Originally published on Medium.
The EU has published a calendar for the Digital Product Passport. Every date on it checks that the data is genuine. None of them checks the product.
The European Commission switched on the Digital Product Passport Registry on July 20 this year, the central list every future passport will point back to. Three days earlier, the registry’s own user guide had said something that got very little attention: a passport for a battery could not yet be registered, because the data catalogue for batteries had not been defined. The first product group with a legal deadline is batteries, and the deadline is February 18, 2027.
The system is being built on schedule, in public, one date at a time. That is the good news, and it is real. The part worth reading slowly is what the dates cover. Every standard and every deadline on the Commission’s calendar is about making the passport trustworthy: the data carrier, the identifier, the registry, the signature on the record. Not one of them asks whether the object in your hand is the object the passport was issued for.
The dates
The Commission publishes its passport plan as a timeline, and it is worth reading as two different kinds of date. Some are fixed in law. Most are the Commission’s own planning, and plans in Brussels move.
The fixed ones are few. The registry went live on July 20, 2026. Batteries follow on February 18, 2027. After that, the next dates written into law belong to separate sector rules: detergents on September 23, 2029, and toys in August 2030.
Everything else is planned. Iron and steel rules and a battery access-rights act are scheduled for the fourth quarter of 2026. Construction products and service providers are pencilled in for the second quarter of 2027. A delegated act for passport service providers follows in the third quarter. Textiles, aluminium and tyres come across the third and fourth quarters of 2027, furniture in 2028, and mattresses and recycled content in 2029.
Put plainly, February 18, 2027 is the only passport deadline fixed in law between now and 2029. Almost every conversation about the Digital Product Passport today is really a conversation about batteries.
What each date actually asks for
The plumbing is already in place. On July 15, 2026, six horizontal standards were cited in the Official Journal under Commission Implementing Decision (EU) 2026/1736 (CEN-CENELEC). They cover data exchange (EN 18216), unique identifiers (EN 18219), data carriers (EN 18220), storage and persistence (EN 18221), APIs (EN 18222) and interoperability (EN 18223). Two security standards, EN 18239 on access rights and EN 18246 on data integrity, closed their formal vote on July 16 (Regen Studio). The Commission’s timeline lists a September 2026 decision on those remaining two.
The registry is live, with a gap. The registry went into production on July 20, 2026, under Implementing Regulation (EU) 2026/1778 (Regen Studio). Its user guide, version 1.0 of July 17, says registering a battery passport “is not currently available, as the semantic catalogue for this product group has not yet been defined.”
February 18, 2027: batteries. The passport becomes mandatory for EV batteries, industrial batteries and the batteries in e-bikes, e-mopeds and e-scooters (European Commission). Each battery gets a unique identifier, linked to it by a QR code. The obligation sits with whoever places the battery on the EU market, and importers carry it the same as manufacturers.
Q4 2026 into 2027: the next rules, still being written. The Commission plans iron and steel requirements and a battery access-rights act for Q4 2026. Construction products and service providers come in Q2 2027, a delegated act for passport service providers in Q3 2027, then textiles, aluminium and tyres in Q3 to Q4 2027. Furniture follows in 2028, and mattresses and recycled content in 2029. These are dates for when rules are adopted, not when they apply. The ecodesign regulation puts at least 18 months between the two (ESPR, Article 4(4)), so a textile passport adopted in late 2027 bites in 2029 at the earliest.
2029 and 2030: sector laws with their own dates. Separate from the ecodesign track, detergent passports start on September 23, 2029, and toy passports in August 2030 (Regen Studio).
The calendar has already moved once
It is fair to ask how firm February 18, 2027 really is, because the battery rules have a record here.
In July 2025 the Council adopted a “stop-the-clock” law postponing the battery due diligence obligations, the rules on sourcing cobalt, lithium, nickel and natural graphite, by two years to August 18, 2027 (Council of the EU). The stated reason was to give producers more time to prepare. The passport date was not part of that change.
