Battery Passport vs. Digital Product Passport: The Differences Explained

Introduction

The question of Battery Passport vs. Digital Product Passport comes up at the beginning of almost every DPP project: are they two separate compliance obligations, or are they different names for the same system?

The most important answer is straightforward: the Battery Passport is the sector-specific Digital Product Passport for batteries. It is not a competing system. It follows the same broader DPP logic, but it has its own legal basis, a fixed compliance date, battery-specific data requirements, and individual-battery granularity.

The Battery Passport is governed by the EU Battery Regulation (Regulation (EU) 2023/1542). The broader Digital Product Passport framework is established by the Ecodesign for Sustainable Products Regulation, or ESPR (Regulation (EU) 2024/1781). Under Article 77 of the Battery Regulation, each LMT battery, each industrial battery above 2 kWh, and each electric vehicle battery placed on the EU market or put into service must have a Battery Passport from 18 February 2027. citeturn127737search1turn127737search0

Understanding this relationship matters because manufacturers do not need to build two completely separate digital infrastructures. The technical foundations overlap substantially. Product identification, data carriers, structured and machine-readable data, controlled access, lifecycle management, interoperability, and connection with the European DPP infrastructure all belong to the same architectural direction. The product-specific data model and regulatory evidence change; the foundation remains reusable. citeturn127737search0turn127737search6

This guide separates the two concepts clearly: which regulation applies, when the obligations start, what information belongs in each passport, where the architecture overlaps, and how manufacturers can build one scalable infrastructure for both Battery Passports and future DPP requirements.

At a glance

• Not either-or: the Battery Passport is the sector-specific DPP for batteries, not an independent alternative to the Digital Product Passport.
• Different legal basis: the Battery Passport follows Regulation (EU) 2023/1542; the broader DPP framework follows ESPR Regulation (EU) 2024/1781 and its product-specific delegated acts.
• Fixed battery deadline: applicable EV, LMT and industrial batteries above 2 kWh require a Battery Passport from 18 February 2027.
• No single ESPR-wide deadline: each product group becomes subject to the requirements defined in its applicable delegated act.
• Shared architecture: unique product identifiers, data carriers, structured data, access rights, interoperability and the EU DPP Registry are common infrastructure elements.
• Practical consequence: manufacturers can build the infrastructure once, then adapt data models, permissions, mandatory fields and evidence for each product category.

Table of contents

1. The most important point first: not either-or
2. Battery Passport: the DPP for batteries
3. Digital Product Passport: the horizontal ESPR framework
4. Battery Passport vs. Digital Product Passport: the differences in detail
5. Where the two passports overlap
6. What this means for compliance planning
7. Battery Passport and DPP in numbers
8. Implementing Battery Passports and DPPs with Nota Sign
9. Frequently asked questions

1. The most important point first: not either-or

A Digital Product Passport is a product-specific digital record that makes defined product information electronically accessible through a data carrier. Under the ESPR, the DPP is connected to a persistent unique product identifier, uses interoperable and open data formats, and provides access according to the rights defined for the relevant product group. The passport can operate at model, batch or individual-item level, depending on the applicable delegated act. citeturn127737search0turn127737search5

The Battery Passport applies the same underlying concept specifically to batteries.

Its legal basis does not come from an ESPR delegated act. It comes directly from the EU Battery Regulation. Article 77 establishes the Battery Passport obligation, while Article 78 requires the Battery Passport to be interoperable with other Digital Product Passports under EU ecodesign legislation. The Battery Regulation also explicitly requires the unique battery identifier to be uploaded to the DPP Registry established under Article 13 of the ESPR. citeturn127737search1turn127737search6

That distinction explains why the word “vs.” can be misleading.

The relationship is not:

Battery Passport or Digital Product Passport

It is:

Digital Product Passport framework

→ Battery-specific implementation

→ Battery Passport

For manufacturers placing batteries on the EU market, the Battery Passport is the immediate obligation. For manufacturers operating across several product categories, it should be treated as part of a broader product-data architecture rather than as an isolated battery compliance project.

