Battery supply chain traceability: The role of battery passports

The environmental impact of battery production is considerable: the production of a single 1,000-pound electric vehicle (EV) battery requires processing about 500,000 pounds of raw materials.¹ By establishing a comprehensive Battery Regulation, the European Union (EU) is paving the way for responsible battery production, reduced carbon emissions, and a circular economy. The EU Battery Regulation Amendment has been a game-changer for the battery industry. This set of rules aims to make batteries more environmentally friendly by tackling two main issues: reducing hazardous materials in batteries and increasing recycling rates. 

Since its implementation, the regulation has significantly impacted how the battery industry operates. Companies have had to adapt their processes and rethink their approaches to battery production and disposal.² One of the most relevant results of this regulation has been the growing importance of battery traceability. 

Battery product passports, in particular, have emerged as a crucial tool. These passports serve as a digital identity for batteries, allowing manufacturers, consumers, and recyclers to track a battery's journey from production to end-of-life. The focus on traceability isn't just about compliance – it's about creating a more transparent and circular supply chain. As you move towards a greener future, these measures ensure that batteries, while powering devices and vehicles, don't come at the cost of the environment. 

For businesses in the battery sector, staying ahead of these regulations and embracing traceability measures like battery passports isn't just good practice – it's essential for long-term success in the European market. This article will help you understand the timeline of the regulation, the context it falls in, the purpose it serves, as well as who the implementation responsibility falls on, which are key elements you need to understand to successfully navigate the Battery Regulation Amendment.

What is the timeline for the EU Battery Regulation?

From 1st February 2027, all EV and industrial batteries on the EU market will require a unique battery passport to be identified with a QR code. However, there are several important dates to keep in mind: 

• 1 February 2025 – Carbon footprint for manufacturing site and battery batch must be third-party verified, and this information must be made publicly accessible online. 
• 1 February 2027 – All light means of transport (LMT) batteries on the EU market require a unique battery passport made retrievable via QR code. 
• 1 February 2028 – Impact assessment of battery lifecycle must be completed (technical documentation must detail percentages of recovered cobalt, lead, lithium, and nickel).³

These targets are part of a bigger picture which aims to reach certain goals by: 

• 2027: 63% collection target for portable batteries; 
• 2028: 51% collection target for light means of transport (LMT) batteries; 
• 2030: 73% collection target for portable batteries; 61% collection target for LMT batteries; EU Commission to assess phasing out non-rechargeable portable batteries.⁴ 

The EU chose a phased roll-out approach, rather than implementing and enforcing it all at once. due to four main reasons: 

1. It gives businesses time to adjust their processes and systems.
2. It allows for the creation and refinement of necessary tools. (e.g., QR code systems)
3. It enables the development of third-party verification infrastructure.
4. It provides time to gather and organise the required information.

What is the EU Battery Regulation?

The Battery Regulation is part of a broader branch of regulations that aims to help the EU's sustainability transition efforts, falling under broader plans such as the EU Green Deal. The Battery Regulation was adopted following the EU Strategic Action Plan for Batteries and is replacing the requirements under the 2006 Batteries Directive. 

Figure 2: The Battery Regulation concerning the EU Green Deal.

However, the revised Battery Regulation takes a different approach than its predecessor. While the 2006 Batteries Directive is focused more on waste management and recycling, the current Battery Regulation is more focused on sustainability-related issues, covering the entire lifecycle of batteries, from raw material extraction to recycling. 

What is a battery passport and what is its purpose?

The Battery Regulation modernises the EU's legislative framework for batteries, aiming to transform the EU into a modern, resource-efficient, and competitive economy. Battery passports are a specific type of digital product passport (DPP) designed for batteries and are a key part of the regulation. They share many characteristics with general DPPs, but are tailored to the unique requirements of the battery industry and related regulations.

A battery passport is a document that stores relevant battery data throughout the entire battery lifecycle, containing detailed information about a battery’s production, testing, and history and helps the battery recycling process. This will ensure that batteries comply with the Battery Regulation Amendment, as well as the Ecodesign for Sustainable Products Regulation (ESPR). 

In other words, a battery passport is a digital record of every battery, documenting its entire lifecycle — from its origins to production, performance testing, and eventual recycling. 

What is the scope of the battery passport?

