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EU Battery Regulation · Mandatory 18 Feb 2027

Before the deadline, give every exported battery a verifiable EU identity.

Under the EU Battery Regulation, from 18 February 2027 electric-vehicle and industrial batteries placed on the EU market must carry a Digital Product Passport (DPP). Using software and AI, we help battery exporters become verified economic operators and get their compliance data in order — so they can go to market compliantly the moment the registration channel opens.

EU BATTERY PASSPORT DPP · eIDAS CELL UPI BT-CN-9144…2007 CARBON FOOTPRINT 62.4 kgCO₂e ORIGIN CN · Shenzhen STATUS VERIFIED BT · 914403003594072614 · EU-DPP · LTA QSeal ✓
01
Raw materials
collect now
02
Cell making
collect now
03
PACK / use
aggregate
04
In service
aggregate
05
Recycling loop
channel pending
The DPP spans the full life cycle · collection on the left can start today
Standards and frameworks the technology stack follows eIDAS · QSeal JTC 24 / CEN ISO 14067 carbon footprint Catena-X GDPR EU Battery Reg. 2023/1542
DEADLINE & CONSEQUENCE

This is not “should we add a QR code” — it is “will the goods still get in”

From 18 February 2027, traction batteries, batteries for light means of transport and industrial batteries above 2 kWh must carry a digital product passport to enter the EU market — no passport, no entry. The unique registration identifier of imported products is checked at the EU customs border. China Customs’ own newspaper put it bluntly:

If the code does not work, the goods do not clear customs.— China Customs newspaper, Chengdu Customs, 17 September 2026 (translated)

01

Registration is not compliance

The official wording is explicit: registration does not constitute proof of compliance. The registry only validates format and structure; the real scrutiny happens at market surveillance. Clearing registration does not mean the goods are safe.

02

The data is not in the registry — it stays with you

The registry stores only identifiers and an index; the passport data is held and maintained by the company itself. So the barrier is not filling in a form — it is end-to-end data governance: the data sits in PLM, MES, ERP and BMS, and carbon data has to be obtained from your suppliers.

03

Outsourcing does not move the responsibility

Appointing a third party is possible, and the official wording recognises that route — but the same document states that the company’s legal responsibility is not transferred. Who does the work, and where liability sits, must be settled in the contract rather than with a promise that we take care of everything.

Sources: European Commission, Digital Product Passport (mandatory date and timeline) · China Customs newspaper (Chengdu Customs), 17 September 2026 · Regulation (EU) 2023/1542. Regulation and implementation arrangements may change; the official EU publications govern.

WHO IT'S FOR

These roles should start DPP preparation now

Before the mandatory date of 18 February 2027, every participant in the chain that ships batteries into the EU will need to go to market with a passport once the registration channel opens. The types of business we assist:

01

Traction battery and cell makers

In-house design and production: you need VERIFIED status in your own name and must aggregate cell-level carbon footprint and material data.

02

Energy storage integrators

Pack and system-level exports require chaining upstream cell data into a traceable product passport.

03

Export traders

Not the producer, but as an economic operator you carry the same compliance responsibility — and need identity verification and data integration capability.

04

OEM supply chains and Tier 1

Where the OEM requires a DPP, you collect compliance data from upstream and connect to networks such as Catena-X.

§01 — REGULATORY BOUNDARY

The compliance window is open — and the boundary is clearer than most people assume

The organisational verification channel is now open, so an entity can obtain VERIFIED status immediately; product registration must wait for the semantic catalogue and the API. We only offer the actions the regulation already permits — that is written on this timeline, and in the contract.

2026.07
Registry goes live
The EU DPP registry went live on 20 July 2026 and the organisational verification (VERIFIED) channel opened. A Chinese entity can apply for a QSeal remotely through a qualified trust service provider.
Available now
2026 Q4*
Semantic catalogue and API
The battery semantic catalogue and the Registry API are expected in Q4 2026; only then does product registration become technically possible.
Opening soon
2027.02.18
Mandatory
EV, light means of transport and industrial batteries above 2 kWh must carry a DPP to enter the EU market.
Deadline
2027 Q2*
Service-provider regime
The delegated act authorising service providers to register on behalf of an operator is expected in Q2 2027 — only then does that role gain legal recognition.
Awaiting law
What can be done nowWhat begins once the channel opens
ALREADY IN FORCE · YOU MAY HAVE MISSED THESE
2025-08-18Separate collection marking: all batteries must be marked (Art 13(4)) — the date has passed.
2026-08-18Labelling obligations: general information, capacity and non-rechargeable labels apply (Art 13(1)–(3)) — the date has passed.

These two are not part of the 18 February 2027 batch — they are already in force. If you export to the EU, or are about to, we suggest checking them first. It is also the first thing we look at in a free diagnosis.

§02 — WHAT WE DO

What we can do — we only take on actions verified as feasible

Every item is labelled with its status: available now, or after the channel opens. The boundary is transparent, and we make no promise that goes beyond the regulation.