A second, quieter delay matters more to anyone who handles a battery after it is sold. The act that decides who may read the restricted parts of a battery passport, such as its detailed composition, is now on the Commission’s timeline for the fourth quarter of 2026 (European Commission). That is roughly three months before the passports it governs become mandatory. The people it covers are the ones who open packs: repairers, second-life operators and recyclers.
None of this means the February date will slip. It means the parts of the system that decide who can see what, and how much a record can be trusted, are arriving last. The pieces that identify, store and exchange data have already shipped.
What none of the dates ask for
Read the security standard closely and the design becomes clear. EN 18246 authenticates the passport through electronic means: W3C Verifiable Credentials, an eIDAS electronic attestation, an ISO 22376 visible digital seal, or an ISO/IEC 20248 digital signature (Regen Studio). Each of these proves that a record is genuine and hasn’t been tampered with. None of them looks at the physical object.
That is a sensible choice for a data system, and it’s worth being clear about what follows from it. A passport can be complete, signed, registered and correct, and still sit on the wrong battery. The carrier that links object to record is usually a QR code. It is fully compliant, and anyone with a photograph and a printer can copy it. Put a copied code on a counterfeit pack and it will open a genuine passport, for a genuine battery, somewhere else.
To be precise about what we are not saying: no DPP rule requires a chip. Every deadline on the Commission’s calendar can be met with a printed code. The passport is doing what it was built to do, which is make product data trustworthy. Proving that this unit is the unit the data describes is a different problem, and the regulation leaves it to the market.
Why batteries are where the gap matters first
It would be a small point if the first category were furniture. It is batteries, and batteries are where counterfeits are already dangerous.
In 2023, researchers at UL Research Institutes led by Judy Jeevarajan opened up counterfeit lithium-ion cells and compared them with genuine ones (ACS Energy Letters). The genuine cells had a current interrupt device, the part that stops an overcharge. The counterfeits didn’t. They had thinner insulators or none at all, and little or no safety tape. Michael Pecht of the University of Maryland told IEEE Spectrum the risk is “probably an order of magnitude worse with these counterfeits” (IEEE Spectrum).
The finding that matters most here is how you tell them apart. As IEEE Spectrum’s reporting put it, you can’t by looking: “One cannot tell from visually inspecting it.” The methods that work are a known genuine cell to compare against, tests of the internal safety devices, or a CT scan. The fakes turn up in cameras, phones, power banks, power tools, e-bikes and e-scooters, which overlaps heavily with the light-means-of-transport batteries that get a passport in February.
So the first mandatory passports go onto a category where the dangerous fake is invisible to the eye, and the link from passport to product is a printed square.
Who meets the gap
Most buyers will never scan a battery passport. The people who will are the ones who handle a pack after its first sale: the bike shop taking a trade-in, the fleet manager replacing a module, the second-life operator grading packs for home storage, the recycler deciding how to take one apart safely.
Those are exactly the people the passport was built to inform. They scan the code, a genuine passport loads, and it tells them the chemistry, the history and the maker. If the pack in front of them is a copy wearing a real code, the passport is accurate about a different battery. Nothing in the rules asks it to know the difference.
This is not an argument against the passport. It is an argument for reading it correctly. It is a trustworthy record. Whether it is a record of this object is a question the object has to answer.
What to do before each date
If you place batteries on the EU market, February 18, 2027 is a legal date, and the registry can’t yet accept your passport. Build the identifier and the data now. Watch for the battery data catalogue, and plan to register the day it opens. Then decide, separately, whether a recycler, insurer or second-life buyer will need to confirm that the pack in front of them is the pack on record. Registering the passport won’t answer that for them.
If you make steel, textiles, tyres or aluminium, your dates are planning dates, not legal ones. The delegated act comes first, then at least 18 months. Use that time to decide where each unit’s identifier will live and who will read it.
If you plan to sell passport services, the service provider act is planned for Q3 2027, and no certification scheme has been published. Being early in that queue will matter once it exists.
Everyone else should treat the calendar as a compliance plan and ask one more question alongside it: once the passport exists, how does anyone know the product carrying it is real?
The passport will be real. Whether the product is real is still up to us.
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