The EU Missed Its August Deadline, but February 2027 Stands

The EU broke its own promise, but companies’ deadline hasn’t moved.

August 18, 2026 was supposed to be the day the European Commission finalized the access rules for the battery passport. That day came and went without the implementing act¹, and the Commission’s own timetable for digital product passports has since pushed that act back to Q4 2026. Starting February 18, 2027, electric vehicle batteries, light means of transport batteries, and industrial batteries with a capacity above 2kWh must carry a QR-code-accessible battery passport before they can be placed on the EU market or put into use. Light means of transport² refers to lightweight mobility devices like e-bikes and electric scooters.

This is where the program stands right now: the rules are arriving late, but the deadline is fixed. So the first task in practice isn’t counting down the days left — it’s separating what will actually be required by February 2027 from what hasn’t even started yet. Open the guidance document the Commission updated as of August 15, and that boundary turns out to be clearer than you’d expect.

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Who’s covered isn’t about capacity — it’s about who puts the finished product on the market

Three types of batteries need a passport: EV batteries, light-transport batteries, and industrial batteries above 2kWh. Home energy storage systems fall under the industrial-battery category too. Portable batteries, automotive starter batteries, and industrial batteries at or below 2kWh are not covered by the passport requirement. Other provisions of the regulation still apply to them — just not the passport.

That much is widely known already. Where practical judgment starts to diverge is what comes next. The Commission has specified that the duty to create and maintain the passport rests with the economic operator³that places the finished battery on the market — not with suppliers of individual components or modules. The same point came up again at a briefing in May 2026. The passport attaches to a completed battery, not to a module or pack that still needs further assembly. If it’s made inside the EU, the manufacturer bears the obligation; if it’s brought in from outside, that falls to the importer or an authorized representative.

So the question a components-and-materials company should be asking isn’t “do we have to issue a passport.” It’s “which of our customers is the one on the hook for the passport, and what will that customer end up demanding from us by February 2027.” Those two questions call for entirely different kinds of preparation. The first is a systems-building problem. The second is a data-contracts-and-form-negotiation problem.

One more thing worth locking in early: the passport attaches to each individual battery unit, not to a model line. The unique identifier and QR code correspond to a single physical unit, and registration runs through a digital product passport registry that the Commission operates. That registry opened on July 20, 2026, and the implementing regulation governing its operating rules took effect on August 6. To register, an economic operator must first obtain economic-operator verification built on an electronic identification framework, and that verification has to be renewed every 3 years.

Of 71 Fields, 15 Are Left Blank for EVs

The Directorate-General for Internal Market’s guidance document, version 2.0, dated August 15, counts every field that goes into the passport one by one, and for each field marks whether it’s mandatory, optional, or conditional for EVs, light means of transport (LMT), and industrial batteries. I downloaded this table myself and counted it directly. There are 71 fields in total, and tallying the status of each by category gives this:

Category	EV	LMT	Industrial (>2kWh)
Total fields	71	71	71
Fields not filled as of February 2027	15	12	12
Remaining fields	56	59	59

The details of the 15 fields left blank are the most practically useful part of this document. Excluding 2 fields removed as duplicates (material composition, rated capacity), the carbon footprint declaration and label, responsible mineral sourcing information, and the recycled-content ratios for cobalt, lithium, nickel, and lead are all marked “not filled as of February 2027.” These are, by and large, exactly the fields people picture when they hear “battery passport.”

The reasons differ slightly from field to field. For carbon footprint, there’s still no implementing act defining the reporting format. For recycled-content ratios, application depends on a delegated act⁴ under Article 8 of the regulation setting out the calculation and verification methodology — and as of early September 2026, the draft was still out for public consultation. The reporting obligation itself is set for after August 2028, and could slip further depending on when the act enters into force. Responsible mineral sourcing is tied to the supply-chain due diligence⁵ obligation, which has been pushed back two years, from August 2025 to August 18, 2027. This change was finalized in July 2025 as part of the fourth Omnibus simplification package.

One thing needs to be made clear here: this delay did not touch the passport dates. I’ve actually seen several materials that read the shift of the due diligence obligation to August 2027 as “the passport got delayed too,” and some commercial guidance pages still say it has been “in effect since August 2025.” It’s an obligation that never started. If you put a confirmed obligation and an obligation that hasn’t even begun into the same slot on your preparation timeline, you end up misallocating budget on both sides.

It’s also easy to miss that the table changes depending on battery type. The health-status fields are the clearest example. EVs fill in only the certified energy status field and leave the other five blank, while LMT does exactly the opposite — filling those five and leaving certified energy status blank. The two categories don’t share a single health-status field in common. For industrial batteries, more than twenty of the remaining 59 fields are marked “if applicable,” meaning applicability has to be determined separately for each product.