01

Obtain VERIFIED status

We help exporters complete identity verification through an EU qualified trust service provider (eIDAS QSeal) to become a verified economic operator — this can start today, and a Chinese entity can do it remotely.

Available now
02

Compliance data governance

Planning the data flow between PLM, MES, ERP and BMS, and building a GDPR and ISO foundation with ten-year retention and minimised disclosure.

Available now
03

AI compliance engine

Automatic schema validation and gap identification with AI — unlike services that only supply a carrier and fill in forms by hand.

Available now
04

China–EU advisory

Technical liaison with EU regulation and local compliance advice, with European partners covering both ends of the value chain.

Available now
05

Passport technical work

Data entry, generation of the JTC 24 UPI, and preparatory work on the PAdES signature chain, ready for submission.

Pilot work now
06

Product registration submission

Once the semantic catalogue opens, we support the whole chain: data aggregation, passport generation and submission.

After the channel opens
07

Your suppliers will not send the data — we go and get it

Most passport fields are not about your own factory. They are about upstream: material composition, recycled content, carbon footprint, due-diligence records. That data sits with your suppliers, you have no contractual leverage over them, and you cannot spare anyone to chase each one. That part is ours — we write the request list, give your suppliers a template, chase them tier by tier, go back and re-ask when the numbers do not reconcile, and hand you the result in a submittable state. International platforms usually quote this as a separate line item, or hand you a portal and let your suppliers fill it in themselves. For a Chinese factory, with Chinese-speaking staff chasing it down to a submittable state — we have not found a second one doing it.

Available now
§03 — ABOUT PASSSHORE

Products cross the sea. We’re the pilot.

A product leaves a Chinese factory, crosses the ocean and reaches an EU port — it needs more than containers and a bill of lading. It needs a digital passport. We do not sell QR codes: from regulatory diagnosis and data architecture to the UPI, QSeal technical integration, economic-operator registration support and ongoing maintenance, what we deliver is the capability for a product to reach the EU compliantly.

Pass (to pass, a passport, to verify) plus Shore (to land, to arrive). Together they are our role: to carry products through the EU compliance gate with a verifiable digital passport, and land them safely.

The operating entity

PassShore is the EU compliance service brand of Shenzhen Baichuan Software Technology Development Co., Ltd. (unified social credit code 914403003594072614); we use the name PassShore externally.

European collaboration network

We complete QSeal qualified electronic seal identity verification through eIDAS qualified trust service providers (QTSPs) — a mandatory prerequisite of the EU central DPP registry (live on 20 July 2026, governed by Implementing Regulation (EU) 2026/1778). We keep tracking the semantic catalogue, the registration API and the delegated act on registration service providers, so that a client’s verified identity can move straight into product registration once the channel opens, without being locked to a single supplier.

01

Clear compliance boundaries

No exaggeration, no overreach, no misleading. We do not register in the EU on a client’s behalf and we do not pose as a regulator, and we separate testing from production registration as it truly is — what is possible today and what only becomes possible once the channel opens is always stated plainly.

02

Verifiable technology

Data architecture, UPI generation and QSeal integration can all be audited; AI-driven schema validation and gap detection replace manual form filling, and we are not tied to a single data carrier.

03

Pragmatic delivery

Diagnose first, spend later, advance in stages; no heavy platform. VERIFIED status can be obtained now — six months before the mandatory date of 2027-02-18.

04

Continuous tracking

Regulations change, and so does our service. Field definitions are synced once the semantic catalogue and delegated acts land, and data governance is recalibrated as the regulation evolves.

§04 — POSITIONING

Everyone does DPP — the difference is whether it lands, and whether they will tell you the truth

Carrier / label vendors

Selling a QR code and hardware
  • Only solves how to attach and scan a code
  • The client fills in the data; quality is not their concern
  • Does not touch identity verification or regulatory determination
  • Hard to show any link to the EU registry

Form-filling / advisory only

Selling manual data entry and a report
  • Piles up data with labour; high marginal cost
  • Determinations change with the person; hard to reproduce
  • Often presents testing as already registered
  • No technology foundation that can evolve
PassShore
Verified identity, AI determination, technology foundation
  • A workable path to a verified VERIFIED identity
  • Automatic AI schema validation and gap identification
  • An honest line between test and production registration
  • A software foundation that evolves with the regulation, not headcount
§05 — REGULATORY INTEL

Regulatory intel and policy analysis

We keep tracking the legislative and ecosystem milestones of the EU battery DPP and the Digital Product Passport — the central registry, the harmonised standards, the access-rights delegated act, the data field guidance, and the Chinese side of the same rules. Every milestone we publish is tied to its official source, so that clients can check the original rather than take our word for it.

The dated milestone list is maintained on our Chinese pages. Each entry carries a written analysis, and every published line has to pass the same human review gate as the rest of our public material — so the list is not machine-translated into English. Open the milestone list ↗

§06 — HOW WE WORK

How we work

Stage one

Identity verification

Obtain a QSeal and become a VERIFIED economic operator (can start today).

