The battery passport will apply to three categories from 18 February 2027

18 February 2027 is the first implementation deadline for the digital product passport described by the Commission. For suppliers of traceability, data, integration and testing services, the commercial scope must be established from the covered categories and each company's legal role.

The three categories covered by the deadline

Article 77 of Regulation (EU) 2023/1542 provides for a battery passport from 18 February 2027 for three specific categories. These are batteries for light means of transport, industrial batteries with a capacity above 2 kWh and electric vehicle batteries. The Commission presents this date as the first implementation deadline for the digital product passport. The timetable therefore creates a common qualification point for the companies concerned.

The 2 kWh threshold applies to industrial batteries, but not to the category of batteries for light means of transport. Portable batteries and industrial batteries of 2 kWh or less are not automatically covered by this deadline. A company operating in the battery sector cannot therefore be considered affected solely on the basis of its sector. The exact product category must be verified before any commercial approach.

The company's role must be verified

Qualification must focus on the manufacturer or importer of a covered battery category. We must also confirm that the battery is placed on the European Union market. These two elements distinguish a company that is directly concerned from a stakeholder involved with a different product, territory or legal role. The Regulation does not support the assumption that every company in the same value chain has an identical need.

A battery may also be integrated into another product, with a different allocation of responsibilities. This situation requires an understanding of who actually holds the role associated with placing it on the market. Activities outside the relevant product scope, territory or legal role must be excluded. No uniform legal threshold should be added to the criteria explicitly provided for the categories covered.

Potential needs relate to data and its control

Suppliers may contribute to traceability, identification, data hosting, integration or testing. These capabilities correspond to several potential components of a battery passport system. However, they do not mean that a project is open at every relevant manufacturer or importer. An industry regulation demonstrates neither the existence of a budget nor an active search for a service provider.

Commercial qualification must therefore include the data system already selected by the company. Some organisations may have chosen a provider before the initial contact. Others may have an internal solution or an integration led by another stakeholder. Identifying the status of this decision avoids treating the regulatory deadline as evidence of an immediate opportunity.

What this changes for suppliers

The 18 February 2027 deadline provides a precise timeframe for organising prospecting. We recommend starting by confirming the battery category, its capacity in the case of an industrial battery, and whether it is placed on the European Union market. The next step is to determine whether the company acts as a manufacturer or importer. This sequence enables out-of-scope accounts to be excluded quickly.

The initial contact can then focus on the capabilities actually offered by the supplier, whether traceability, identification, hosting, integration or testing. We also check whether a data system or provider has already been selected. The accounts that remain worth pursuing are those combining a covered category, a relevant legal role and a need that can still be addressed. This method reduces outreach based solely on general involvement in the battery sector.