How to Test Your Battery Passport Before February 2027

There is little time left to discover that a battery passport implementation fails. The 18 February 2027 deadline allows no progressive compliance: on that date a battery either has a valid passport or it does not. The good news: four public reference sets make it possible to test a solution beforehand, and two testing environments exist — the Battery Pass consortium's, and the one the Commission opened on 20 July 2026 alongside the European registry.

The four reference sets to check against

None of these replaces the others. The guidance says what to publish and for whom; DIN DKE SPEC 99100 says how to model it; the EN standards say how to exchange it; the registry says how to declare it.

The Battery Pass consortium resources

The consortium publishes four directly usable deliverables:

• •the Data Attribute Longlist v2.0, building on the fundamentals of DIN DKE SPEC 99100 and on the previous version 1.3;
• •the Data Model v2.0, released alongside it, providing technical specifications for data structures;
• •user stories from a technical perspective, published in June 2026, describing implementation approaches;
• •a test environment, presented as helping organisations validate the data and technical features of their individual battery passport solution.

These documents carry no legal weight. Their value is filling the gap left by the Commission guidance, which lists data points without defining units, formats or types — and which states itself that future updates may add them.

The six-point test plan

1. Coverage of the mandatory core. For each category in your catalogue: 46 mandatory points for an electric vehicle battery, 49 for LMT, 32 for an industrial battery above 2 kWh. The test is to produce a complete passport and check that no point marked "Mandatory" is empty — and that no point marked "not to be filled as of 18 February 2027" is populated. Over-compliance is also non-compliance.

2. Access level separation. Article 77(2) splits information between the general public, authorities and notified bodies, and persons with a legitimate interest. Test with three identities: an anonymous visitor must not see the detailed composition (points 45 to 49) or the test reports (point 50); an authority profile must see everything. See the detail of the access levels.

3. Dynamic data feeding. Points 51 to 71 come under Annex XIII point 4: they are updated in service, from the BMS, not frozen at manufacturing. The test is to change a state-of-health value and verify the passport reflects the new value, with a timestamp.

4. Identifier resolution. The QR code must link to a unique identifier compliant with the ISO/IEC 15459 series or equivalent (Article 77(3)), resolvable to a URL. The test includes physical legibility: Article 13(7) requires visible, legible and indelible marking — so it must survive the battery's real service life.

5. Registry declaration. Article 77(10) requires the unique identifier to be uploaded to the central European DPP registry, through the standardised EN 18222 API. This test need not run in production: the Commission opened the registry on 20 July 2026 together with a testing environment, announced the same day. See our article on the EU registry applied to batteries.

6. Persistence. Article 78(e) requires the passport to remain available after the responsible economic operator ceases to exist or ceases its activity in the Union. This is the least performed and most discriminating test between solutions: ask your vendor what happens to the passports at the end of the contract, and get the answer in writing.

The three most likely failures

The all-public passport. A solution displaying every field to anyone scanning the QR code publishes industrial property with no legal obligation to do so, and fails the access-level test.

The frozen passport. A solution treating the passport as a document generated at manufacturing satisfies neither the currency requirement of Article 77(4) nor dynamic points 51 to 71.

The captive passport. A solution where passports stop being accessible at the end of the contract breaches Article 78(e) and the open standards "without vendor lock-in" requirement of Article 77(5).

In short

Testing a battery passport before February 2027 is possible today, by checking the implementation against four reference sets — the Commission guidance for scope, DIN DKE SPEC 99100 and the Battery Pass consortium Data Model for modelling, EN 18216 to 18223 for exchange, and the European registry for declaration. Six tests are enough to qualify a solution: coverage, access, dynamics, identifier, registry, persistence.

Arianee runs an open DPP infrastructure designed around these six requirements, with passports that persist independently of the contract. See our Battery Pass page, assess your position with the DPP readiness simulator, or request a demo.

Sources: European Commission announcement — “The Digital Product Passport Registry is now live”, 20 July 2026 · Guidance Document: Digital Batteries Passport – data points by category, v2.0, 15 August 2026 (European Commission) · Battery Pass consortium — Data Attribute Longlist v2.0, Data Model v2.0 and test environment · Regulation (EU) 2023/1542, Articles 13, 77 and 78 (EUR-Lex) · Digital Product Passport — Batteries, European Commission.