EU Battery Passport Compared With Other Product Passports

The battery passport and other product passports share the idea of a structured electronic record reached through a data carrier, but they sit under different laws, with different duties, different data and different dates. The battery passport is created by Regulation (EU) 2023/1542, with a fixed duty date of 18 February 2027 in Article 77 for specified battery categories. Other product passports are created by the framework in Regulation (EU) 2024/1781, known as ESPR, which enables passports product group by product group through delegated acts, and no product needs an ESPR passport until a delegated act for its group requires one. Treating the two systems as one system confuses a fixed sector duty with a framework that is still being filled in group by group.

The scope is the comparison of the two legal bases, read as checked on 28 October 2026. The guide covers the ESPR framework only, as the task requires, and does not state the passport data for any ESPR product group, because those data are set by delegated acts that may not yet exist for a given group.

What law creates the battery passport?

The battery passport is created by Article 77 and Annex XIII of Regulation (EU) 2023/1542, which set the duty, the categories, the date and the information structure in a single Regulation. The duty is self contained, in the sense that a reader can find the categories, the date and the Annex XIII structure in the same instrument, without waiting for a further delegated act to create the duty, although delegated and implementing acts may add detail on matters such as data points and the registry. The self contained character is why the battery passport is described as the first product passport with a fixed date, and it is also why battery preparation can proceed on the Regulation text and the Commission guidance, rather than waiting for a product group act.

What law creates other product passports?

Other product passports are created by Articles 9 to 12 and Annex III of Regulation (EU) 2024/1781, the ESPR, which set a framework for passports without setting product specific duties in the Regulation itself. Under Article 9, a product can only be placed on the market if a digital product passport is available in accordance with the applicable delegated act, and the delegated act specifies the data, the carrier, the level of identifier and the access rules for that product group. The ESPR working plan for 2025 to 2030 prioritises product groups including textiles, furniture, tyres, iron and steel and aluminium, but prioritisation is not a duty, and a product group carries a passport duty only when its delegated act says so. The framework character is the central difference from the battery passport.

How do data and access compare?

Data and access compare as a sector list against a framework list, with Annex XIII setting the battery information by tier, and Annex III of the ESPR setting the kinds of information that a delegated act may draw on, including composition, compliance documentation, manuals, safety information and operator identifiers. Both systems use access tiers, both use unique identifiers and both use a data carrier, but the battery tiers are fixed in Annex XIII while the ESPR tiers are set per delegated act. A reader should therefore not assume that a field in a battery passport appears in an ESPR passport for another product, or that an ESPR field appears in a battery passport, because each system draws its field list from its own instrument. The comparison should be made field by field, instrument by instrument.

What does a comparison table look like?

A comparison table keeps the legal basis, the duty trigger and the data source apart for each system. The table below states the positions in general terms, as checked on 28 October 2026.

Can one system satisfy the other?

One system cannot be assumed to satisfy the other, because a battery passport satisfies the Battery Regulation for a battery, while an ESPR passport, where required, satisfies the ESPR for a product, and a product that is both a battery and an ESPR product, or a product containing a battery, may need both readings. A battery incorporated in a product that later falls under an ESPR delegated act raises a double record question, in which the battery record and the product record each need to be satisfied on their own terms, with the identifier link between battery and product recorded where the instruments require it. The double reading should be mapped product by product, rather than assumed to collapse into a single record, until the relevant delegated act and any registry arrangements state otherwise.

What should a manufacturer with both kinds of product do?

A manufacturer with both battery products and other products should run two preparation tracks, one for the fixed battery duty and one for the ESPR groups that affect its other products, with a shared identifier and data discipline that serves both tracks without merging them. The battery track works to the 18 February 2027 date, the ESPR track works to the delegated act dates for each group, and the shared discipline covers unique identifiers, data quality, access control and record retention. A single track that tries to serve both systems on the battery timetable will overprepare for ESPR groups that have no duty yet, while a single track on the ESPR timetable will underprepare for the fixed battery date. Two tracks with shared discipline is the proportionate structure.

What limits apply to this comparison?

The limits are that ESPR duties depend on delegated acts that are still being adopted, and this guide states only the framework. This guide gives general educational information only and is not individual legal advice. A manufacturer with a specific product should check both Regulations and the relevant delegated act as checked on 28 October 2026 before acting.