EU battery passport implementation status: acts, standards and the registry

As of 25 October 2026, what the battery passport still lacks is mostly Commission acts. Drafts on access rights for a legitimate interest and on minimum values for industrial batteries are currently open for public feedback. The labelling rules, the carbon footprint method and format for EV batteries and the recycled content method exist as drafts but have not been adopted, and the carbon footprint method for industrial batteries is only planned. What is in place: the EU registry and its implementing regulation, six standards for digital product passports, the first harmonised standard under the Battery Regulation and, in Germany, the fines in the BattDG. None of the missing acts changes the start of the passport obligation on 18 February 2027.

How do we check the status?

Every entry rests on a primary source, which we link:

• ‘Have your say’, the Commission’s consultation portal, for planned initiatives, drafts and feedback periods;
• the Official Journal of the EU via EUR-Lex for adopted acts and the references of harmonised standards;
• the Commission’s digital product passport pages, above all the FAQ for batteries, for the registry and the guidance documents;
• gesetze-im-internet.de for German law.

We check the affected entries whenever we notice a new publication in the Official Journal or on ‘Have your say’. We do not promise a fixed schedule, which is why every row shows the date we last checked it and the top of the table shows the date of the whole tracker. ‘Last change’ is the day the status last changed: the start of the latest feedback period, publication in the Official Journal, or entry into force.

Where a legal deadline has passed and the act is still missing, the deadline is marked ‘deadline passed’.

Where does each item stand?

Which delegated and implementing acts are missing?

Most open items are acts that the Battery Regulation requires the Commission to adopt. The one that matters most for the passport is the implementing act under Article 77(9). It is to specify who counts as a person with a legitimate interest and which restricted parts of the passport they may download, share and re-use. The draft names, among others, repairers, remanufacturers, repurposers, waste treatment operators, recyclers, vocational training centres and the purchaser of the battery. A draft is not law; any of these lines can change before adoption.

Other deadlines have passed as well: for the labelling rules, for the carbon footprint method and format (since 2024 for EV batteries, since 2025 for industrial batteries), for minimum values for industrial batteries and for the recycled content method. For the recognition of schemes that help companies meet their due diligence obligations (Art. 53), the Commission lists only planned initiatives, and the Regulation sets no deadline.

For most of these acts, an obligation starts only after the act enters into force: the label 18 months after the labelling rules, the carbon footprint declaration 12 or 18 months after method and format, the minimum values 18 months after their act and recycled content documentation 24 months after the method, in each case no earlier than the fixed date in the Regulation. Delegated acts also enter into force only if the European Parliament and the Council raise no objection within three months (Art. 89(6)). The timeline walks through the arithmetic.

Which standards exist already?

For batteries themselves there is a single harmonised standard: EN 18060:2025 on the performance and durability of EV batteries, in the Official Journal since 16 September 2026. Batteries that meet it benefit from the presumption of conformity in Article 15(3) to the extent the standard covers the requirements. For stationary storage and other industrial batteries there is no harmonised standard yet. There, Article 15(1) still applies: tests, measurements and calculations with reliable, accurate and reproducible methods that take the state of the art into account.

For the passport technology, six harmonised standards for digital product passports have been cited since 15 July 2026: data exchange, identifiers, data carriers, storage, APIs and interoperability. They rest on the Ecodesign Regulation and give a presumption of conformity only with its Articles 10 and 11. According to the Commission’s FAQ, this means six of the eight DPP standards are now cited.

How far along is the EU registry?

The digital product passport registry has been running since 20 July 2026, with a testing environment and a helpdesk. Implementing Regulation (EU) 2026/1778 sets out how economic operators verify their identity (for example with a qualified electronic seal), how they register passports and what proof they receive. The registry holds the unique identifier of each battery; the passport itself stays with the economic operator or a service provider acting on its behalf. Still to come are the API for registrations and the battery data model in the semantic repository, against which the registry is to check completeness. Submission from BatteryPass to the registry is planned planned.

What guidance has the Commission published?

The guidance document ‘Digital Batteries Passport: data points by category’, version 2.0, lists 71 data points and shows per category what is required at the start and what comes later. Like the FAQ for batteries, it is not binding, but it reflects the Commission’s reading. The due diligence guidelines under Article 48(5) were due by 26 July 2026; we did not find them in the Official Journal.

What does the environmental omnibus change?

In December 2025 the Commission proposed targeted changes to the Battery Regulation: the producer definition, the hazardous substances shown on the label, the replaceability of LMT batteries and some reporting duties. The battery passport is not affected. The proposal is not law yet.

Which rules apply in Germany?

Germany set out its penalties under Article 93 in the Battery Law Implementation Act (Batterierecht-Durchführungsgesetz, BattDG), in force since 7 October 2025. Anyone who, intentionally or negligently, fails to ensure that the passport information is accurate, complete and up to date commits an administrative offence (section 60(2) No. 29), with a fine of up to EUR 10,000. For breaches of the due diligence obligations, section 60 provides for up to EUR 500,000.

How to cite

If you cite the tracker, please include the ‘as of’ date:

BatteryPass, Implementation status of the EU battery passport, as of 25 October 2026, https://kabin.sh/en/battery-passport/implementation-status

Changes to the tracker

• 25 October 2026: Tracker published; every entry checked against its primary source.