From 18 February 2027, a battery passport – the first implementation of a Digital Product Passport (DPP) in the European Union – will become mandatory for batteries in electric vehicles, light means of transportation, and industrial applications above 2 kWh placed on the EU market.
While it is on the verge of implementation, the discussion on DPPs and their potential is ever-deepening: From its usage to enable circular economy to its linkage to many more data-based processes. The European Commission plays its part in this discussion and deliberates integrating DPPs into further administrative processes for products through the European Product Act in Q3 2026. Therefore, an expanded scope for DPPs seems likely – beyond already existing horizontal obligations under the Ecodesign for Sustainable Products Regulation (ESPR), and ‘vertical’ product-specific legislations like the Battery Regulation or Construction Product Regulation (CPR) that introduce DPPs.
This article intends to address how this broader scope may look like: How DPPs may reshape administrative processes in the future; what potential benefits for companies, authorities, and end-users in the EU Single Market there are – and challenges on the road to an effective contribution of DPPs to efficient administrative processes.
Status quo: Are DPP data machine-readable and compatible?
One foundation for reshaping administrative processes is ensuring that data is made available in a machine-readable format, enabling greater digitalisation and automation. The battery passport and DPPs under the CPR and ESPR require data to be machine-readable. Many data points, such as battery weight or data describing the critical performance functions of a product, can relatively easily be provided in structured, directly machine-readable formats. Other types of information, however, are more complex and may currently exist in longer documents or descriptive formats rather than as discrete data fields, requiring additional processing or structuring before they can be used in automated systems.
To ensure that the requirement of machine-readability achieves its intended effect also for more complex types of information, clearer standards and guidance are needed. These should promote genuinely structured information and machine-readable data formats, helping to unlock the potential for automated processing and more efficient administrative procedures.
Another important aspect is that data needs to be compatible across legislation. Particularly vertical regulations such as the battery regulation, construction products regulation or toys safety regulation are not fully aligned in their phrasing of data requirements. As a result, common semantics are still lacking. Now, at the dawn of DPPs, this may not yet be an imminent issue. However, the challenge will scale with the number of product categories with DPPs (see below) and therefore needs to be addressed to enable data flows across industry sectors.
Which benefits do DPPs bring to administrative processes?
With properly structured, machine-readable data in place, DPPs have the potential to transform administrative processes across the EU Single Market. The core principle is that product data is provided once and can then be accessed by the public or actors with a legitimate interest. This enables more efficient workflows for authorities, companies, and consumers alike. In practice, this means that paper-based multi-reporting can be eliminated, authorities can directly retrieve data and render it to their liking, and a single DPP may serve multiple regulatory requirements.
- European Union & Public Authorities:
DPPs can help safeguard the Single Market under high product volumes and be an option to get a better handle on the extreme number of packages entering the EU Single Market by enabling more targeted, data-driven market surveillance: Authorities can access harmonised information for compliance checks instead of chasing scattered documents across borders.
- Companies:
DPPs may reduce administrative burdens and increase automation, if it eliminates the need for separate submission of differently formatted data and varying requirements to different authorities. The concept of ‘paperless conformity’ becomes possible when notified bodies and authorities work with authenticated digital data and can ensure confidentiality. At the same time, a harmonised DPP framework can create a level playing field as international competitors must report on the same transparency standards to enter the EU market and bad actors can be identified more easily. Moreover, the requirement to provide product data in the national language can in the future be handled more automatically, enabling small and medium-sized businesses to access new markets more easily.
- Consumers:
DPPs aim to provide trustworthy information on product safety, durability, repair options, environmental performance and end-of-life handling. For batteries and construction products, this includes better insight into hazardous substances, recycled content, expected lifetime and available collection or recycling schemes, supporting more informed purchasing decisions and greater confidence in sustainability claims.
Challenges on the Way to Interoperable DPPs
While DPPs have significant potential, practical challenges remain. Data interoperability, reporting practices, and regulatory alignment all need careful attention to make DPPs fully effective.
First, fragmented reporting requirements and limited regulatory alignment add hurdles to efficient administrative processes. Currently, companies often submit similar information multiple times across separate templates and channels, increasing administrative burden. Consolidating product data in DPPs as a single source supported by interoperable and machine-readable data structures, can help reduce duplication and facilitate more automated processing. When combined with harmonised regulatory requirements, e.g. on chemicals or due diligence, such as those being developed in the Omnibus legislation, this approach would make DPPs an even more effective tool.
Second, data compatibility is crucial: product-specific regulations, e.g. for toys, construction products, batteries – so far – each come with their own semantics on data requirements that are hardly aligned. Even semantics that cover all battery applications are a significant challenge in the absence of an elaborate guidance by authorities or mandated, comprehensive standards. Common reference dictionaries and semantics, that are aligned or at least compatible, are the key to avoid isolated “DPP islands” and efficiency in handling DPPs across product categories and, particularly, for products with a high number of components with DPPs, like vehicles for example. The current JTC 24 drafts already reflect this goal, as they add a dictionary reference to any data point in a DPP via a definition repository. Still, actual implementation and governance of a definition repository will take a while and significant effort of actors along and across value chains, although underway today.
Third, data quality and verification and confidentiality pose further challenges. The battery passport does not foresee detailed verification for most data, leaving potential gaps for inaccurate or fraudulent data. How authorities and market surveillance bodies detect and handle such cases poses an important issue for consideration. In addition, confidentiality of data and the closely related IT security and trustworthy handling of access-restricted data is a major factor for companies to commit to digital data exchange, particularly those involved in conformity assessment. Companies must be able to trust that crucial IP-related data cannot be accessed by unauthorized third parties. That particularly includes a sensitive approach to the governance of access management and roles therein. Even for the battery passport it has not been outlined yet, how the umbrella term ‘persons with a legitimate interest’ will be broken down into different roles, and the corresponding implementing act likely won’t be available before Q4/2026[1].
As a bottom line to these challenges, political and technical readiness are essential to reap the benefits of DPPs. While their increased implementation in administrative processes will only happen in the coming years, the roadmap to that point should consider the issues above. That also includes for public authorities to be ready: authorities such as market surveillance need both the political mandate, knowledge and technical capability to leverage DPPs and make administrative processes subject to innovation.
Outlook: BatteryPass-Ready and the Road to Future DPPs
From 18 February 2027, the battery passport will be the first real-world implementation of the EU DPP concept and a blueprint for future DPPs in other sectors. BatteryPass-Ready contributes practical test insights to address early implementation challenges and support data validation, offering an approach to translate regulatory requirements into a machine-readable and testable form. Find out more about the project’s work in our recent articles about user stories, functionalities of the testing environment, and the enterprise model about the battery passport ecosystem.
As more products get a DPP under the ESPR and other legislation after 2027, the potential impact of DPPs across the Single Market will grow significantly. To realise its potential, future DPPs will need clear governance, robust data, and solutions that work for both large players and SMEs. If these conditions are met, DPPs can evolve into a versatile digital instrument that strengthens EU competitiveness.
Rebecca Ebner, Manuela Hafner, Johannes Simböck
acatech
[1] https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/16473-Batteries-access-rights-to-certain-parts-of-the-battery-passport_en
