Digital Product Passport and battery passport: what changes in February 2027?
18 February 2027 is a hard date for battery QR marking and electronic passports for specific battery categories. It is not the date on which every product in Europe suddenly needs a DPP.
1. The rule and exact date
Regulation (EU) 2023/1542 is directly applicable EU battery law. Article 13(6) requires batteries to carry a QR code from 18 February 2027. For LMT, industrial batteries above 2 kWh and EV batteries, that QR provides access to the battery passport.
Article 77 requires the electronic passport for those three categories from the same date. For other batteries the QR provides applicable label, conformity and waste information.
2. Who and what are affected?
The economic operator placing the battery on the market must ensure the passport exists. Manufacturer, importer, brand, seller, data provider and platform may all be involved, so assign legal and operational ownership per model.
LMT includes light means of transport such as e-bikes and e-scooters. EV covers traction batteries. Industrial batteries need a passport above 2 kWh, while all battery categories remain within the Article 13 QR rule.
3. Which data belongs in it?
Annex XIII public data includes manufacturer/model, category, manufacturing place, chemistry/materials, hazardous substances and critical raw materials, carbon footprint, due diligence, recycled content, capacity, voltage, power, lifetime, warranty, efficiency, internal resistance, markings, EU declaration of conformity and waste information.
Restricted data includes detailed composition, replacement parts, dismantling instructions, safety measures, test reports and individual-battery status, usage and state-of-health data. Access roles are therefore part of the design.
4. It is a technical system too
The QR connects to a unique identifier based on ISO/IEC 15459 or equivalent. Information must remain accurate, complete and current. The passport must use open standards, be interoperable, structured, searchable and machine-readable, and avoid vendor lock-in.
A normal webpage is not enough: operators need source governance, versioning, access roles, a durable QR route, export/API, registration evidence and agreements on updates, ownership and continuity.
5. Central registry and wider rollout
The Commission has developed a central DPP registry for batteries and future passports. Registration can use an interface or API, semantic and structural checks can be automated, and proof of registration can be downloaded.
Other groups follow under the Ecodesign for Sustainable Products Regulation through delegated acts. The 2025–2030 work plan includes textiles/apparel, tyres, furniture, mattresses, iron/steel, aluminium and horizontal requirements such as repairability. The product-specific act determines fields, timing and transition.
6. What a Merqivio scan can and cannot prove
Merqivio deterministically checks public product pages for battery and product-group signals, passport links, QR references, identifier terms, model and technical data, conformity documents, sustainability, waste and machine-readability signals.
A URL scan cannot reliably see a physical QR, internal evidence, test results or restricted data. A missing web signal therefore creates an evidence request and attention point, not an automatic legal violation or certification.
7. Practical route to February 2027
Inventory scope per model and split QR-only, battery passport, future ESPR group and no demonstrated scope. Assign owner and supplier, build a field matrix, collect evidence, choose identifier/passport architecture, register, generate QR, test public/restricted routes and retain acceptance evidence.
Schedule periodic review because products, supplier data, URLs and EU delegated rules change. Monitoring helps but does not replace product-specific legal assessment.
Official and pricing sources
Merqivio provides automated risk analysis of publicly visible signals, not legal advice or certification. The listed vendor prices are public examples and may change.
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