We've been getting a lot of questions at Minespider about the EU Digital Product Passport (DPP) Registry. Can manufacturers register their battery passports already? Do they need to register their company themselves? And will their DPP provider handle registration for them?
We went through the European Commission’s registration process and latest guidance to see what companies can actually do right now. While you can already enroll your company and complete identity verification, you’ll still have to wait before you can successfully register a battery passport.
With the 18 February 2027 deadline approaching, here's what we've learned, what's changing, and what manufacturers should focus on now.
Key takeaways
- The EU DPP Registry is operational, but successful battery passport registration is not yet possible.
- Economic operators can begin company verification now, even if they plan to work with a DPP service provider.
- Battery passport semantic specifications are expected by the end of October 2026, with API integration guidelines planned for December.
- Battery passports must be registered at individual item level, based on what constitutes the finished battery.
- The 18 February 2027 deadline remains unchanged for the battery categories covered by the EU Battery Regulation.
Can you register a battery passport in the EU DPP Registry yet?
The Registry became operational in July 2026, following the adoption of Commission Implementing Regulation (EU) 2026/1778. Companies can already access the production environment, enroll their organizations, and complete identity verification.
However, the Commission's Registry User Guide confirms that successful battery passport registration remains unavailable because the required semantic catalog hasn't been defined. This catalog will establish the common data structures and formats the Registry needs to validate battery passports, which means manufacturers can prepare their information now but still can't complete the registration process.
Another question we often hear is whether manufacturers will need to upload their entire battery passport to the EU Registry. The answer is no. The Registry stores identifiers and registration information, including details about the responsible economic operator, while the complete battery passport remains hosted outside the Registry by the manufacturer or an authorized service provider.
For manufacturers, this means Registry registration adds another step to the battery passport process, but it doesn't replace the systems where product information is collected, managed, and updated. That work still happens outside the EU Registry.
What did the European Commission announce on September 30?
During its third battery passport webinar, the Commission provided a clearer timeline for the technical specifications manufacturers and DPP providers are waiting for.
The European Commission announced that battery passport semantic specifications and data formats for developers are expected by the end of October 2026, providing clearer guidance on how manufacturers need to structure their data to meet the Registry's validation requirements.
The Commission also outlined several other upcoming developments:
The webinar also included a live demonstration of organization verification, and the Commission confirmed improvements to verification error handling. It also announced further updates to battery passport data-point guidance and additional explanatory materials to help companies navigate the verification process.
These dates give manufacturers more clarity, but they are planned publication milestones rather than guarantees that all related functions will immediately be ready for production. In particular, publishing API guidelines doesn't necessarily mean successful API-based battery passport registration will become available at the same time.
What do manufacturers need to do for organization verification?
Manufacturers can start verifying their organizations in the EU Registry today, even if they intend to use a DPP provider for future passport registration.
The Registry needs to establish the identity of the economic operator responsible for the battery. For legal entities, the documented verification methods include a qualified electronic seal (QSeal) or another eligible electronic attestation of attributes issued under EU law. Natural persons and sole traders have different options, including a qualified electronic signature (QES) or an eligible high-assurance identification method.
Companies can consult the EU Trusted List Browser to find qualified trust service providers. The important distinction is that verification confirms who your company is, not whether your battery or its passport meets every regulatory requirement.
One of the questions customers regularly ask us is whether Minespider will be able to register passports on their behalf. The answer is “probably”. The EU framework provides for authorized third-party involvement, but the Commission is still finalizing the technical arrangements for service accounts and API integration. Until those details are confirmed, manufacturers shouldn't assume that publishing a passport through their DPP provider automatically registers it with the EU.
For companies already working with a DPP provider, the practical question is how Registry registration will fit into their existing workflows. Manufacturers shouldn't have to rethink how they manage their battery data every time a new technical requirement is introduced. The goal should be to connect these processes while keeping responsibilities clear.
"Manufacturers should not treat the battery passport as something they finish in February 2027. Batteries can remain in use for years, and the information around them will change. The economic operator is the one who is responsible for maintaining the battery passport throughout the life of every battery they put on the market. But we will be there to support them every step of the way."
- Nathan Williams, Founder & CEO of Minespider
Can manufacturers use existing identifiers and QR codes?
