From 18 February 2027, any electric vehicle, light means of transport, or above-2 kWh industrial battery placed on the EU market without a battery passport cannot be sold. That makes EU battery passport data a market-access issue, not a formatting task handled on deadline day. The real exposure sits upstream: carbon footprint, recycled content, and due diligence information live across several supplier tiers, and assembling, verifying, and structuring it into a per-unit Annex XIII record realistically takes 12 to 18 months. Teams that wait will spend early 2027 discovering what they cannot yet prove. This analysis of the February 2027 deadline breaks down what Article 77 of Regulation (EU) 2023/1542 actually requires, why the 2025 due diligence postponement did not move the passport deadline, and how the three access tiers shape the build. It also sets out a practical readiness sequence for Q4 2026 onward, from locking scope and identifiers to automating multi-tier supplier data
