My device has a battery — do I need two passports?
Yes, typically two passports: one for the device, one for the battery
A device with a built-in or replaceable battery is in practice subject to two separate regulations: the digital product passport under the ESPR (Regulation (EU) 2024/1781) for the device itself, and the separate battery legislation for the battery passport. These are two different legal procedures, each with their own timeline, their own dataset and their own responsible party. For the purposes of the passport, the device and battery are not treated as a single unit, even though they are physically integrated. For elektropas.com, this means that the passport we compile covers the device — the battery itself has a separate passport procedure that runs through a different channel.
Applies to: devices with a battery, not to devices without
This separation applies to electronics and ICT equipment in which a battery is incorporated, such as many household appliances, laptops and small devices. This involves two separate obligations that exist side by side: one for the product as a whole (under the ESPR, article 9) and one specifically for the battery as a component (under the battery legislation). For equipment without a battery, this question does not arise; in principle there is only one passport procedure, namely that of the product itself. What exactly falls under the battery legislation — what type of battery, what capacity, what application — is not set out in the sources used here, and that question properly belongs in the official text of that legislation, not on this page about the ESPR.
Date not yet fixed for the device passport, battery rules run separately
The publication date for the digital product passport for electronics and ICT is not yet fixed. The ESPR work plan 2025-2030 works per sub-category, and the delegated acts that set out the specific obligation per product group are expected from 2027 onwards. Once such an act has been published for a sub-category, the date for that category will be stated here. Until then, there is no obligation for the device to have an ESPR passport. The battery legislation is a separate procedure with its own timeline, which does not follow from the sources of this article — for that date, the official source of the battery legislation is the place to consult, not this page.
What this means for the structure of your data
In practice it is advisable to keep the two files separate from the outset, even though it is a single physical product. First: identify whether the device itself will fall under an ESPR delegated act, and if so, which sub-category applies — this determines when the device passport becomes mandatory. Second: check whether the built-in battery has its own passport obligation under the battery legislation, and what data is required for it — this is a separate question with a different answer than the question about the device. Third: ensure that the data that specifically relates to the battery (chemistry, capacity, origin of raw materials, and the like) does not get mixed with the data relating to the device as a whole, because they belong in different passports and may also be supplied by different parties. Finally: bear in mind that the unique identification code of the device (article 12 of the ESPR) is a different link than a possible identification code of the battery under its own legislation — the device and battery are not automatically linked to each other, that requires a deliberate arrangement of the data.
Where this is stated: article 9 and article 12 of the ESPR
Article 9 of the ESPR requires a digital product passport for each product falling under a delegated act, and that passport covers the product as placed on the market — the equipment. Article 12 governs the unique identifier associated with that product passport, and that identifier is linked to the product, not to individual components thereof. From these two articles it follows that the ESPR passport is an instrument for the product as a whole, within the scope of the ESPR. What applies to the battery as a separately regulated component falls outside these two articles and outside the scope of this section — for that, the text of the battery regulation itself is the correct reference point.
Anyone working on this question now would be well advised to set up the two files separately: one folder with data on the equipment for when the ESPR subcategory for that equipment applies, and one with battery-specific data for when that regulation requires a battery passport. Once the delegated act for the relevant electronics or ICT subcategory has been published, the date and content of that obligation will be added here.
What this is based on
- Regulation (EU) 2024/1781 (ESPR), article 9 (digital product passport)
- Regulation (EU) 2024/1781 (ESPR), Article 12 (unique identifier)
The regulation itself is on EUR-Lex. We provide references per statement; you do not have to take our word for it.
What you must concretely do
What is expected of you
One product, one passport — the device is the starting point
Article 9 of the ESPR (Regulation (EU) 2024/1781) links the digital product passport to the product placed on the market. For a device with an integrated battery, the device is the product for which the obligation applies, not the battery as a separate component. In practice, this means for a manufacturer or importer that work is carried out on the basis of one passport per device, in which the properties of the battery as a component are included — not as a second, independent passport alongside that of the device.