The weight of the remaining fields falls on suppliers

So are the remaining 56 fields, once you exclude the 15, the easy ones? Half of them, yes. Manufacturer name and address, model and batch number, place and time of manufacture, weight, capacity, chemical composition, voltage range — most of these values already sit in spec sheets or ERP systems.

The problem is the other half. The items in the second batch of Annex 13 of the regulation⁶ are mandatory across all three categories. Detailed composition — including the materials used in the cathode, anode, and electrolyte — part numbers by component, contact information for replacement-parts suppliers, and disassembly information. Disassembly information even includes exploded diagrams of the battery system, the disassembly sequence, and the tools required. The list of critical raw materials exceeding 0.1% by weight is already mandatory under the first batch, too.

These values are usually not held by the cell manufacturer alone. They have to come up from the cathode-material, anode-material, and electrolyte companies, as well as parts suppliers. The obligation to issue the passport sits with whoever puts out the finished product, but the raw data for the required fields is scattered across the tiers above them.

And this batch is exactly where it overlaps with the access-permission problem mentioned earlier. Detailed composition and disassembly information aren’t in the open zone anyone can view by scanning a QR code — they sit in a restricted zone accessible only to “parties with a legitimate interest.” The design has repair shops and recyclers in mind, but the implementing legislation that will define who qualifies for that access, and whether they can download or reuse the data they receive, hasn’t been issued yet. Suppliers are being asked to hand over data that borders on trade secrets, while it remains unsettled who will actually get to see it. That’s reason enough for a supplier to hesitate before submitting.

Domestic readiness splits along this same line. A survey released in August 2026 by the Korea Chamber of Commerce and Industry (Daehan Sanggong Hoeuiso) and the Korea Industrial Complex Corporation (Hanguk Saneop Danji Gongdan), covering 300 export companies, found that 99.3% of respondents said they had already been asked, or expected to be asked, by customers to submit carbon-emissions data. 90.3% said they were already making, or planning to make, the same demand of their own suppliers. But when asked (multiple choice allowed) how they manage this data, 66.3% said they use in-house systems, 42.4% said Excel or manual documents, and 38.8% said separate formats specific to each customer. In other words: the demand has already arrived, but the formats are still all over the place.

Among Korea’s three major battery makers, industry reporting confirms some movement. LG Energy Solution has built an integrated management system linking the data the passport requires to its internal systems, and has a product-level carbon-footprint calculation system in place. Samsung SDI is running a passport pilot program as part of the Global Battery Alliance. SK On has built an information flow running from parts suppliers through cell manufacturers to automakers, and has piloted the passport-issuance process. That said, this is drawn from industry reporting rather than official disclosures or announcements, so it’s hard to judge from this alone just how far each company’s preparations actually extend.

Oswarld’s Lens

This structure felt familiar to me. I’d been wrestling with almost the exact same problem while building a service called Customs Note. It’s a service where you enter a single bill of lading number and it pulls together everything on one screen — customs clearance status, HS classification codes, tariff rates, import requirements, related regulations, and trade statistics. A big chunk of the build time went into actually integrating six types of Korea Customs Service (KCS) public data and securing 53 different authentication keys. This service won an award at the 2026 KCS Public Data & AI Startup Competition.

Customs Note — A workspace that never interrupts your customs workflowHS classification, tariff rates, regulations, case law, and AI consultation — all on one screen. A workspace built for customs practitioners.customsnote.kr

One decision I made while building it overlaps exactly with this week’s topic. Having AI suggest candidate HS classification codes is convenient. But I made the AI’s suggested candidates get re-verified against official KCS data, and I blocked any unverified code from ever showing up on screen at all. Leaving a blank field was uncomfortable, but I judged that a field filled in without grounds was far more dangerous. The cost of walking back a wrong number submitted to customs is nowhere near comparable to the discomfort of an empty field.

The battery passport is data of the same nature. It’s a record that market surveillance authorities will open up in February 2027, and every single value in it is a number that gets traced back later. So I find it hard to readily agree that building the system should be step one in preparation. What’s needed before that is writing down, for every single field, “where did this value come from, and who’s accountable for it.” A field with no source is better left empty for now. If a company starts filling in values it couldn’t get from suppliers with internal estimates, those estimates will harden into the baseline once the carbon footprint and recycled-content fields switch on in 2028.

