Battery Passport vs Digital Product Passport: What's the Difference?

The EU battery passport is not a rival scheme to the Digital Product Passport (DPP) — it is a Digital Product Passport, and specifically the first one with a binding deadline anywhere in EU law. "Battery passport" names the specific case; "Digital Product Passport" names the general family it belongs to.

That relationship is the genuinely interesting part of this story, and it is also the part most explainers get vague about. This post is the comparison: two legal instruments, two data models, one shared registry, one shared standards stack, and — because the dates do not line up — a clear answer to which obligation actually lands on your desk. For what a battery passport is in plain terms, start with our guide to the Regulation; for the wider DPP landscape beyond batteries, see the Digital Product Passport pillar guide.

Two instruments, one shared idea

The Digital Product Passport is not itself a single regulation. It is a design pattern — a machine-readable, standards-based record attached to a product — introduced as a general framework by Regulation (EU) 2024/1781 (OJ L, 2024/1781, 28.6.2024; CELEX 32024R1781), the Ecodesign for Sustainable Products Regulation (ESPR). ESPR does not itself require any product to carry a passport. It empowers the Commission to require one, product group by product group, through delegated acts under its Article 4.

The battery passport did not wait for one of those delegated acts. It was written directly into sector-specific law: Regulation (EU) 2023/1542 (OJ L 191, 28.7.2023; CELEX 32023R1542), the Batteries Regulation, whose Article 77(1) sets a fixed obligation and a fixed date without needing an ESPR delegated act to switch it on. That is why batteries got there first: the general framework was still assembling its machinery while the sector-specific rule already had a statute and a deadline.

Side by side

Which one actually applies to you

If you place an LMT battery, an industrial battery with a capacity greater than 2 kWh, or an electric vehicle battery on the EU market, Article 77(1) already binds you and the date above is fixed — no ESPR delegated act needs to exist for your obligation to be real. Note that "2 kWh" is the trigger for this obligation, not the legal definition of an industrial battery; Article 3(1)(13) is a two-limb test with no weight threshold on its design-purpose limb, which is easy to under-scope if you screen purely by capacity. Our battery categories page walks through that distinction in full.

SLI (starting, lighting, ignition) batteries and portable batteries are outside Article 77 by name — that exclusion is deliberate and worth stating plainly, because it is the most common question we get. As of July 2026 there is also no adopted ESPR delegated act bringing batteries in general under Article 4, so for those two categories neither instrument currently imposes a passport duty.

If your product is not a battery at all, the battery passport is irrelevant to you and your question is entirely about ESPR: has the Commission adopted a delegated act for your product group yet, and if so, what does it require? That is the question our Digital Product Passport pillar guide is built to answer, because the details vary by sector in a way a battery-specific site should not try to generalise.

Where the two obligations touch: the shared registry

The battery passport and the general DPP are not just conceptually related — they are wired into the same registry. Article 77(10) of the Batteries Regulation, a paragraph added by corrigendum and missing from the original 2023 Official Journal PDF, requires the operator placing a battery on the market to upload its unique identifier "in the registry referred to in Article 13(1) of Regulation (EU) 2024/1781." Commission Implementing Regulation (EU) 2026/1778 (OJ L, 2026/1778, 17.7.2026; CELEX 32026R1778) built that registry, and its Article 1 scope names, in the same list: "(a) products covered by delegated acts adopted pursuant to Article 4 of Regulation (EU) 2024/1781; (b) batteries covered by Article 77 of Regulation (EU) 2023/1542" — plus construction products, toys and detergents. One registry, several legal bases feeding it.

We cover the registry itself — upload deadlines, the national administrator requirement, and the still-missing Article 77(9) access-rights act — in a dedicated deep dive. The point worth taking from it here is narrower: the registry is the strongest evidence that "battery passport" and "Digital Product Passport" are not two systems, they are one system with two entry points.

Same standards, no shared presumption of conformity

Both instruments point engineering teams at the same standards stack. Commission Implementing Decision (EU) 2026/1736 (OJ L series, 15.7.2026; CELEX 32026D1736) cites EN 18216 (data exchange protocols), 18219 (unique identifiers), 18220 (data carriers), 18221 (data storage and persistence), 18222 (APIs) and 18223 (system interoperability) — the same six a battery-passport implementation would build against for identifiers, carriers and interoperability. Two further standards in the same family, prEN 18239 and prEN 18246, were still under vote as of mid-July 2026 and are not yet published.

The nuance is in what that citation does not say. The Decision's title and legal basis name Regulation (EU) 2024/1781 only; Regulation (EU) 2023/1542 appears solely in a footnote noting that 2024/1781 amended it. Presumption of conformity attaches to the legislation a standard is cited under, and nothing equivalent has been cited under the Batteries Regulation — an absence, not a Commission statement, but a real one. Build against EN 18216–18223 for interoperability regardless; they are still the best available description of what a portable, machine-readable passport looks like.

What this means for a compliance plan

• Batteries in scope: stop waiting on ESPR. Article 77(1) is self-executing law with a date. Nothing about the general DPP framework needs to move first.
• Batteries out of scope (SLI, portable): there is genuinely nothing to build yet. Watch for a future ESPR delegated act rather than trying to anticipate Annex XIII rules that do not apply to you.
• Non-battery products: this site is the wrong place to look for your deadline. Track your own product group's delegated act; the battery passport timeline tells you nothing about when yours lands.
• Everyone: the registry and the standards are shared infrastructure. An identifier scheme and a data-carrier choice built against EN 18219 and EN 18220 now will still be the right choice once your own sector's delegated act catches up.

For the full field-by-field data model, see data requirements; for the complete obligation calendar, see compliance.