The battery may have its own legislation with its own requirements
Apart from the ESPR, there is battery legislation that imposes its own information requirements on batteries, even when that battery is built into a device. This is a different regulation, with a different legal basis than the ESPR. For a company placing electronics with a fixed or replaceable battery on the market, this means that two regulations can be relevant at the same time: the ESPR for the device as a whole, and the battery legislation for the battery itself. This is different from "the same passport twice" — it is rather that two information obligations can exist side by side, which do not automatically come together in the same document.
The unique identification code must match what is actually sold
Article 12 of the ESPR regulates the unique identification code that is linked to the passport. For a company of 10 to 100 employees, this means that per model, and where relevant per variant, its own code and its own dataset are required. A device with a built-in non-replaceable battery is generally a different variant from the same housing with a replaceable battery from a different supplier — even if the rest of the device is identical. This relates to the question which data go into the digital product passport: the battery data belong there as part of it, but the question of what level of detail is exactly requested depends on the delegated act established for that product category.
The delegated act per category determines what is exactly recorded
What exactly about the battery must be stated in the passport of the device is not prescribed in detail in the ESPR itself, but in the delegated act drawn up per product category. For companies that want to prepare now, it is useful to follow what a delegated act is and why it determines what must be done, because that piece of legislation can differ per category — which is also why there is no single fixed checklist that is the same for all electronics with a battery.
Where things go wrong in practice
Two separate files that do not align with each other. A procurement department collects battery data for battery legislation, while a quality department separately prepares the product passport. Both files contain overlapping data about the same battery, but with minor discrepancies — a different chemistry type stated, or a different capacity value — because they were filled in at different times.
A variant with replaceable battery that is treated as the same model. A device is sold in two versions: one with a fixed battery, one with a replaceable battery from a different supplier. One passport and one identification code are used, while the underlying data — battery chemistry, capacity, replaceability — differ between the two variants.
Unclear about who supplies the battery data. When installing a battery from an external supplier, there is no fixed agreement on who supplies and updates which data. If there is a change of battery supplier — something that occurs regularly in electronics — the passport then remains unchanged, while the actual composition of the device has already been adapted.
Assuming that the battery's passport replaces the device's passport. An importer receives documentation from a battery manufacturer that complies with the battery regulation, and assumes that this also satisfies the obligation for the device. These are two different obligations with a different legal basis, even if the underlying battery data partly overlap.
No visibility on which subcategory applies. Because the requirements may differ per product category, work is sometimes carried out based on assumptions about what "comparable" devices must include in the product passport, without having established under which product category the own device falls precisely and which delegated act will apply to it.
What you can document
- An overview per model variant of the device, specifying which battery (fixed or replaceable, which chemistry, which supplier) is in that specific variant — as a basis for correct linking to the unique identifier from Article 12 of the ESPR.
- An internal agreement on who is responsible for keeping the battery data current within the device's product passport, especially when the battery is sourced from an external party.
- A clear distinction in own documentation between data supplied for the battery regulation and data included in the digital product passport of the device, even if both files are partly from the same source.
- A note on which product category the own device is classified, so that when the corresponding delegated act is published, it is quickly clear which requirements become relevant — to be consulted via which products in the electronics sector fall under the ESPR.
- A supplier agreement with the battery supplier on communicating changes to specifications, so that the device's product passport does not fall behind a modified battery installation.
- For companies uncertain whether their own size has consequences for the obligations: a look at whether the digital product passport also applies to small businesses, to determine whether there is an exemption position or not.
This is not legal advice. This page provides general information about the regulations that this platform covers. We are not familiar with your situation. If you are in doubt about your own case, consult a lawyer or the competent supervisory authority.
Written with AI based on the sources above, checked by a human on 2026-08-22. Is something incorrect? Let us know — corrections take priority.