Regardless of the origin, the batteries with a capacity over 2kWh will require a battery passport to be listed in the European market⁵: 

• Electric vehicles (EVs) over 25 kg
• Light means of transport (LMT) under 25 kg
• Intended for industrial uses (>5 kg)
• Portable batteries (≤5 kg)
• Starting, Lighting, and Ignition (SLI) automotive batteries

The Battery Regulation places a considerable obligation on manufacturers and suppliers across several industries. This means changes to their supply chains, manufacturing processes, and potentially even investments in new technologies to meet these requirements. On the other hand, suppliers will need to provide the necessary data for the battery passport and work closely with manufacturers to ensure compliance. 

Download our guide to view the table of the Battery Regulation obligations for manufacturers, importers, distributors and second-life operators.

What are the data requirements for the battery passport?

While data requirements for digital product passports (DPPs) have been defined by the Ecodesign for Sustainable Products Regulation (ESPR), implementation requires the whole supply chain to cooperate and define the crucial information that could prevent a product from going to waste. Data requirements for the specific products or product groups might differ and more information will be published in the Supplementing Acts to the ESPR. For now, here are the data requirements for DPPs you need to know:⁶ 

• Unique product identifier: Each DPP links to a unique product ID via a data carrier (e.g., barcode, QR code) placed on the product, its packaging, or in accompanying documentation.

• Compliance with global standards: The DPP follows ISO/IEC 15459:2015 standards to ensure consistency, quality, and global interoperability.

• Structured, machine-readable data: All information in the DPP is structured, machine-readable, and based on open standards, making it searchable and compatible with digital systems.

• Comprehensive product information: The DPP contains key details about the product model, batch, or individual item, enhancing transparency across the supply chain.
• Controlled access to information: Access to DPP information is regulated per Article 10, with specific access levels for each product group as set by Article 4.

For a complete list of the requirements for DPPs laid out in the ESPR, follow our step-by-step guide on how to comply with ESPR for manufacturers, importers, distributors and retailers.

A new wave of requirements 

The following legal requirements under the Batteries Regulation came into effect on 18 August 2024.⁷ 

• Economic operators must now adhere to sustainability, safety, labelling, marking, and information requirements of the Batteries Regulation. 
• Portable batteries, including those integrated into devices, are limited to a maximum lead content of 0.01% by weight. An exception is made for portable zinc-air button cells until August 18, 2028.
• For rechargeable industrial batteries exceeding 2 kWh capacity, LMT batteries, and EV batteries, documentation must be provided detailing electrochemical performance and durability parameters, along with technical information on how these values were determined.
• Battery management systems in stationary energy storage systems, LMT batteries, and EV batteries should incorporate information on health state parameters and projected lifespan.
• Stationary battery energy storage systems require technical documentation to verify their operational and usage safety.

Who is responsible for implementing battery passports?

As the regulation provides in-depth requirements regarding the technical specifications of manufacturing a battery, and what is required for a battery passport, it poses somewhat of a challenge for manufacturers. However, it is the party placing the battery on the EU market that holds the responsibility of ensuring that all the required data is entered into the digital record and that the information is correct and up to date. 

The main actor responsible for implementing the battery passports is the economic operator, which is defined as per (Article 2,1(19)) as: 

“Any entity (manufacturer, authorised representative, importer, distributor or fulfilment service provider or any other natural or legal person)⁸” 

This means that whoever puts the product on the EU market is responsible. Therefore, the economic operator is subject to obligations concerning:

• manufacturing batteries; 

• preparing batteries for re-use and repurposing;
• repurposing or remanufacturing of batteries;
• making them available or placing them on the market, including online placing or putting them into service.

Therefore, the economic operator is responsible for creating, updating, and storing the battery passport information throughout the battery's lifecycle. They have to ensure the batteries meet all the rules, like having the right safety labels (CE marking), before selling them in stores or online, or before they're used for the first time in Europe. 

It doesn't matter where the battery was made; everyone involved needs to follow these rules for making batteries, getting them ready to be reused, fixing them up for a new life, and selling them. 

Battery passports will require input from cell producers, module producers, battery producers, automotive OEMs, battery service, refurbishing, and repurposing companies. For manufacturers, this means that they have to adapt to changes in supply chain management and traceability to make sure they have access to the EU market and avoid fines.⁹ 

Who needs access to the battery passport?