This matters especially for companies producing products that contain batteries. A vehicle, industrial machine, energy-storage system or other finished product can involve a Battery Passport at battery level and separate DPP obligations at finished-product level once the relevant product rules apply. The two records serve different regulatory objects but operate within the same broader digital-product-information model.

Key takeaway: The Battery Passport is the Digital Product Passport for covered batteries. It has its own regulation and deadline, but it belongs to the same broader DPP infrastructure.

2. Battery Passport: the DPP for batteries

The Battery Passport is currently the most concrete mandatory product-passport implementation in the EU framework.

Article 77 of the EU Battery Regulation fixes the date and the covered battery categories. From 18 February 2027, a Battery Passport is required for:

• electric vehicle batteries;
• LMT batteries, including batteries for light means of transport;
• industrial batteries with a capacity greater than 2 kWh.

The obligation applies when those batteries are placed on the market or put into service. citeturn127737search1turn127737search3

The scope of the information is battery-specific.

The Battery Passport combines information associated with the battery model with information relating to the individual battery. Annex XIII of the Battery Regulation establishes the relevant information categories and different levels of access. Public information, information reserved for authorities and notified bodies, and information available to parties with a legitimate interest are handled separately. citeturn127737search3

In operational terms, this means a Battery Passport needs to connect several types of information throughout the battery lifecycle. These include identity and manufacturer information, battery characteristics, material and composition information, performance and durability information, safety-related information, and lifecycle-specific records.

Additional regulatory outputs, including carbon-footprint information, recycled-content information and supply-chain due-diligence results, follow the applicable requirements and application dates established by the Battery Regulation and the corresponding secondary legislation. The important distinction is that the passport serves as the structured digital record for the required results; it is not automatically a public repository for every piece of raw upstream supply-chain data.

Another important implementation point is granularity.

For the battery categories covered by Article 77, the passport is associated with the individual battery. Each battery therefore needs its own electronically accessible record and unique identifier. This creates a very different scaling requirement from a product-information system that stores one record for an entire model or product family. citeturn127737search1

For a manufacturer producing hundreds of thousands or millions of batteries, the architecture must therefore support:

• individual product identities at scale;
• reliable generation and assignment of identifiers;
• lifecycle updates;
• controlled information access;
• long-term availability;
• integration with manufacturing and enterprise systems;
• connection to the EU DPP Registry.

The Battery Passport is consequently not just a compliance page behind a QR code. It is an operational data layer connected to individual physical batteries.

Key takeaway: The Battery Passport has a fixed deadline, a deep battery-specific data scope and individual-battery granularity. Manufacturers need infrastructure that can operate at production scale.

3. Digital Product Passport: the horizontal ESPR framework

The broader Digital Product Passport is established through the ESPR.

Unlike the Battery Regulation, the ESPR does not create one universal compliance date for every product category. It establishes a horizontal legal and technical framework. Product-specific obligations are then defined through delegated acts that determine the relevant product group, required information, data-carrier rules, passport granularity, access rights, update responsibilities and application dates. citeturn127737search0turn127737search2

This distinction is essential.

There is no single date on which “the DPP” becomes mandatory for every physical product in Europe.

Instead, the rollout proceeds product group by product group.

The European Commission adopted the first ESPR and Energy Labelling Working Plan 2025–2030 on 16 April 2025. It prioritises six new product groups: textiles/apparel, furniture, tyres, mattresses, iron and steel, and aluminium. The working plan gives indicative adoption timelines for the corresponding regulatory work; the binding requirements and application dates come from the relevant delegated acts. citeturn382356search0

This structure means companies must map their product portfolios against the relevant legal instruments rather than planning around one generic “DPP deadline.”

The ESPR also defines the core architecture that these future passports use.