Existing identifiers and QR codes may still be suitable, provided they meet the applicable EU requirements.
The Registry requires a Unique Product Identifier that uses a resolvable HTTPS URL. An internal serial number alone isn't enough, but manufacturers can incorporate existing serial numbers into a compliant identifier structure. GS1 is one possible approach, but it isn't the only permitted identification scheme.
The QR code also doesn't need to point directly to the EU Registry. Its purpose is to provide access to the battery passport, which can remain hosted by the manufacturer or its DPP provider. Following successful registration, the Registry generates a separate registration identifier that is distinct from the battery's Unique Product Identifier.
For manufacturers that already have serial numbers and QR codes built into their production processes, this is an important point. Preparing for the Registry doesn't necessarily mean starting from scratch, but existing identifiers and access links need to be checked against the EU requirements before they are used for battery passport registration.
During the September webinar, the Commission explained that the standards referenced for QR codes and unique identifiers are expected to be updated through a delegated act in 2027, referring to EN 18219:2026 (Unique Identifiers) and EN 18220:2026 (Data Carriers). The currently referenced standards remain acceptable as equivalent standards in the meantime.
How will battery passports be registered?
The Commission has documented individual registration, bulk XML or JSON uploads, and API-based registration, but successful battery passport registration is not yet available through these methods.
The Registry User Guide describes individual and bulk registration procedures, while API integration guidelines are expected in December 2026. Both individual and bulk submissions depend on the battery-specific semantic specifications becoming available.
If the API isn't ready by February 2027, the documented web interface and bulk-upload methods could provide alternatives once battery registration itself becomes operational. However, the Commission hasn't confirmed a separate fallback procedure if the underlying technical infrastructure remains incomplete.
For manufacturers already creating battery passports through internal systems or a DPP provider, the question is how registration will fit into those existing workflows. Ideally, registering a passport should become part of the publishing process rather than another manual task. The Commission's upcoming API and service-account guidance will help determine what's technically possible.
Which batteries need a passport?
From 18 February 2027, battery passports become mandatory for electric vehicle (EV) batteries, light means of transport (LMT) batteries, and industrial batteries above 2 kWh that fall within the scope of the EU Battery Regulation.
The Registry requires registration at individual item level, rather than only at model or batch level. However, the relevant item is the finished battery, which may contain several cells, modules, or packs.
For example, where multiple packs depend on a shared battery management system (BMS) or other common components to function as one battery, the complete system may constitute the finished battery. Independently functioning batteries are assessed separately.
This is something we keep seeing in discussions with manufacturers: the way a company tracks cells, modules, and packs internally doesn't necessarily match the level at which the EU requires a battery passport. A manufacturer may track dozens of components within one system, but that doesn't automatically mean each component needs its own registered passport. Getting this distinction right early helps avoid unnecessary duplication while preserving the component-level information needed for servicing, replacement, and future lifecycle events.
Batteries placed on the EU market or put into service before 18 February 2027 generally don't require retrospective registration. However, certain lifecycle changes, such as remanufacturing or repurposing after the requirements apply, may trigger new passport obligations. A simple repair doesn't automatically require a new passport.
What battery passport data is required from February 2027?
Not all battery passport data becomes mandatory in February 2027, and the requirements vary depending on the battery category.
The Commission's battery passport data-point guidance identifies 71 data points and explains their applicability across different battery categories.
The guidance helps manufacturers distinguish between different types of requirements:
For example, some operational information may remain empty when a new battery is first registered because that information only becomes available during use. Battery status and applicable performance and durability information must still be provided where required.
In our work with manufacturers, we often find that the required information already exists, but rarely in one place. Manufacturing data sits in ERP or production systems, technical specifications are managed separately, and supplier information arrives in different formats. The challenge is connecting these sources and keeping the information accurate as the battery moves through its lifecycle.
The forthcoming semantic specifications will provide further technical definitions for how that information must be structured and formatted for Registry validation.
Who will be able to access battery passport information?
Not everyone will have access to the same battery passport information. The EU Battery Regulation distinguishes between public information, data reserved for authorities, and information available to stakeholders with a legitimate interest.
This is particularly relevant to repairers, recyclers, and second-life operators, who may need access to technical information that isn't publicly available.