Let me flag one caveat. I drew this judgment from customs-practice data, and the battery supply chain has more layers and different sensitivities around trade secrets. Whether a supplier hands over detailed composition data isn’t a data-design problem — it’s a matter of contracts and negotiation, and I can’t claim my experience transfers directly to that.

The Closing section is accurate and free of issues.

Closing

Only once you’ve determined whether your product falls into one of the three categories, whether your company is the obligated party rolling out the finished product or the one feeding data upstream, and which of the 71 items are actually switched on for your category — only then does the content of the request you’ll send to suppliers become clear.

The dates deserve careful attention. February 18, 2027 is written directly into the regulation’s text, so it’s hard to see it being pushed back for technical reasons. The detailed rules meant to fill in that framework, by contrast, keep slipping — they’ve already been delayed several times. The guidance document is at version 2.0, with a next version already flagged. For now, the most realistic approach seems to be tracking the passport’s existence obligation separately from what actually goes inside it.

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💬 At your company, is battery passport preparation owned by the regulatory affairs team, or by quality or IT? I’ve noticed the shape of the supplier request form changes quite a bit depending on which department holds it.

📨 If you have a colleague handling European exports, or one who’s started receiving supply-chain data requests, please pass along at least the table of 71 items.

References & Further Reading

Primary sources

• European Commission, “Digital Product Passport for Batteries (Battery Passport)”, 2026. : This is the Commission’s official page laying out scope, obligated parties, and the implementation timeline. It’s where you’ll find the line stating that the passport obligation falls on the economic operator placing the finished product on the market.
• European Commission DG GROW, “Guidance Document: Digital Batteries Passport – data points by category, Version 2.0”, 2026.8.15. : This is the original source behind the 71-item count cited in this piece. It contains a table mapping each data point to its legal basis and its applicability by category.
• European Union, “Regulation (EU) 2023/1542”, 2023.7.12. : Article 77 establishes the passport obligation, and Annex 13 sets out the data points and their access tiers.
• Council of the EU, “Simplification: Council adopts law to ‘stop-the-clock’ on due diligence rules for batteries”, 2025.7.18. : This is the basis for pushing the due-diligence obligation back to August 2027. It confirms that the passport deadline itself was left untouched.
• Herald Business (Herald Gyeongje), “As overseas environmental regulations tighten, companies are left to manage carbon data on their own”, 2026.8.19. : This lays out, figure by figure, the results of a survey of 300 exporting firms conducted by the Korea Chamber of Commerce and Industry and the Korea Industrial Complex Corporation.

Background

• Maeil Ilbo, “[Feature] DPP regulation spreads from batteries to home appliances… Korea still at the crawling stage”, 2026.9.6. : A reported piece surveying how Korea’s three major battery makers, along with the tire and appliance industries, are preparing.
• Sourcemap, “Commission Hosts Info Session on EU DPP Implementation for Batteries”, 2026.5.28. : A summary of the Commission’s briefing session, including the point that modules and packs still awaiting assembly are not required to carry a passport.

Related past issues

• What BYD’s 5-Minute Charging Really Tells Us: It’s Not About Charging Speed, It’s About Industrial Structure

The author is Oswarld (Kwangseob Ahn). Current roles: Adjunct Professor at Sejong University, Strategy Consultant at INLEVEL9. Career, research, books, and recent work are kept current on the About page. Latest · July 2026: HEMA-2: A Consolidation-Aware Tri-Memory Architecture with Multi-Channel Scheduling for Lifelong Conversational AI.

📝 Glossary

Footnotes

1. Implementing act: A subordinate piece of EU legislation through which the Commission sets detailed procedures to ensure rules already established in EU law are applied uniformly across member states. It’s adopted after review by a committee of member-state representatives. ↩

2. Light means of transport (LMT) battery: A battery used in lightweight mobility devices such as e-bikes and electric scooters. This is a category the EU Battery Regulation classifies separately. ↩

3. Economic operator: An EU legal term referring to the party placing a product on the market. It covers manufacturers, importers, authorized representatives, and distributors, with obligations varying by role. ↩

4. Delegated act: A piece of legislation through which a higher-level regulation hands the Commission authority to set technical details. It’s typically used for matters requiring specialized expertise, such as calculation methodologies. ↩

5. Due diligence: The process by which a company itself verifies where and how raw materials like cobalt, graphite, lithium, and nickel were sourced, and manages the associated risks. It bundles together policy-setting, risk assessment, third-party verification, and public reporting. ↩

6. The second tier of Annex 13: Annex 13 of the regulation divides passport data points by who is permitted to view them. The second tier is a restricted band viewable only by parties with a legitimate interest and by the Commission itself, and it’s where detailed composition and disassembly information sits. ↩