As transport and industrial sectors accelerate to achieve electrification and eliminate dependence on fossil fuels, the demand for sustainable battery production is mounting. The European Parliament is pushing to ban the sale of new internal combustion engine cars by 2035, meaning the demand for battery materials will continue to dramatically increase.¹ By 2030 the EU will need 5 times more cobalt and 18 times more lithium compared to the demand in 2018, numbers which exponentially increase when estimating demand in 2050.² If electrification is to be a truly sustainable transition, a system-level approach must be taken to ensure sustainable material sourcing, efficient battery production, and effective end-of-life processing.

An update to the 2006 Battery Directive³ aims to ensure that the growth of the battery industry is done sustainably. In July 2023, the EU Battery Regulation Amendment was adopted by the EU Council, laying out the structure to achieve sustainable battery lifecycles. This includes a digital record system to enable the transfer of key information between parties - the battery passport, which is detailed in Chapter IX of the regulation.⁴

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Who does the battery passport regulation affect?

According to the Battery Regulation update, every industrial or electric vehicle (EV) battery on the EU market with a capacity of over 2 kWh will require a battery passport. This means regardless of the origin of the battery, it will require a battery passport in order to be listed in the European market. It will be the responsibility of the party placing the battery on the market, to ensure that all data required is entered in the digital record and that the information is correct and up to date.

Battery passports will therefore require input from:

• Mining and refining companies
• Cell and battery producers
• Vehicle brands
• Battery servicing, refurbishing, and recycling companies

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What information will need to be included in the battery passport?

The battery passport must contain information on:

• Identification of the battery in the form of a unique identifier.
• Basic characteristics of the battery including type and model.
• Statistics on performance and durability must also be updated over the battery lifecycle by parties conducting repair or repurposing of the battery.

The specific performance characteristics required in battery digital product passports are detailed in Chapter IX of the Battery Regulation Amendment. Technical documentation on the electrochemical performance and durability of the battery must be provided, including details on how this data was obtained. This is to ensure the batteries meet the minimum requirements for battery performance and capacity in order to guarantee batteries on the market are operational and efficient over a sufficient lifetime.

To gain access to the battery passport, the physical battery must have a QR code printed or engraved on it to act as a unique product identifier.⁵‍

Information stored in the battery passport will need to be selectively shared with three distinct groups: the general public, regulatory bodies, and battery service and end-of-life processors. Each group of users will need to have different read and write permissions for the data in each battery passport, so that everyone has the information they need while data privacy is maintained. The precise data points each group of users requires access to are detailed in Annex XIII.

The Battery Regulation Amendment also outlines many other requirements for making key data available to the battery value chain. While the battery passport is not specifically prescribed as the way of making this data available, it is likely that in future amendments to the regulation, more of this information will need to be included in the battery passport. However, it’s important to mention that ensuring the protection of confidential data is also a key consideration in the Battery Regulation Amendment, as aspects of this data are linked to companies' intellectual property and competitive advantages.

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‍When will battery passports be required?

From 1st February 2027, all EV and industrial batteries over 2 kWh sold into the EU market will require a unique battery passport retrievable using the unique product identifier in the form of a QR code.

Key dates for other Battery Regulation requirements

The Battery Regulation update also requires sustainability assessments accessible via the QR code on the battery for other battery parameters:

• February 2025 - carbon footprint specific to the manufacturing site and batch of batteries which is third-party verified and publicly accessible on the internet
• December 2025 - minimum recycling efficiency is 65% lithium-based batteries
• December 2027 - critical mineral recovery rates from waste batteries set (lithium 50%, nickel 90%, cobalt 90%, copper 90%)
• ‍February 2028 - impact assessment of battery life cycle to ensure it meets the maximum carbon footprint threshold
• August 2028 - technical documentation detailing the percentages of cobalt, lead, lithium, and nickel which came from recovered sources
• December 2030 - minimum recycling efficiency of 70% lithium-based batteries

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Interoperable, transferable, and trustworthy battery passports

There are stringent requirements for the systems used to create battery passports, therefore you must ensure that the system you choose meets the EU requirements for a scalable and reliable battery passport network. 

All information included in the battery passport needs to be based on open standards and be in an interoperable format that is transferable through an open interoperable data exchange network such as Catena-X. There are clear requirements for selective data access, editing, and sharing, while also maintaining a high level of data security and privacy. Therefore you must choose a system with strong selective data sharing capabilities that ensure data privacy. 

Data authentication, reliability, and integrity must also be ensured. Therefore using a private cloud or blockchain-based system could risk non-conformity due to their weaknesses in this area. It is worth considering more decentralised systems which excel in data immutability. 

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‍What is decentralised data storage?

Decentralised data storage involves keeping data in multiple interconnected locations rather than in a single centralised point. This approach ensures the integrity of a single source of truth, such as a manufacturer's bill of materials, while allowing for the necessary information to be continually distributed as required to selected parties in a peer-to-peer fashion. A strategy that is also supported by the EU Data Economy Strategy.⁶

Mr Thomas Götz from the Wuppertal Institute explained the current landscape of digital product passports and how it brings together data in one place, while also emphasising the need to do this in a decentralised way:

“A decentralised approach using data from different sources is - especially from the beginning phase onwards - very important because the spread data has to be brought together. It’s reasonable to use existing data and link to it from the DPP so that (...) all needed information is collected and can be found in one place.”‍

‍Learn more about the importance of decentralisation and data security for digital product passports

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2025 product carbon footprint for electric vehicle batteries

Per Article 7 and Annex II of the EU Battery Regulation, the carbon footprint must be calculated for each battery in each EV sold in the EU from February 2025. The carbon footprint must cover the four key lifecycle stages of the battery; mineral extraction and pre-processing, cell manufacture, distribution, and end-of-life processing (recycling). While this data isn’t legally required to be stored in a battery passport until 2027, the carbon footprint declaration must also contain a weblink to public data on the emission values. So this first major requirement of the EU Battery Regulation can be thought of as a warm up for the full battery passport required in 2027.