Stage two

Data governance

Connect the systems and aggregate product life-cycle data.

Stage three

Platform and pilot

Data entry, validation, and preparatory work on the UPI and the signature chain.

Stage four

Submission and operation

Submit the registration once the channel opens; QSeal renewal and ongoing compliance.

FAQ — STRAIGHT ANSWERS

The six questions clients ask most about the DPP

Without an EU entity, can a Chinese company register a DPP itself?
This has to be looked at in three separate layers; it cannot be answered in one sentence.

① The registry layer — the registry requires the registering party to be a verified economic operator, and an economic operator is not required to be established in the EU. The manufacturer itself can be the responsible party and complete organisational verification with an eIDAS qualified electronic seal (QSeal). On this layer, a Chinese company can do it alone.

② The measured layer — we have completed organisational registration in the registry acceptance environment using a real Chinese entity: the system accepted Country of Registration = CN together with Local definition and the Unified Social Credit Code, and successfully generated a sealed European Commission declaration, with no unsupported-entity error at any point. The boundary must be stated clearly: this was done in the acceptance environment, which does not mean production has been verified; and an organisation being registered is not the same as full verification passing — full VERIFIED status still requires the seal-and-return step with the QSeal.

③ The Battery Regulation layer (most often overlooked) — a non-EU producer selling batteries directly to end users in the EU by distance contracts must appoint an EPR authorised representative in each Member State of sale (Article 56(3)); responsibility for the battery passport lies with the economic operator placing the battery on the market (Article 77(4)), which allows that operator to authorise another operator in writing to act on its behalf, but does not provide for responsibility to be transferred by contract.

So whether you can register alone, and where responsibility ultimately rests, depends on your sales structure — direct sales to end users, or via an EU importer. We clarify that first, and then propose an approach.
Can this be done now, or should we wait for the registration channel to open?
Identity verification should be done now. The organisational verification channel opened in July 2026, so obtaining VERIFIED status now is half a year ahead of the mandatory date of 18 February 2027. Data governance, schema validation and preparatory work on the UPI and the signature chain can also start now; the product registration submission follows once the semantic catalogue opens (expected Q4 2026).
Will you register the battery passport in the EU on our behalf?
No — and we would not recommend relying on it. EU law does not yet recognise a service-provider role for registration on behalf of another party; the delegated act is expected around Q2 2027. Until then, any promise that we will register on your behalf goes beyond the current regulatory position. PassShore positions itself as a compliance technology partner: we help you build your own verified identity, aggregate your data, and be ready to submit.
If data has to reach the EU, is that GDPR compliant?
It cannot be asserted in general terms — it depends on the data flows and on the roles of the parties. There is currently no GDPR adequacy decision between China and the EU, so processing involving the EU needs a separate legal basis (for example standard contractual clauses), together with data residency, minimised disclosure, ten-year retention and access control. In the proposal we set out controller and processor roles, data flows and legal bases item by item, rather than giving a general assurance.
How are you different from vendors who only sell a QR code or only fill in forms manually?
A carrier vendor only solves how to attach and scan a code and takes no responsibility for data quality; a form-filling vendor piles up data with labour and cannot reproduce its own determinations. PassShore provides a verified identity path + automatic AI schema validation + a technology foundation that can evolve, and keeps the boundary between testing and production registration honestly separate.
From kick-off to compliant market access, how long does it take and what does it cost?
QSeal identity verification usually takes a few working days; data governance and platform preparation generally start at several weeks, depending on the maturity of your systems.

The cost of a QSeal depends on the provider and the scope required, and the spread is enormous: comparing the providers on the official eIDAS trust list that are qualified for a remote qualified electronic seal (TSL service type QRemManage for QSealCD, meaning the provider runs the qualified seal creation device centrally in the cloud and the signatory needs no physical hardware), published prices range from €20 per year up to €5,600 in the first year — roughly a factor of 280. Providers also differ in what the figure includes — tax, a one-year or three-year term, whether the number of seals is unlimited, whether there is a one-off activation fee — so the headline numbers cannot be compared directly. XAdES-LTA signatures on product content files are charged per item.

We quote after a multi-source enquiry against your actual scope, and never use a single vendor figure as the budget basis.
OUR COMPLIANCE STANCE

We only offer services within the actions the regulation already permits, and we tell clients where the boundary is.

§07 — CONTACT
PassShore

Shenzhen Baichuan Software Technology Development Co., Ltd. · Unified Social Credit Code: 914403003594072614

Services: EU Digital Product Passport (DPP) compliance advisory · data governance · technology platform

Email: liu_spring@139.com

Address: Room 2126, South Tower, HBC Huilong Business Center, Longhua District, Shenzhen, China

// VERIFIED identity verification can start now — half a year ahead of the deadline

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