If you make it and place it, the duty is yours
Most of what is written about battery passports is addressed to someone else — the importer bringing in non-EU cells, the authorised representative acting for a distant maker. If you manufacture LMT batteries, EV batteries or industrial batteries above 2 kWh and place them on the EU market yourself, there is no one between you and the obligation. You are the economic operator Article 77 of the Battery Regulation names, and from 18 February 2027 each battery you place needs a registered digital product passport. Not a corporate sustainability programme — a per-unit record, hosted, accessible and kept up to date for the battery's market life.
This piece is the honest scope of that work for a manufacturer without a compliance department to absorb it.
The guessing phase ended on 28 July
Until the end of July, "which fields are actually mandatory for my category" could only be answered by reading Annex VI and Annex XIII side by side and making judgement calls. On 28 July the Commission published its data-points-by-category matrix — the first official document that marks every numbered data point mandatory, optional, applicable in certain cases, or not to be filled, per category, with its legal source. We covered it in full when it landed; the short version for a manufacturer planning the work: chemistry, the recycled cobalt, lithium and nickel shares, hazardous substances and the core identity set are mandatory across all three categories, several performance points are mandatory for EV and LMT but conditional for industrial, and the carbon footprint declaration is not to be filled at launch because its format is still to be specified in a coming implementing act.
Read that last one carefully. The declaration format does not exist yet; the carbon footprint obligation and the data collection behind it are not going anywhere. Methodology, lifecycle stages, verification — that remains the longest lead-time item in a passport programme, and as the maker you hold most of the primary data. Nothing about "not to be filled at launch" makes it sensible to start collecting late.
What the registry asks of you, as of this week
Implementing Regulation (EU) 2026/1778 entered into force on 6 August. The registry it governs has been operational since 20 July, and the model is decentralised: you host the passport, at a stable public address behind a compliant identifier, and what the registry takes at registration is your product group and your passport identifiers. Your passport lives on your infrastructure or your platform's — not on a Commission server.
Two honest status points. First, operator verification is open now, and worth completing now: under the adopted text an expired or absent verification blocks registrations and data changes, not just access. Second, battery passport registration itself is not yet possible — the semantic catalogue the registry validates against is still undefined, and the registry's own user guide says so. Verify now; register when the catalogue lands. Anyone selling you a "fully registered battery passport" today is describing something the registry cannot yet do.
The afternoon that sizes the project
The software problem — field validation against Annex XIII, tiered access so that legitimate-interest data is gated, a public viewer, QR data carriers, an identifier that passes as ISO/IEC 15459-compliant — is a solved category. The project on your desk is the data: take the mandatory column for your category, inventory it against your ERP and test records, and you will know the true size of the work by the end of an afternoon. As the maker you start closer to done than any importer — the design, chemistry and performance data are yours. The gaps are upstream — supplier declarations, recycled-content evidence — and upstream gaps close on calendar time, not engineering time. That is the whole argument for starting now rather than in the autumn.
If you want to see the whole pipeline against your own category before committing to anything, book a demo and bring your field list.
What changed in EU battery and product-passport regulation, what it means for operators, and the dates ahead.
Take the Next Step
Ready to be compliant by 18 February 2027?
EU Digital Passport Processor creates, hosts, and submits EU Battery Passports for manufacturers and importers. Demo accounts are available on request.