The battery passport is a data-ownership problem, not a labelling problem.

The battery passport requirement is being treated inside most manufacturers as a labelling and QR-code workstream, owned by packaging or engineering. That framing is wrong, and it is the single most common reason readiness programmes stall. The obligation is to publish a defined set of product, material, performance, and due-diligence data per battery, kept accurate over the product's life, and reachable through a data carrier by parties with different access rights. Almost none of that data lives in one system today, and much of it is not yours — it sits with cell suppliers, recyclers, and testing partners. The work is therefore governance: who owns each field, who is contractually obliged to supply it, and who signs off that it is correct.

If you place batteries or battery-containing products on the EU market, start from your bill of materials and mark every required field as available, derivable, or supplier-dependent. Supplier-dependent fields set your real timeline, because renewing contracts and getting attested data back typically runs two to three quarters. Expect your PLM or ERP to be the system of record and the passport platform to be a publishing layer — not the other way round.

Importers carry the same substantive exposure with less leverage: you are accountable for data you did not create. Certifiers and notified bodies should assume clients will arrive with incomplete provenance and plan verification capacity accordingly.

• 18 Feb 2027 — battery passport applies to industrial, LMT, and EV batteries in scope; obligation sits with the economic operator placing the battery on the market.
• Rolling ESPR delegated acts — each act switches on category-specific DPP requirements; stationary storage, electronics, steel, and textiles are in the current working plan.
• Now — supplier contract renewals are the practical deadline; data clauses added late cost far more than they do at renewal.

The teams furthest along are doing three unglamorous things. They appointed one accountable data owner per field and published that list internally. They added data-supply and attestation clauses to supplier agreements at the next scheduled renewal rather than reopening contracts. And they built a thin internal register first — a spreadsheet, then a table in the PLM — so the vendor decision came after the data model was understood, not before. The teams that are behind almost all selected a platform first and are now negotiating scope changes.

GS1 Digital Link. Worth understanding even if you have not chosen a passport platform: it defines how a single carrier resolves to different resources for different audiences, which is exactly the access-rights problem the passport creates. Getting the identifier and resolver strategy right early avoids reprinting carriers later.

• Commission ESPR working plan and delegated-act pipeline

  The order of categories tells you when your product line enters scope.

• Battery Regulation Article 77 and the battery-passport provisions

  Read this alongside your BOM: the data fields map to systems you may not own.

• CIRPASS / CEN-CENELEC DPP data-model work

  The identifier and data-carrier decisions here will outlive any vendor choice.

• GS1 Digital Link guidance for data carriers

  Cheapest place to get labelling right is before the first print run.

• National market-surveillance authority enforcement notes

  Enforcement patterns in one member state preview the rest.