The EV passport timeline is a sequence of phased duties, not a single deadline, and the record must keep each duty, its date, and its legal basis separate. The carbon footprint declaration for EV batteries applies from 18 February 2025 or 12 months after the relevant delegated and implementing acts enter into force, whichever is later. The battery passport applies from 18 February 2027 under Article 77. Carbon footprint performance classes, recycled content duties, and due diligence reporting follow later dates and separate acts, and several of those dates are expected dates until the relevant delegated acts are published. A timeline that gives one date for every duty will mislead every reader who relies on it for planning.
The EV passport timeline means the dated sequence of duties that build the EV passport record, from declaration to passport to later data duties. The scope is EV batteries, with each date labelled as fixed in the Regulation or expected pending a delegated act.
How is the EV category decided?
The EV passport timeline applies to that category, and the record should state the vehicle category, the weight basis, and the reason the battery falls inside the definition. Articles 7, 8, 48, and 77 is the operative provision for the point in question, and Annex XIII sets the passport content where a passport applies. A programme manager planning EV passport work across declaration, passport, and later duties should not assume that a traction battery for another vehicle type follows the same entry. A plan for an EV model should show the declaration work, the passport build, and the later recycled content and due diligence work as separate workstreams, each with its own date and owner, rather than as one project with one deadline.
How are model and individual layers kept separate?
For the EV passport timeline, the record should keep the two layers separate, with a link from the individual record to the model record. The timeline, legal basis notes, and delegated act tracker for a model value should name the test or calculation method and the date, while evidence for an individual value should name the measurement, the date, and the source system, such as the battery management system. Due diligence application dates have been the subject of amendment work, and the timeline should state the date in the current consolidated text and the status of any amendment, as checked on 28 October 2026, rather than assert a date that amendment work may have changed.
How are performance values stated?
For the EV passport timeline, a capacity value, a power value, a cycle life value, or a capacity retention value should state the test conditions, the reference temperature, the charge and discharge rates, and the end point used. A programme manager planning EV passport work across declaration, passport, and later duties should record which requirement applies to the EV battery in question and which requirement does not, with the article reference. A plan for an EV model should show the declaration work, the passport build, and the later recycled content and due diligence work as separate workstreams, each with its own date and owner, rather than as one project with one deadline.
How is use phase information recorded?
For the EV passport timeline, state of health, cycle count, temperature history, and fault history, where recorded, should be tied to the unique identifier and dated, so a later reader can see the sequence. The timeline, legal basis notes, and delegated act tracker should include the data extraction date and the version of the software or method used, where that information is available. Due diligence application dates have been the subject of amendment work, and the timeline should state the date in the current consolidated text and the status of any amendment, as checked on 28 October 2026, rather than assert a date that amendment work may have changed.
How are repair and second life operations distinguished?
For the EV passport timeline, the record should name the operation, the operator who carried it out, the date, the parts changed, and the tests applied after the operation. A programme manager planning EV passport work across declaration, passport, and later duties should check whether a new passport, a linked passport, or an updated passport is required for the operation, and should record the reasoning. A plan for an EV model should show the declaration work, the passport build, and the later recycled content and due diligence work as separate workstreams, each with its own date and owner, rather than as one project with one deadline.
How is access and handover handled?
For the EV passport timeline, the passport access rules in Article 77 set different levels for the public, for persons with a legitimate interest, and for authorities and notified bodies, and the record should not promise wider access than the Regulation allows. Due diligence application dates have been the subject of amendment work, and the timeline should state the date in the current consolidated text and the status of any amendment, as checked on 28 October 2026, rather than assert a date that amendment work may have changed. A programme manager planning EV passport work across declaration, passport, and later duties should retain the handover record with the identifier, so a later dispute can be traced to a dated transfer.
How is a timeline maintained when an act is delayed?
Maintaining a timeline when an act is delayed means recording the delay as a fact, not as a new promise. The timeline entry for the affected duty is marked as expected, the original date is kept with its legal basis, and the status of the delegated act is noted with the date checked. A worked timeline shows the carbon footprint class duty with its original date rule, a note that the delegated act had not entered into force at the check date, and a review date for the next check. The plan that depends on the duty is adjusted to the review date, and the adjustment is recorded. A timeline that silently moves a date forward, without a note on the act, hides the reason for the move and misleads the next planner.
| Duty | Date in the Regulation | Status |
|---|---|---|
| Carbon footprint declaration, EV | 18 February 2025 or 12 months after acts, whichever later | Check current text and acts |
| Battery passport, EV | 18 February 2027 | Fixed date in Article 77 |
| Later duties | Separate dates and acts | Expected until acts publish |
A timeline is a planning record, and a date that is not labelled as fixed or expected will be read as a promise that the law has not yet made.
Sources & further reading
- Regulation (EU) 2023/1542, consolidated text, EUR-Lex ↗
- OECD Due Diligence Guidance for Responsible Supply Chains of Minerals ↗
- Proposal amending battery due diligence dates, EUR-Lex ↗
Source links point to primary materials and further reading, including commercial implementation resources where cited. This introductory guide does not replace the legislation.