Battery Passport Compared With the Digital Product Passport

The battery passport and the digital product passport are often used as if they were two names for the same record, but they name different legal instruments, with different duties, different data and different dates. The battery passport is the electronic record required by Article 77 of Regulation (EU) 2023/1542 for specified batteries from 18 February 2027, with the information structure set in Annex XIII. The digital product passport is the record framework created by Regulation (EU) 2024/1781, the ESPR, under which a product needs a passport only when a delegated act for its product group requires one, with the data and access rules set by that delegated act. A reader who uses the two names interchangeably will apply the wrong duty to the wrong product, and will miss the fixed battery date or invent an ESPR date that does not exist.

The scope is the naming and legal basis distinction, as checked on 28 October 2026. The guide covers the ESPR framework only, and does not state the passport data for any ESPR product group.

Why are the two names confused?

The two names are confused because both describe a structured electronic record, reached through a data carrier, that follows a product through its life, and because the battery passport is sometimes described in general discussion as a digital product passport for batteries. The shared idea is real, and the shared technology, with unique identifiers, data carriers and access tiers, is also real, but the shared idea does not make the legal duties the same. The battery passport is a sector duty with a fixed date, while the digital product passport is a framework duty that depends on a delegated act, and a general discussion that shortens both to passport hides the legal difference. The correction is to name the instrument in every statement, so that battery passport means the Regulation (EU) 2023/1542 record, and digital product passport means the ESPR record.

What is the battery passport in one definition?

The battery passport is an electronic record for an individual battery, containing model information and individual information, including information resulting from use, as set out in Annex XIII, accessible through a data carrier on the battery, and required by Article 77 for electric vehicle batteries, light means of transport batteries and industrial batteries over 2 kWh placed on the market or put into service from 18 February 2027. The definition has four parts, namely individual record, Annex XIII content, data carrier access and fixed duty, and a record that lacks any part does not meet the definition. A model datasheet, a label and a voluntary product record are not battery passports under that definition, even where they contain similar information.

What is the digital product passport in one definition?

The digital product passport under the ESPR is a structured, machine readable record for a product in a product group covered by a delegated act, containing the data that the delegated act specifies, drawn from the kinds of information listed in Annex III of Regulation (EU) 2024/1781, accessible through a data carrier, with access regulated by the delegated act. The definition has a conditional part, namely the delegated act, without which there is no duty, and a reader should always ask which delegated act, for which product group, and from which date, before concluding that a product needs a digital product passport. A product in a group with no delegated act has no ESPR passport duty, however complete its voluntary record may be.

What does a naming table look like?

A naming table pairs each name with its instrument, its trigger and its data source, so that the names cannot be swapped without the difference showing. The table below states the positions in general terms.

Can a battery need both records?

A battery can need both readings where the battery is placed on the market as a battery under the Battery Regulation, and the product containing the battery later falls under an ESPR delegated act, or where a battery product is itself within an ESPR group. In that case the battery passport satisfies the Battery Regulation for the battery, and the ESPR passport, where required, satisfies the ESPR for the product, and the two records should each be satisfied on their own terms, with the identifier link between battery and product recorded. The double reading should be mapped product by product, rather than assumed to collapse into one record, until the relevant delegated act states otherwise. A single record that is assumed to satisfy both instruments without a mapping risks satisfying neither.

How should the names be used in a file?

The names should be used in a file with the instrument attached, so that every passport reference states whether it means the battery passport under Regulation (EU) 2023/1542 or the digital product passport under Regulation (EU) 2024/1781, with the article and the date. A file that uses the word passport without an instrument label forces a later reader to guess, and guessing across two instruments is a reliable source of error. The labelling discipline is the same as the jurisdiction labelling discipline in the international cluster, applied to instruments rather than territories, and it should be applied in every guide, record and file that mentions either passport.

What limits apply to this distinction?

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