Battery Passport and Digital Product Passport
A product passport is an electronic record of your product, reached through a QR code on the product. The company that places the product on the EU market is responsible for it. We create the passport, give it its unique identifier and keep the data up to date on your behalf, under a written authorisation next to your mandate.
A QR code alone is not a passport: the passport is the data behind it, kept as the law requires.
Battery Passport
Regulation (EU) 2023/1542 (Batteries Regulation), Article 77.
- Required for LMT batteries, industrial batteries over 2 kWh and electric vehicle batteries placed on the market from 18 February 2027.
- Every battery carries a QR code with a unique identifier that leads to its passport (Article 77(3)).
- The economic operator placing the battery on the market may authorise another operator in writing to act on its behalf (Article 77(4)). We take on this task; the legal responsibility stays with that economic operator.
- We keep the data accurate, complete and up to date, register the identifier in the EU registry and never sell or reuse your data (Article 77(10), Article 78).
Digital Product Passport
Regulation (EU) 2024/1781 on ecodesign for sustainable products (ESPR).
- Required product group by product group, as the Commission adopts delegated acts – first iron and steel, textiles, furniture, tyres, electronics and other priority groups. Each act applies, as a rule, at the earliest 18 months after it enters into force.
- Under ESPR the passport is not part of an authorised representative's mandate (Article 28(1)). We prepare and update it on your behalf under a separate authorisation.
- A backup copy is kept by an independent digital product passport service provider (Article 10(4)); we arrange it with one.
- We upload the unique identifiers to the EU digital product passport registry for you (Article 13).
Our passport platform
We create and keep battery passports and digital product passports on the platform of dpp.gs, our technology partner.
Key dates
- The Commission sets up the EU digital product passport registry (ESPR, Article 13).
- Battery passport for LMT, industrial (over 2 kWh) and electric vehicle batteries; QR code on all batteries (Batteries Regulation, Articles 13(6) and 77).
Legal basis
Regulation (EU) 2023/1542, Articles 77 and 78, and Regulation (EU) 2024/1781 (ESPR), Articles 9 to 13.
Questions
Are you then responsible for my passport?
No. The law keeps the responsibility with the company that places the product on the EU market; we act on its behalf under a written authorisation and do the work.
Is the passport part of the Authorised Representative mandate?
No. Under the Batteries Regulation and ESPR the mandate covers compliance tasks such as keeping the documentation and cooperating with authorities. The passport is a separate service that you order together with your mandate.