Under Articles 9–11, a DPP must be connected through a data carrier to a persistent unique product identifier. The data must use open standards and interoperable formats and, where appropriate, be machine-readable, structured, searchable and transferable. Access is governed according to the rights defined for the relevant product group. The system is decentralised: the complete passport data is stored by the responsible economic operator or a DPP service provider rather than centrally inside an EU database. citeturn127737search0

The European Commission launched the Digital Product Passport Registry in July 2026 together with a testing environment. The Registry provides the central infrastructure for registering unique product identifiers and associated metadata, while full DPP data remains decentralised. citeturn127737search7

This is one of the strongest points of architectural overlap between the Battery Passport and future ESPR passports. Article 77 of the Battery Regulation explicitly connects battery identifiers to the same Registry framework.

Key takeaway: ESPR creates the horizontal DPP framework. Product obligations arrive through product-specific rules, while the Registry, identification principles, interoperability model and decentralised architecture provide a common infrastructure layer.

4. Battery Passport vs. Digital Product Passport: the differences in detail

The following comparison shows where the Battery Passport differs from the general ESPR DPP framework even though the two follow the same underlying architecture.

Dimension	Battery Passport	Digital Product Passport under ESPR
Legal basis	EU Battery Regulation, Regulation (EU) 2023/1542	ESPR, Regulation (EU) 2024/1781, plus product-specific delegated acts
Scope	EV batteries, LMT batteries and industrial batteries above 2 kWh	Product group by product group under applicable delegated acts
Compliance date	Fixed: 18 February 2027 for the Battery Passport obligation	No single universal date; the applicable act defines the requirements and application date
Data scope	Battery identity, model and individual-battery data, composition, performance, durability, safety and other battery-specific information; additional regulatory results apply according to the relevant requirements	Defined separately for each product group
Granularity	Individual battery for covered categories	Model, batch or item level as specified in the applicable delegated act
Data carrier	Connected to the individual battery and its unique identifier	Data carrier on the product, packaging or accompanying documentation as defined in the applicable act
Access model	Public, authority/notified-body and legitimate-interest access levels according to Battery Regulation requirements	Role- and data-specific access rights defined for each product group
EU Registry	Battery unique identifier uploaded to the ESPR DPP Registry	Unique identifiers registered through the shared DPP Registry infrastructure
Responsible party	Economic operator placing the battery on the market or putting it into service	Responsible economic operator under ESPR and the applicable product-specific rules
Regulatory maturity	Fixed passport obligation and detailed battery-specific legal framework	Horizontal framework in force; requirements specified product group by product group

The biggest practical difference for compliance teams is the deadline.

For batteries, the passport date is already fixed in the Regulation: 18 February 2027. There is no equivalent single ESPR-wide compliance date. A manufacturer of textiles, furniture, tyres, steel or another ESPR priority product needs to follow the delegated act for that specific product group. citeturn127737search1turn382356search0

The second major difference is the data model.

The Battery Regulation already defines a battery-specific information structure. Under ESPR, the Commission defines the data requirements per product group. A textile product, tyre, piece of furniture and steel product do not use an identical passport dataset simply because they all fall within the broader DPP framework.

The third difference is granularity.

Battery Passports operate at the level of the individual covered battery. ESPR explicitly allows future product passports to be defined at model, batch or item level, depending on the characteristics of the product group and the applicable delegated act. citeturn127737search0

These distinctions affect storage volumes, identifier strategies, integration architecture, update processes and operating costs.

Key takeaway: The underlying model is shared, but the legal basis, deadline, data requirements and granularity differ. Battery Passport implementation is specific to batteries; DPP infrastructure is broader.

5. Where the two passports overlap

The most important strategic point is not where the Battery Passport and ESPR DPP differ. It is where they overlap.

Both require a reliable digital connection between a physical product and its digital record.

That connection starts with a unique identifier.

Under the ESPR, each passport must be connected through a data carrier to a persistent unique product identifier. The Battery Regulation likewise requires the battery to have a unique identifier and explicitly connects that identifier to the ESPR Registry. citeturn127737search0turn127737search1

Both also depend on a data carrier.

Depending on the applicable rules and physical product, this can be implemented through technologies such as a QR code or another machine-readable carrier. The carrier is the access point; it is not the passport itself.

