One family, two regulations: battery passport vs the ESPR DPP.

The terms get used interchangeably, but they are not the same thing. The battery passport comes from the Batteries Regulation (EU) 2023/1542 and has a fixed date: 18 February 2027. The digital product passport under ESPR (EU) 2024/1781 is a framework that reaches product groups one delegated act at a time, starting with iron & steel and textiles. Think of the battery passport as the first, fully specified member of the DPP family — the template everything else will resemble.

In one line: the battery passport is the first, fully dated member of the digital product passport family — its own regulation (2023/1542) and its own deadline (18 February 2027) — while ESPR DPPs (2024/1781) arrive product group by product group via delegated acts.

Two legal bases, one idea

Both instruments answer the same question — what is this product, what is it made of, and what happens to it at end of life — as a structured digital record attached to the physical product. The difference is how they arrive. The battery passport sits inside a complete, sector-specific regulation: (EU) 2023/1542, Article 77, with scope and deadline written into the law itself. The ESPR DPP sits inside a framework regulation, (EU) 2024/1781 (in force since July 2024), that defines the machinery but leaves each product group's requirements and timing to a delegated act. One is a finished rulebook; the other is a rulebook factory.

Side by side

Legal basis — battery passport: Batteries Regulation (EU) 2023/1542. ESPR DPP: Regulation (EU) 2024/1781 plus per-group delegated acts.
Timing — battery passport: fixed, 18 February 2027. ESPR: no single go-live; first delegated act expected around 2026 (iron & steel), textiles indicatively 2027, obligations biting roughly 18 months after each act enters into force.
Scope — battery passport: EV batteries, all LMT batteries (no threshold), industrial batteries above 2 kWh, including batteries incorporated into products. ESPR first wave: textiles, furniture incl. mattresses, tyres, iron & steel, aluminium.
Data — battery passport: around 110+ defined data points, with DIN DKE SPEC 99100 as guidance. ESPR: data requirements set per delegated act.
Out of scope — portable consumer batteries (laptops, phones, power tools) get labelling and collection rules, not a battery passport.

Where they converge

The family resemblance is deliberate. Both rely on a data carrier on the product — GS1 Digital Link QR codes or Data Matrix — resolving to a structured record. Both put responsibility on the economic operator placing the product on the EU market, which catches importers of finished goods, not just manufacturers. Both demand the record stay accessible for the product's regulated lifetime — up to 15 years, which means custody and backup, not a PDF on a web server. And the shared infrastructure is arriving: the EU DPP Registry opens for registration on 19 July 2026. Enforcement follows the same pattern too — customs can detain non-compliant goods, and member states set the penalties.

Why one platform makes sense

Many companies will face both regimes: an equipment maker with a >2 kWh battery inside an ESPR-relevant product, a mobility brand selling accessories and apparel, a steel-using manufacturer with battery-powered lines. Running two compliance stacks doubles the cost of what is fundamentally one discipline — structured, verifiable, maintained product data. PassPer builds battery passports for the 2027 deadline today — AI extraction from the spec sheets and declarations you already hold, human review, eIDAS qualified seal, GS1 Digital Link QR, registry filing on EU-sovereign hosting — and the same foundation extends to ESPR product groups as their delegated acts land. Start with the free readiness check or the 2026 compliance guide.

Frequently asked questions

If we comply with the battery passport, do we automatically have an ESPR DPP?

Not automatically — the battery passport satisfies the Batteries Regulation, and any ESPR obligation on your other products would come from its own delegated act. But the hard work overlaps heavily: structured product data, supplier evidence, QR carriers, registry filing. Battery-passport compliance is a very large head start on any future DPP.

Which obligation arrives first?

The battery passport: it is mandatory from 18 February 2027 for EV batteries, all LMT batteries and industrial batteries above 2 kWh. On the ESPR side the first delegated act — expected around 2026 for iron and steel — starts the clock, with company obligations biting roughly 18 months after it enters into force and textiles indicatively following in 2027.

Is an e-bike battery covered by the battery passport or by an ESPR DPP?

The battery passport. E-bike, e-scooter and e-moped batteries are LMT batteries under Regulation (EU) 2023/1542 and need a passport from 18 February 2027 with no capacity threshold. ESPR delegated acts cover other product groups on their own timelines.

Do we need two separate systems for battery passports and DPPs?

No. The two share the same architecture — structured data, verifiable records, QR access, long-term availability — so one platform can serve both. PassPer builds battery passports today and the same data foundation carries into ESPR product groups as their delegated acts land.

See where you stand — three ways, all free.

Take the 2-minute readiness check, watch the 10-minute interactive walkthrough, or download the full 2026 compliance guide. No account needed.

Free readiness check → See it in action Get the guide (PDF)