Battery passports, DPPs, and EPDs in one playbook
Battery manufacturers planning new plants while selling into the EU juggle three asks that sound similar but are not: EPDs for embodied carbon disclosure, battery passports for each physical battery, and broader Digital Product Passport rules coming through ecodesign. The trick is building one data spine at plant level that feeds all three so teams avoid duplicate work and last‑minute scrambles.


Three acronyms, three scopes
EPD is the third‑party verified product disclosure most construction buyers already recognize. It reports life‑cycle impacts per declared unit and follows EN 15804 or ISO 14025 rules. Battery passport is a digital record tied to each individual battery with a QR code, including model data, plant location, and the verified carbon footprint. Digital Product Passport under the Ecodesign for Sustainable Products Regulation is a broader system that will phase in product‑category datasets across the EU.
Dates that set your roadmap
Battery passports are mandatory from 18 February 2027 for EV, LMT, and industrial batteries above 2 kWh, and must be accessible via QR code (Regulation EU 2023/1542, Annex XIII, 2023) (EUR‑Lex, 2023). Carbon‑footprint declarations apply per battery model and plant starting as early as 18 February 2025 for EV batteries and 18 February 2026 for rechargeable industrial batteries, subject to the delegated and implementing acts timing noted in the Regulation (EUR‑Lex, 2023). Due‑diligence obligations were postponed to August 18, 2027 to give industry and notified bodies more runway (Council of the EU, 2025) (Consilium, 2025).
ESPR entered into force on 18 July 2024, with the first work plan adopted in April 2025 and initial product rules expected to bite from 2027 to 2028 for early categories. Batteries already have their own passport under 2023/1542, but ESPR sets the shared plumbing for future digital product data flows (European Commission, 2024) (European Commission, 2024).
Plant metrics to capture now
Think like a showrunner. If the plant ledger is tight, every downstream episode runs on time. Prioritize primary data that moves results the most: electricity by meter or line, thermal fuels, yield and scrap, solvent and binder usage, process gases, water intake and discharge, on‑site renewables, internal logistics, and waste treatment. Pull supplier EPDs or verified LCI for cathode, anode, separator, electrolyte, casing, and packaging. Keep inbound and outbound transport distances and modes by lane.
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From plant ledger to product EPD
An LCA practitioner maps your inventory to modules A1 to A3 and beyond, selects the right PCR, and documents assumptions so results are comparable. If multiple plants make the same cell or pack, decide on separate plant‑specific EPDs or a consolidated EPD with declared variability. EPDs commonly run on five year cycles, so align today’s declarations to mature before or with 2027 passport go‑live.
How EPD results feed the battery passport
The Regulation requires the carbon footprint in kg CO2e per kWh, broken down by life‑cycle stage, and linked to the manufacturing plant and EU declaration of conformity. That is exactly the structure a robust product EPD produces when built from plant‑level primary data, then independently verified. The passport also needs a public link to the study that supports the footprint values, which your EPD dossier can satisfy where permitted by the scheme (EUR‑Lex, 2023).
Where Digital Product Passports meet batteries
ESPR’s DPP will not replace the battery passport. It sets shared rules for data carriers, access rights, and registries that make product information machine‑readable across categories. The overlap is beneficial. Master data you curate for the battery passport, like model identifiers, manufacturing location, material composition, and repair or state‑of‑health data models, will be reusable for ESPR product codes as they phase in (European Commission, 2024).
Build once, reuse everywhere
Use one data model for three outputs. Capture primary data quarterly in the MES and energy systems, keep supplier declarations organized by part number, and tag everything to a plant, line, and product revision. That cadence lets teams refresh EPDs on schedule, generate passport payloads at pack serialization, and answer DPP fields without another spreadsheet fire drill. It also keeps auditors happy when notified bodies review your footprint methods.
New U.S. plants selling into the EU
Design compliance into the factory. Specify sub‑metering per line, contract renewable electricity with credible tracking, and require suppliers to provide third‑party verified footprints for critical components. Set bill‑of‑materials governance so packaging, spares, and test cycles are captured. Draft purchasing clauses that allow sharing of necessary impact data into EPDs and passports. Get QA ready for QR code management and serialization.
Picking an LCA partner without the busywork
Look for hands‑on data collection support that reaches into utilities, maintenance, and procurement, not just a software portal. Demand clear PCR guidance, operator‑agnostic publishing options, and verification‑ready documentation. Ask how they align EPD modeling with the battery passport schema so one dataset can populate both, quickly. Speed matters when sales is chasing specifications and compliance gates at the same time. It should feel calm, not chaotic or unweildy.
Thread pulled tight
Treat the plant as your single source of truth. Feed that data into product EPDs that buyers understand. Then route the verified numbers and identifiers into battery passports and, soon, DPPs. One spine, three outputs, fewer surprises.
Frequently Asked Questions
Which dates actually matter for European battery passport compliance?
Digital battery passports are required from 18 Feb 2027 for EV, LMT, and industrial batteries above 2 kWh, with QR code access and specified content fields (Regulation EU 2023/1542, 2023) (EUR‑Lex, 2023).
Do we need separate EPDs for each plant or one global EPD?
You can publish plant‑specific EPDs or a consolidated EPD that reflects variability. Because the passport links footprint values to the manufacturing plant, many choose plant‑specific EPDs to simplify traceability and updates.
Is the DPP the same as the battery passport?
No. The battery passport is mandated by the Battery Regulation for specific battery types. DPP is a cross‑category framework under ESPR that will roll out product rules from 2027 to 2028 for initial groups. Batteries already have a passport pathway, but the data plumbing will align (European Commission, 2024).
What changed in 2025 on due diligence timing?
The EU postponed battery due‑diligence obligations to August 18, 2027 to allow industry and notified bodies more time to prepare (Council of the EU, 2025) (Consilium, 2025).
