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Before 18 February 2027: what is settled for the Digital Battery Passport and what is still open

The registry, harmonised standards and data point guidance are published; the access rights act is not yet adopted. Where things stood in November 2026 and what companies can do now.

18 February 2027 is the start date set by Article 77(1) of the EU Batteries Regulation (EU) 2023/1542. Some of the supporting texts are already published and others are still being prepared. This article records the position on the review date; later changes are governed by official EU publications.

What is settled

  • Start date: the date in Article 77(1) has not changed. The 2025 amendment moved the battery due diligence obligations (Article 48) to 18 August 2027, but did not move the Digital Battery Passport date.
  • Registry: the Digital Product Passport registry has been operational since 20 July 2026, with a testing environment. Implementing Regulation (EU) 2026/1778 sets out how it works. It entered into force on 6 August 2026 and expressly covers the batteries in Article 77.
  • Harmonised standards: Implementing Decision (EU) 2026/1736 published six references on 15 July 2026: EN 18216 (data exchange protocols), EN 18219 (unique identifiers), EN 18220 (data carriers), EN 18221 (data storage, archiving and persistence), EN 18222 (APIs) and EN 18223 (system interoperability).
  • Data content: the European Commission’s data point guidance is now at version 3.2 (19 October 2026) and lists 71 data points for three battery categories. It is not legally binding, but it is the most detailed official reference so far.

What is still open

  • Access rights: Article 77(9) required the Commission to adopt, by 18 August 2026, an implementing act specifying who counts as a “person with a legitimate interest” and what they may access, download, share and re-use. That date was missed, and the Commission’s timeline now shows Q4 2026. Published reports indicate that public feedback on the draft runs until 16 November 2026.
  • Remaining two harmonised standards: listed in the Commission’s timeline for November 2026.
  • Carbon footprint declaration and label: the guidance says their format is still to be set by an implementing act, so they are not filled in or displayed as of February 2027.
  • Passport service providers: the Commission’s timeline places the delegated act on Digital Product Passport service providers in Q2–Q3 2027, after the Digital Battery Passport starts to apply.

None of these open points has changed the start date in Article 77(1). Project plans should still work towards 18 February 2027.

What companies can do now

  • Map one representative model against the data point guidance and assign a source and an owner to each data point.
  • Prepare the public and authority information first. Treat “person with a legitimate interest” as a configurable role, so that its membership and download and sharing rules can be adjusted once the implementing act is adopted.
  • Confirm which company is the responsible operator and start the identity verification the registry requires.
  • Run a test registration in the registry’s testing environment, which needs a separate EU Login account.
  • Decide on the unique identifier and QR code approach. Article 77(3) requires them to comply with the ISO/IEC 15459 series or equivalent.

Official sources

This article helps with project preparation and is not legal advice. Refer to the official text and professional advice for specific obligations.