Behind that access point sits the actual DPP infrastructure:

• persistent product identity;
• structured data;
• machine-readable information;
• lifecycle updates;
• access-control logic;
• authentication and integrity controls;
• interoperability with other systems;
• long-term data availability;
• Registry interaction.

ESPR Article 11 explicitly requires Digital Product Passports to be interoperable at technical, semantic and organisational levels. Battery Regulation Article 78 contains the corresponding requirement for the Battery Passport to be interoperable with other Digital Product Passports required under EU ecodesign law. citeturn127737search0turn127737search6

This common foundation changes the implementation decision.

A manufacturer that treats the Battery Passport as a completely isolated project can create a point solution that solves the first deadline but duplicates identity, data integration and access-management work when other DPP obligations enter the portfolio.

A shared architecture creates a different model:

Common DPP infrastructure

→ Battery-specific data model

→ Battery Passport

Common DPP infrastructure

→ Product-group-specific data model

→ ESPR Digital Product Passport

The data schema changes. The regulatory fields change. Access rights can change. Evidence requirements change. The core infrastructure does not need to be rebuilt from zero.

That is why product identity, integration architecture and data governance decisions made during a Battery Passport project have significance beyond battery compliance.

Key takeaway: Product identifiers, data carriers, structured data, controlled access, interoperability and Registry integration form a reusable technical foundation for both Battery Passports and broader DPP implementations.

6. What this means for compliance planning

For manufacturers, the distinction can be translated into three practical steps.

1. Determine the applicable regulation for every product line

Start by mapping products against the relevant legal framework.

For each product line, establish whether it is:

• a battery directly covered by the EU Battery Regulation;
• a product category governed by an ESPR delegated act;
• a finished product containing a battery;
• a combination of product and component levels subject to separate information obligations.

Products with integrated batteries deserve particular attention because the battery and the finished product are separate regulatory objects.

A Battery Passport attached to the battery does not automatically replace the Digital Product Passport for the finished product when that finished product is itself covered by a separate DPP obligation.

Conversely, a future DPP for the finished product does not replace the Battery Passport required under Article 77 for the covered battery inside it.

2. Separate deadlines from data obligations

For covered batteries, the Battery Passport obligation begins on 18 February 2027. Battery-specific regulatory requirements for carbon footprint, recycled content, due diligence and other subjects follow the application dates established for those respective obligations.

For ESPR products, there is no universal DPP date. The applicable delegated act determines the product-specific requirements and when those requirements apply.

This separation prevents a common compliance error: treating every battery-related data requirement as if it begins automatically on the Battery Passport date, or treating every ESPR product as if it shares one common DPP deadline.

3. Build one shared infrastructure

The strategic objective is to avoid implementing the same foundational capabilities repeatedly.

A shared infrastructure can manage:

• product and item identifiers;
• data carriers;
• product master data;
• lifecycle records;
• role-based access;
• Registry registration;
• supplier-data workflows;
• compliance evidence;
• audit trails;
• data authentication and integrity.

The Battery Passport then becomes the first regulated use case running on that infrastructure.

When additional product categories enter scope, manufacturers add the required data model, roles, business rules and evidence without recreating the entire product-identity architecture.

For companies operating in batteries and energy storage, this is particularly important. The 2027 Battery Passport requirement creates an immediate compliance project, but the infrastructure investment has a longer life than that single regulation.

Key takeaway: Map the regulation per product line, distinguish the applicable deadlines, and build one common DPP infrastructure that can support multiple regulatory variants.

