

Updated 2026-04Essential reading

The EU Battery Regulation requires a Digital Product Passport for three categories of battery. Portable batteries and SLI (starting, lighting, ignition) batteries are not in scope.

Scope by battery category

Battery category	In scope?	DPP required from	Definition
EV battery	Yes	18 February 2027	Traction batteries designed for the propulsion of electric vehicles, with a capacity above 2 kWh. Includes passenger cars, commercial vehicles, buses, and electric trucks.
Industrial battery >2 kWh	Yes	18 August 2027	Batteries designed for industrial use with a capacity exceeding 2 kWh. Includes stationary energy storage systems, UPS systems, and grid-scale batteries.
LMT battery	Yes	18 February 2027	Batteries designed for light means of transport — electric bicycles, electric scooters, and other light electric vehicles. The capacity threshold is >2 kWh.
Portable battery	No	N/A	Batteries under 5 kg that are not designed for industrial use or vehicle propulsion. AA, AAA, button cells, power banks. Exempt from DPP requirements.
SLI battery	No	N/A	Starting, lighting, and ignition batteries used in conventional vehicles. 12V car batteries. Exempt from DPP requirements.

What "placed on the market" means

A battery is "placed on the market" when it is first made available on the EU market. This is determined by the date the battery enters the EU supply chain — not the manufacturing date.

⚠️Manufacturing date vs market date

The compliance deadline applies to when the battery is placed on the EU market, not when it was manufactured. A battery manufactured in December 2026 but placed on the EU market in March 2027 needs a registered DPP. A battery manufactured in March 2027 but already placed on the EU market before February 2027 does not retroactively need one.

Batteries at the boundary

Some batteries sit at the edge of the scope definition. These are the most common questions:

Batteries just under 2 kWh — If an industrial battery has a rated capacity of exactly 2 kWh or below, it is out of scope. The threshold is "exceeding" 2 kWh, so 2.0 kWh is out and 2.1 kWh is in.

Second-life batteries — Batteries repurposed for a second use (e.g., an EV battery repurposed for stationary storage) are in scope if the repurposed battery falls into an in-scope category. The economic operator who repurposes the battery takes on the DPP obligation.

Batteries in equipment — A battery embedded in a product (e.g., an EV battery in a vehicle) is in scope if the battery itself meets the category definition. The DPP requirement applies to the battery, not the vehicle.

How DPP Cloud handles categories

When you create a passport in DPP Cloud, the first step is selecting the battery category: EV Battery or Industrial Battery. LMT batteries are classified under the Industrial category with the LMT sub-type selector. The category you select determines which Annex XIII fields are required and which compliance deadline applies.

ℹ️Category cannot be changed after creation

The battery category is locked once the passport is created. If you need to change the category, create a new passport with the correct selection. This is because the category determines the field schema and regulatory requirements.

EU Compliance Timeline: All Key Dates

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⚖️ Legal & Compliance

EU Battery Regulation 2023/1542: What It Requires

Updated 2026-04

📋 Passport Creation