Battery Passport and the EU Registry: The Article 77(10) Obligation
The battery passport must be declared to the central European Digital Product Passport registry. The obligation sits in Article 77(10) of Regulation (EU) 2023/1542: the economic operator placing the battery on the market "shall upload the unique identifier in the registry referred to in Article 13(1) of Regulation (EU) 2024/1781". That registry has been open since 20 July 2026. It is the least discussed obligation in the battery framework — and it does not appear in the original version of the Regulation.
An obligation added after the fact
The Batteries Regulation of July 2023 predates the ESPR of June 2024. Article 77(10), as it appears in the consolidated version of Regulation (EU) 2023/1542, results from the articulation between the two texts:
The economic operator placing the battery on the market or putting it into service shall upload the unique identifier in the registry referred to in Article 13(1) of Regulation (EU) 2024/1781.
The cross-reference runs both ways, which settles any doubt about the article number. Article 13 of the ESPR, titled "Digital product passport registry", provides in paragraph 1 that the Commission shall set up the registry by 19 July 2026, and then states explicitly:
The registry shall store the unique identifiers for batteries as referred to in Article 77(3) of Regulation (EU) 2023/1542.
Each text names the other. Worth noting to avoid a common confusion: it is Article 13 of the ESPR that creates the registry — Article 12, immediately before it, covers unique identifiers, not the registry.
The consequence is simple to state and heavy in practice: a compliant battery passport on 18 February 2027 is not only a record reachable by QR code, it is also an identifier declared in a European registry. An implementation producing substantively perfect passports that are never declared to the registry remains incomplete.
What the registry holds — and what it does not
The central registry is a directory, not a product database.
| In the registry | With the economic operator or its provider |
|---|---|
| Unique product and passport identifier | Detailed passport content: composition, performance, durability |
| Reference of the responsible economic operator | Dynamic BMS data: state of health, cycles, events |
| Product category and classification data | Access-restricted data |
| Timestamp and proof of registration | Lifecycle history: repairs, repurposing, transfers |
That split follows from Article 78(c) of the Batteries Regulation, which requires passport data to be stored by the responsible economic operator or by operators authorised to act on its behalf — not by the Commission.
Who uploads, and when
Article 77(10) designates "the economic operator placing the battery on the market or putting it into service". That is the same party responsible for passport accuracy under Article 77(4): manufacturer, importer, or distributor treated as a manufacturer by Article 44.
The timeline joins two texts:
| Date | Event | Basis |
|---|---|---|
| 20 July 2026 | Central European DPP registry opens | Art. 13 ESPR |
| Summer 2026 | User guide for economic operators published and revised | European Commission |
| 18 February 2027 | Battery passport mandatory — and therefore unique identifier to upload | Art. 77(1) and 77(10) |
The technical framework for exchange
Registration is not done through a form but through an API. Standard EN 18222, defining APIs for passport lifecycle management and searchability, is one of the six CEN-CENELEC JTC 24 standards cited in the Official Journal by Commission Implementing Decision (EU) 2026/1736 in July 2026.
For a battery programme, that means three building blocks must work together on 18 February 2027:
- 01.The unique identifier, compliant with the ISO/IEC 15459 series or equivalent (Article 77(3));
- 02.The passport itself, reachable by QR code with differentiated access rights (Articles 77(2) and 78);
- 03.The registry declaration, through the standardised API (Article 77(10)).
Three distinct timelines converging on one date.
Three common mistakes
"The registry hosts my passport." No: it holds the identifier and a proof of registration. The passport stays with you or your provider, subject to the persistence requirement of Article 78(e) — the passport must remain available even if the responsible operator ceases its activity.
"The registry is an ESPR obligation, not a batteries one." Article 77(10) of the Batteries Regulation imposes it explicitly, by reference to Article 13(1) of the ESPR. It is a batteries obligation, executed in ESPR infrastructure.
"We will deal with the registry after the passport." Both share the same effective deadline. A battery placed on the market on 18 February 2027 needs its passport and its declared identifier.
In short
Article 77(10) of Regulation (EU) 2023/1542 requires the unique identifier of every battery passport to be uploaded to the central European DPP registry created by Article 13 of the ESPR, open since 20 July 2026. The registry holds the identifier, the responsible operator, the category and a proof of registration; passport content stays with the economic operator or its authorised provider. Exchange runs through the standardised EN 18222 API.
Arianee registers every DPP with the central registry automatically through the standardised API, with no re-keying and no custom development on the brand's side. See our dedicated page on the EU DPP registry, our Battery Pass page, or request a demo.
Sources: European Commission announcement — “The Digital Product Passport Registry is now live”, 20 July 2026 · Regulation (EU) 2023/1542, Articles 77 and 78 — consolidated text of 31 July 2025 (EUR-Lex) · Regulation (EU) 2024/1781 (ESPR), Article 13 (EUR-Lex) · Digital Product Passport — Batteries, European Commission · Commission Implementing Decision (EU) 2026/1736 citing the harmonised DPP standards (EUR-Lex).
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