While many imagine a product passport to be a label with more fields on it, it’s in fact a full, live data record that a QR code or RFID identification points to. We have seen similar consumer-facing, voluntary marketing ploys, like with coffee beans and olive oil tracing back to the farms they came from. But EU digital product passports are no marketing ploy, and getting the underlying system right matters more than choosing industrial identification and workplace safety solutions off the shelf.
Batteries First
The EU’s Battery Regulation (EU) 2023/1542 makes a digital passport mandatory from February 2027 onwards for each and every electric vehicle battery and industrial battery above 2kWh. At least those that are placed on the EU market.
The passport will carry five categories of data:
- Product identity (unique identifier, chemistry, capacity, manufacturer)
- Environmental data (lifecycle CO2 emissions per kWh and recycled-content percentages, such as for lead, lithium, nickel and cobalt
- Performance and lifecycle data (state of health and charge cycles) updated continuously
- Full materials composition down to raw materials and their country of origin
- End-of-life information (dismantling and recycling)
The technical implementation is very specific here, as the QR codes are built to the ISO/IEC 18004 standard, GS1 Digital Link URIs for product identification, and a unique serialized identifier is used for every individual battery rather than a single code per model. Product traceability and accountability will be improved dramatically, especially in a warmer climate, with higher EV usage, where battery risks are present.
The consequences for missing it are stark, as simple as being allowed to exist in the EU market or not. Market surveillance authorities can withdraw, recall, or impose a sales ban on anything that falls short, on top of whatever national penalty regime each member state sets.
Why This Isn’t Just a Batteries Problem
Batteries are just the first product category through the door, but the broader framework already exists: the Ecodesign for Sustainable Products Regulation (ESPR, (EU) 2024/1781), which came about in July 2024. It’s there to extend digital product passport requirements across other product groups over time, like textiles, iron and steel, aluminum, tires, paint, chemicals, and energy-related products are already named in it, with the first passport requirements for the likes of textiles and iron and steel are expected to start applying from around 2027 or 2028.
The pattern the Battery Regulation setting the unique identifiers, structured lifecycle data, machine-readable carriers, a central registry is something that we can expect to see again, with the ESPR expecting to reuse it rather than reinvent one for each new category.
What’s clear is that a manufacturer cannot just treat these passports as a box-ticking compliance exercise – it’s far more rigorous and fundamental than that, and it will permeate through your entire culture and operations.
What UK Manufacturers Actually Need to Build
Being outside the EU does not exempt a UK manufacturer from any of this. A digital product passport UK is export-driven rather than policy-driven. In other words, UK automotive companies are not selling just domestically – the EU will always be an important market to sell into. And, when selling into it, their electric vehicles, energy storage, electronics or advanced materials have to meet EU product compliance. The businesses most exposed are the ones whose product data still lives in spreadsheets, supplier emails, and paper certificates rather than a structured, queryable system. So even if only some of their sales are in the EU, it’ll likely make sense to revamp their entire system and incorporate a passport throughout their operations, rather than just patch the EU side.
The QR code labels or RFID tags themselves aren’t the real cost here, but the collecting and validating of data from every supplier across a multi-tier value chain. It has to be in a format that can be published and updated as products move through their lifecycle.
It’s the same discipline behind end-to-end, compliance-ready traceability systems that are already being built in adjacent regulated sectors like food supply. This is where the same underlying problem of having to prove where each unit came from and what happened to it gets solved – and it gets solved with the same combination of unique identifiers and structured records, not with paperwork.
Durable and uniquely serialized labels and tags are the layer of that system that we see and interact with. It’s important, and the innovations in moving away from barcodes to RFID are, in retrospect, absolutely vital. But it’s not the whole of it. A passport will have to be implemented into an ERP system, and building the backbone in 2026 against the fixed battery deadline is what puts a manufacturer ahead of the next category ESPR names, rather than starting cold when it does.
The businesses that find the February 2027 deadline straightforward will be the ones who spent 2026 building the data infrastructure, using ERP modules like Odoo to help, and treating it with full seriousness from top to bottom.
Spencer Hulse is the Editorial Director at Grit Daily. He is responsible for overseeing other editors and writers, day-to-day operations, and covering breaking news.