The Commission is developing additional rules under Article 77(9) to clarify which stakeholders qualify for restricted access and what they can do with the information, including downloading, sharing, and reusing it.
During the September webinar, the Commission indicated that a committee vote was targeted for December 2026 or early January 2027. Until those rules are finalized, some access permissions remain unresolved.
What should battery manufacturers do now?
Manufacturers don't need to wait for the Registry API to start preparing. The most useful work is establishing the data, identifiers, and processes their battery passports will depend on.
Based on the questions we're seeing from customers, we recommend focusing on five priorities:
- Start organization verification. Identify the responsible economic operator, review the available electronic identification methods, and begin the Registry enrollment process.
- Review product identifiers and QR codes. Check that your existing serial numbers, URLs, and identifier structures meet the applicable requirements for identification and resolution.
- Map the required battery passport data. Use the Commission's guidance to understand which attributes apply to your batteries, where that information exists, and what still needs to be collected.
- Define the correct passport level. Determine which finished batteries require individual passports and how they relate to the cells, modules, packs, and systems you track internally.
- Prepare for ongoing updates and future integration. Make sure your systems can manage changing battery information, access permissions, and connections to the Registry once the remaining specifications become available.
The 18 February 2027 deadline remains unchanged, but preparing for battery passports shouldn't be viewed as work that ends on that date.
The Registry is one part of the battery passport journey. Getting registered will be an important milestone, but the real test comes afterward, when battery information needs to be updated, shared, and used throughout the product's life. The systems manufacturers build now should be ready for both.
For more practical guidance, explore our Digital Battery Passport guidance page, where we answer common questions about implementation, data requirements, and preparing for February 2027.
Frequently asked questions about the EU DPP Registry
1. Is the DPP Registry ready for Battery Passports?
The DPP Registry testing environment is already available, giving companies a way to familiarise themselves with the registration process before Battery Passports become mandatory in February 2027.
This does not mean every technical detail is final, but it does mean preparation can start now. Companies can review the available Registry guidance, test onboarding, map their Battery Passport data, and decide how registration will fit into their internal systems and workflows.
For manufacturers and importers, the Registry is no longer just a future requirement. It is becoming an operational part of Battery Passport compliance.
2. Who is responsible for registering a Battery Passport in the DPP Registry?
The economic operator placing the battery on the EU market, or putting it into service, is responsible for registering the Battery Passport in the DPP Registry.
A third party can support the process. For example, a manufacturer, OEM, implementation partner, or Battery Passport platform may help create, update, and manage passport data if authorised. However, this does not transfer the legal responsibility away from the responsible economic operator.
In practice, companies need a clear process for who owns the data, who manages updates, and how Registry registration will be handled.
3. Does the DPP Registry store the full Battery Passport?
The DPP Registry does not replace the Battery Passport itself. The full Battery Passport remains hosted and managed by the responsible economic operator or an authorised provider acting on its behalf.
The Registry primarily records registration information and metadata, supports verification workflows, and helps authorities access the relevant passport record where required.
That distinction matters: Registry registration is one part of compliance, not the whole Battery Passport solution. Companies still need a reliable system for collecting, structuring, maintaining, and sharing the underlying product, compliance, and lifecycle data.
4. Do batteries placed on the market before February 2027 need a Battery Passport?
Batteries placed on the EU market or put into service before the Battery Passport requirements apply do not automatically need a retrospective Battery Passport simply because the deadline arrives.
However, lifecycle changes can create new obligations. If a battery is remanufactured, repurposed, or prepared for reuse after the requirements apply, a new Battery Passport may be required. In those cases, the new passport should be linked to the previous one so the battery’s lifecycle history remains traceable.
A simple repair does not normally require a new Battery Passport. The key distinction is whether the battery has only been repaired, or whether it has undergone a more substantial lifecycle transformation such as remanufacturing or repurposing.
5. Does the Registry registration ID need to appear in customs declarations?
For Battery Passports, the Registry registration identifier does not need to be entered into electronic customs declarations.
The Battery Passport still needs to be registered in the DPP Registry, but the registration identifier is not currently required as a customs declaration field for batteries. This is an important distinction from some broader Digital Product Passport rules under the ESPR.
For companies importing batteries into the EU, the takeaway is that Registry registration remains necessary, but the customs declaration process does not currently require the Battery Passport registration ID.