The Battery Regulation explains three main access groups for the battery passport, each with different levels of access.  

The general public 

The public can easily access general, non-confidential information about a battery, including its type, model, basic performance, and sustainability metrics (e.g., carbon footprint and recycled content). This transparency allows consumers to compare battery options and make informed decisions about batteries or products containing them.¹⁰

Notified Bodies, Market Surveillance Authorities, and the European Commission

The main difference between this group and the general public is that it has more complete access to data within the battery passports. This can include detailed technical specifications, compliance documentation, and supply chain information. These bodies need access to this data to verify compliance with EU regulations, conduct market surveillance activities, and enforce safety and environmental standards. Having a higher level of access allows these bodies to effectively oversee the battery market and ensure adherence to the Battery Regulation. 

Persons with legitimate interest

Persons with legitimate interest are individuals or entities who have a valid reason to access and use sensitive battery information that is not publicly available, such as battery composition details, disassembly instructions, and the state of health data. Some examples are battery manufacturers, recycling companies, or repair and refurbishment services. They act as a middleman because they can access more detailed information than the general public, but less than the regulatory bodies. To get access to this information, actors have to demonstrate their legitimate interest to the relevant authorities, such as battery repair, reuse, and recycling, supporting the circular economy goals of the regulation¹¹. 

What are the challenges for the implementation of battery passports?

Battery passports can be complex because of the large amount of information they need. As a result, several challenges arise when you begin to implement them.

Data management complexities

Managing the data efficiently is a challenge in itself. The regulation requires actors to collect, integrate, and certify extensive data throughout the battery lifecycle. This requires transparent and efficient communication between actors to ensure everybody along the supply chain can provide the information needed.¹² Managing the data silos between battery supply chain actors is key –- without everybody's input the battery passport will not be complete, and hence not comply with the regulation; which can either facilitate or stagnate data completeness, accuracy, and up-to-date status.¹³  

Supply chain transparency 

Other than coordination challenges between supply chain actors, confidentiality concerns are an important challenge.¹⁴ Establishing trust between access groups can be difficult, due to data security concerns.¹⁵ An important point to consider is the lack of standards for data interoperability, which can make data sharing a challenge. Hence, there are still gaps to be filled within the regulation.  

Technological hurdles 

In addition to coordination challenges, the infrastructure needed to keep these systems running and the data safe is an important consideration. The blockchain technology needed to facilitate the confidential sharing and verification of data can be costly and complex.¹⁶ Ensuring interoperability between different systems and platforms that access groups and actors along the supply chain use can be overwhelming.¹⁷

How to comply with the Battery Regulation?

While it is important to acknowledge the challenges surrounding the implementation of the battery passport, there are ways for the economic operator to ensure compliance. So how do you achieve compliance with the Battery Regulation?

Step 1: Start by assessing how prepared you are to meet the compliance requirements and pinpoint strategic business opportunities within the battery passport framework. 

Step 2: Establish processes for continuous data collection and updating, especially for dynamic data like battery state of health. 

Step 3: To address data gaps, complete a thorough audit of existing data across the battery lifecycle. Identify critical information gaps based on regulatory requirements. Then, develop strategies to collect missing data, potentially through collaboration with suppliers and partners.¹⁸ 

Step 4: Implement systems for ongoing data collection and verification. Consider investing in emerging technologies and platforms that facilitate secure data sharing and verification. 

Conclusion 

The Battery Regulation and the introduction of mandatory battery passports mark an important step toward a sustainable and transparent battery ecosystem. By requiring detailed lifecycle data, promoting circular economy principles, and ensuring compliance with strict sustainability standards, it sets a precedent for increased transparency and lifecycle focus across industries, potentially influencing global standards. 

For businesses, this represents not just a challenge but also an opportunity. Adapting to these requirements can drive technological advancements, improve consumer trust, and open doors to new markets. Battery passports are more than just a compliance tool; they are a gateway to reshaping how batteries are designed, used, and recycled. 

As industries prepare for full implementation, collaboration, technological readiness, and robust data management will be key to success. The future of batteries lies in transparency, traceability, and sustainability — a future that benefits businesses, consumers, and the planet alike.