Review date: 6 July 2026. Article 77 of Regulation (EU) 2023/1542 states that, from 18 February 2027, each LMT battery, each industrial battery with a capacity greater than 2 kWh, and each electric vehicle battery placed on the market or put into service shall have an electronic record, the battery passport. This is not the same as saying every product containing a battery must have a full product DPP on that date.
What the 2027 date actually covers
The 18 February 2027 date is important, but sellers need to distinguish between a battery passport, battery QR-code or labelling requirements, and future product passports under the broader ESPR framework.
| Item | Scope check |
|---|---|
| Battery passport | Explicitly stated for LMT batteries, industrial batteries above 2 kWh, and electric vehicle batteries. |
| Battery QR code | The Battery Regulation includes separate QR-code and labelling information requirements. These should not be described as a full product DPP without checking scope. |
| Products containing batteries | Check the battery type, capacity, market role, and supplier documents before claiming a passport obligation. |
| ESPR product passport | Other product categories depend on future delegated acts and product-specific rules. |
Who should screen first
Sellers of e-bikes, e-scooters, energy-storage equipment, industrial battery packs, traction batteries, and large professional equipment batteries should build a battery-passport data checklist first.
Sellers of earbuds, smart watches, electronic toys, portable speakers, remote controls, lighting products, and other consumer goods containing small batteries should still check labelling, restricted substances, recycling obligations, user instructions, and supplier evidence. However, they should not present every such product as requiring a full product DPP before confirming the legal scope.
Documents to collect now
- Battery classification: portable, LMT, industrial, EV, or another classification basis.
- Capacity and specifications, especially whether the battery is above 2 kWh.
- Supplier evidence: manufacturer, model, batch, chemistry, material information, and safety documents.
- Labelling and information: QR code, compliance declarations, recycling marks, instructions, and warnings.
- Market role: manufacturer, importer, distributor, brand owner, or marketplace seller.
Remove risky wording
Avoid saying: “From 18 February 2027, all battery-powered products without a digital passport cannot enter the EU.” A safer wording is: “From 18 February 2027, specific battery categories under the EU Battery Regulation enter the battery-passport requirement; products containing batteries should be screened by battery type, capacity, and market role.”
Avoid saying that Amazon has confirmed a specific 2026 Q4 DPP field unless there is an official platform notice. Use: “Sellers should monitor marketplace compliance updates and prepare traceable data in advance.”
GreenArk Certification (Shenzhen) Co., Ltd. can support EU Battery Regulation scope screening, battery document checklists, supplier data templates, label and instruction review, marketplace wording, and DPP preparation-path assessment. This is preparation and consulting support, not a promise of market access, platform approval, test results, certification results, registration results, or commercial outcomes.