7. Battery Passport and DPP in numbers

18 February 2027

Battery Passport obligation

From this date, each covered EV battery, LMT battery and industrial battery above 2 kWh placed on the EU market or put into service must have a Battery Passport. citeturn127737search1

Regulation (EU) 2023/1542

Legal basis for the Battery Passport

The EU Battery Regulation establishes the sector-specific Battery Passport requirements, including Article 77 on the passport and Article 78 on technical design and interoperability. citeturn127737search6

July 2026

EU DPP Registry launched

The European Commission launched the Digital Product Passport Registry together with a testing environment in July 2026. The Registry records unique product identifiers and associated metadata while full product-passport data remains decentralised. citeturn127737search7

2 kWh

Industrial-battery threshold

Industrial batteries with a capacity greater than 2 kWh fall within the Battery Passport obligation under Article 77. citeturn127737search1

6 priority product groups

First ESPR Working Plan

The Commission's 2025–2030 Working Plan prioritises textiles/apparel, furniture, tyres, mattresses, iron and steel, and aluminium for new ESPR product measures. citeturn382356search0

19%

Companies describing themselves as well-prepared

In the KPMG European Digital Product Passport Readiness Survey, only 19% of participating organisations described themselves as well-prepared, with clear governance, assigned roles and an executive-backed roadmap. The remaining 81% were in earlier readiness stages. citeturn774753view0turn774753view2

KPMG also found that 53% were only “getting started,” 16% planned to start soon, and 12% remained unprepared. Supplier engagement and data collection was the most common preparation activity, while collecting data across the supply chain was the most frequently reported implementation challenge. citeturn774753view2

Key takeaway: The Battery Passport deadline is fixed, the common Registry infrastructure is operational, and ESPR product requirements are advancing. Most organisations surveyed by KPMG have not yet reached mature DPP readiness.

8. Implementing Battery Passports and DPPs with Nota Sign

Nota Sign Digital Product Passport Platform provides the infrastructure for enterprises to create, operate and manage Digital Product Passports across product lifecycles.

For manufacturers asking whether they need a “Battery Passport platform” or a “DPP platform,” the more important question is whether the architecture supports both the battery-specific obligation and the wider Digital Product Passport model.

Nota Sign is designed around that shared foundation.

Manufacturers can establish trusted product identities, connect product and lifecycle data, manage access-controlled information, and operate digital compliance workflows without building separate identity and evidence systems for every new passport requirement.

For Battery Passport implementations, the platform supports the product-level architecture required to connect individual batteries with their digital records. Product information can be linked to lifecycle data and integrated with existing enterprise systems such as ERP, MES, PLM and supplier-data environments.

The same infrastructure supports broader Digital Product Passport use cases. Product-specific schemas, mandatory fields, roles and workflows can be configured according to the relevant regulatory requirements while the underlying identity, access, integration and trust infrastructure remains consistent.

Digital trust is another critical layer.

ESPR requires authentication, reliability and integrity of DPP data. Nota Sign brings enterprise digital trust capabilities directly into DPP workflows through:

• electronic signatures;
• electronic seals (eSeal);
• digital certificates;
• identity-based approval workflows;
• audit trails;
• verifiable compliance records.

Explore Nota Sign eSeal →

For manufacturers exchanging DPP information across suppliers, subsidiaries, customers and external partners, these mechanisms create evidence of who issued or approved critical records and help protect the integrity of compliance documentation.

The architecture also allows DPP implementation to build on existing enterprise IT investments instead of replacing them. ERP, MES, PLM, product-data systems and supplier platforms remain systems of record for the information they manage; the DPP layer connects the relevant data to a persistent product identity and exposes the required information through controlled digital workflows.

This is particularly important for global manufacturers operating several regulated product categories.

The objective is not to build:

one Battery Passport system

+ one textile DPP system

+ one equipment DPP system

+ another system for every future product group.

The objective is to establish:

one trusted Digital Product Passport infrastructure

+ battery-specific data and workflows

+ product-specific DPP models as regulations apply.

That approach reduces duplicated integration work and gives compliance, IT and product teams a common architecture for product identity, lifecycle information and digital evidence.

Explore Nota Sign Digital Product Passport Platform →

Request a Demo →

Key takeaway: The Battery Passport is the first immediate use case, but the infrastructure should support the wider DPP model. Nota Sign provides one foundation for product identity, lifecycle data, enterprise integration and digital trust, with product-specific requirements configured on top.