The Battery Regulation DPP: what Annex XIII requires
The EU Battery Regulation is the first major regulation to mandate Digital Product Passports at scale. Starting from early 2027, industrial and EV batteries sold in the EU must carry a DPP accessible via a QR code.
Annex XIII specifies the data fields every battery passport must contain:
- Battery identification — manufacturer, model, batch, unique identifier
- Battery chemistry — cathode, anode, electrolyte composition
- Capacity and performance — rated capacity, energy, voltage, internal resistance
- Carbon footprint — CO2e per kWh across the lifecycle
- Recycled content — percentage of recycled materials by type
- Supply chain due diligence — responsible sourcing declarations for cobalt, lithium, nickel
- End-of-life — collection, recycling, and second-life instructions
- Safety information — hazardous substance declarations, transport classifications
Carbon footprint per kWh: how to calculate and verify
One of the most technically demanding requirements is the carbon footprint declaration per kWh. This requires:
- Life Cycle Assessment (LCA) data covering raw material extraction, manufacturing, and transport
- Third-party verification or use of approved calculation methodologies
- Regular updates as production processes change
The key challenge isn't calculating it once — it's maintaining and updating verified carbon data across product variants and production batches.
Supply chain due diligence
The Battery Regulation includes specific requirements for responsible sourcing, particularly for:
- Cobalt — conflict mineral traceability
- Lithium — environmental impact of extraction
- Nickel — supply chain human rights due diligence
Manufacturers must demonstrate due diligence across their supply chain. This means collecting and verifying declarations from raw material suppliers — exactly the kind of multi-tier supplier data collection challenge that manual processes can't handle at scale.
QR code scanning requirements
The regulation specifies that battery DPPs must be accessible via QR code. "Accessible" means:
- The QR code links to a web-accessible passport
- The passport displays required information in a structured, readable format
- Different audiences (regulators, recyclers, consumers) may need different views
This three-audience requirement maps directly to the PUBLIC/BUYER/INTERNAL visibility model — consumers see safety and recycling info, recyclers see composition details, and regulators see everything including audit trails.
How to implement without an enterprise project
Many battery manufacturers assume DPP compliance requires a massive ERP integration project. It doesn't have to.
A practical approach:
- Start with a passport template aligned to Annex XIII fields
- Assign supplier-side fields (raw material sourcing, responsible mining declarations) to your suppliers via structured task workflows
- Attach evidence — LCA reports, third-party certifications, due diligence declarations
- Publish with QR codes that meet the regulation's scanning requirements
- Use the audit trail to demonstrate ongoing data governance
You can be compliant and operational in weeks, not months.
Passiris supports battery DPP templates aligned to EU Battery Regulation requirements. Book a demo to see how it works for battery manufacturers.