While batteries above 2 kWh will require a digital product passport from 18 February 2027, readiness on the factory floor is nowhere near where it should be, says an auditor who sees it first-hand. Zsolt Takács, owner-CEO of ESGinfo.hu and ReadyPass, has taken part in more than a hundred audits touching product data and product-requirement compliance over the past decade. We asked him: on a scale of one to ten, where do manufacturers stand today?
"Probably around two — but more likely one," he estimates. This article looks at why that number is so low, and what it means for everyone who doesn't make batteries — because they are next in line.
Why so low?
1. The local plant doesn't decide
The battery manufacturers in the first wave of obligations are typically Hungarian production units of Asian — Korean and Chinese — multinationals. Such a plant, however large, does not decide on its own what marking goes on the product: product development, packaging and labelling are settled at headquarters.
Myth: "We're a big factory, surely someone is on top of this." Audit experience shows the opposite: it is precisely the size that lets responsibility slip through the cracks — the plant manufactures, compliance sits elsewhere, and the deadline falls in between.
2. Silos: compliance in one country, the plant in another
"The compliance department sits in Paris, the plant in Debrecen" is how Zsolt Takács describes the typical multinational setup. Regulatory compliance, product conformity and communications are handled by separate organisational units that never quite connect. The result: the wrong marking ends up on the product, and not at the right time.
3. Not one regulation — ten at once
Companies are not unprepared for a regulation; they are unprepared for this many complex requirements at the same time: PPWR, EUDR, DPP, EPR (extended producer responsibility), DRS (deposit return schemes), CBAM. "Companies don't know which way to turn" — even multinationals are in firefighting mode rather than planned preparation. The volatile EU regulatory environment doesn't help: past postponements tempt many to bet that "it will slip anyway".
4. Product data today: error-ridden spreadsheets, no requirement management
A recurring audit finding is that product data is substantially incorrect or incomplete. It often lives in Excel databases "full of errors", with untraceable sources. And manufacturing culture largely lacks something software development adopted long ago: requirement management — recording requirements and tracking them continuously. What does exist — customer sample approvals — covers technical parameters (dimensions, tolerances, colour), while a product's other conformity obligations are checked only periodically, if at all.
Supplier declarations are a story of their own
Asked whether he has ever seen an obviously false, "copy-paste" supplier declaration, the answer is an unambiguous yes. "Very often these product declarations simply don't contain adequate data" — in fact, an engagement is running right now to verify the truthfulness of an Asian supplier's product declaration. The problem is twofold: not only may the data be false, but often it cannot even be determined whether it is true.
What does this mean if you don't make batteries?
Batteries are only the first wave. Under the ESPR (EU) 2024/1781, textiles, construction products and further product groups follow — and the pattern will be the same: long lead times, scattered data, silos. Whoever starts organising now is not working for the authorities but for themselves: on the customer side, DPP-level data requests are already arriving (greenhouse-gas emissions, scope 1–2, material origin) toward suppliers.
How to move up from a one
1. Obligation map: which product, from when, which regulation applies (ESPR, Battery Regulation, PPWR, EUDR, CBAM). 2. Data inventory: where product data lives today (ERP, Excel, paper, "in someone's head") and what is missing. 3. Assign an owner: the DPP is neither an IT project nor a marketing task — connecting the silos is a leadership decision. 4. Gap analysis: start small and structured — for a fast first step, see a digital product passport from Excel in 4 steps.
Frequently asked questions
If headquarters decides on labelling, what can the local plant do?
Flag and prepare: obligation map, data inventory, local specification. Experience shows central compliance moves later than production needs it to — local preparation buys time.
Can we really count on deadlines slipping?
It has happened, but it is a risky business plan: realistic preparation takes about a year, and customer data requests are arriving today regardless of the legal deadline.
Is Excel itself disqualifying?
No — a structured, validated spreadsheet is a good starting point. The problem is the unverified table with an untraceable source.
Find out where you stand on your own scale. ReadyPass helps you get from a one to a seven with gap analysis, validated data templates and a signed, verifiable product passport.