The JRC battery carbon footprint requirements also mandate that information is collected throughout the value chain, specific to each battery model and manufacturing plant.¹² Any changes to the bill of materials or the energy mix at the facilities in the value chain must be reflected in the battery carbon footprint, and carbon offsets cannot be included in the calculation. These figures will then be used to categorise EV batteries into carbon footprint performance classes in the future for easy differentiation.

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Other Battery Regulation Amendment information requirements

The Battery Regulation requires many other criteria to be met to sell batteries in the EU, including the reporting of a carbon footprint declaration, recycled content percentages, as well as human rights and battery supply chain due diligence obligations throughout the battery value chain. Here are some of the main requirements that must be met:

Facilitate repair and end-of-life processing

Battery model information must be made electronically available to parties conducting any repair or end-of-life processing. Information should also be made available to end users to facilitate collection schemes for end-of-life batteries. This means producers and distributors must ensure consumers are aware of collection schemes through the use of posters and social media campaigns, or QR codes on the battery which link to a website providing the relevant information. This leads to businesses having greater responsibility for what happens to the products they produce after they leave the factory.

Extended producer responsibility 

Extended battery producer responsibility will mean that new and refurbished battery producers are required to finance or organise the collection of waste batteries. It is possible for organisations to appoint a different producer responsibility organisation, but a take-back network within each of the EU member states must be established somehow, not merely in target areas where the collection is most profitable.

Recycled content

By the beginning of 2031, batteries must contain a minimum of 16% cobalt, 85% lead, 6% lithium, and 6% nickel which are from non-virgin sources. To meet these targets, all waste batteries collected must enter a recycling process with a minimum efficiency of 70% for lithium-based batteries in order to recover at least 80% of lithium, 95% of nickel, 95% of cobalt, and 95% of copper.

Battery health data

Battery health information must be made available to the battery owner in order to determine the further use, repurpose, or remanufacture potential of the battery. 

Conformity declarations

Before a battery can be placed on the EU market, it must have a conformity assessment conducted by a notified body to produce a declaration of conformity.

Safety and hazardous materials requirements 

Stationary batteries must include evidence that they are safe during their normal operation as part of their technical documentation. All batteries cannot contain materials which present a hazard to humans or the environment during all stages of the battery life cycle. A range of delegate acts will follow the Battery Regulation Amendment to outline the details of the hazardous substances requirements.

Battery supply chain due diligence requirements

Companies selling EV and industrial batteries on the EU market must conduct supply chain due diligence to mitigate social and environmental risks.

• A ten-year record of supply chain transparency must be kept detailing the chain of custody of each material from the source to the company selling the battery in the EU. This due diligence process must also be third-party verified. 
• The overall quantity of raw materials used in each battery must also be communicated as a percentage or mass per material.
• The due diligence policy must also be verified by a notified body to ensure the scope, competence, and reliability of the due diligence process.
• All information must be made available to the public, to authorities upon request, and to downstream customers.

Use our custom-trained AI assistant for further guidance on the EU battery regulation and battery carbon footprint requirements

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Risks of non-compliance with the Battery Regulation:

The amendment states that businesses should actively remedy harm caused by themselves or in cooperation with other actors, even when due diligence has been carried out. Such operators should be liable for any adverse impact within their control that they caused or contributed to. Anyone adversely impacted is entitled to remedies and should be provided with access to justice. This adds to the ever-increasing need for greater supply chain visibility and overall product impact tracking in order to mitigate the risk of significant compensation claims when something goes wrong.

When market surveillance discovers that batteries which do not comply with this regulation are sold, and notices to correct non-compliance are ignored, the batteries will be prohibited from sale and recalled if already in the market. A situation that would come at great expense and reputation damage to the parties involved. 

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What value will battery passports bring?

Battery passports may at first seem like an administrative burden, but they also present the opportunity to work towards the common good and create competitive advantages for businesses. Here are a few ways you can benefit from the battery passports:

Enable sustainable production

The battery passport system is designed to ensure the sustainable production of batteries as demand continues to grow rapidly. Durability and performance data reporting requirements will lead to batteries being of higher quality and in use for longer. As more data requirements are added to battery passports, it will also lead to greater traceability in battery supply chains.

Create a competitive edge

The performance requirements and conformity declaration will ensure that EV and industrial batteries meet a certain standard. From a commercial perspective, the requirement for durability information will also increase competition in areas of longevity and quality, providing companies with additional ways to differentiate themselves from their competition.

Leverage your data

Making information openly available via battery passports empowers OEMs and consumers to make more informed buying decisions. For the upstream parties in battery production, attaching data to each unique product allows companies to monetise their sustainable business practices by creating a data stream to their downstream customers.

Incentivise sustainable product use

The need to continue updating the battery passport over the product's life cycle will also start to facilitate more sustainable use of the product.

Learn more about the benefits and ROI that digital product passports bring

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What value will the other Battery Regulation Amendment requirements bring?

The additional requirements outlined in the Battery Regulation Amendment are even more extensive than for the battery passport, but these too create an opportunity for businesses to capitalise on:

Improve end-of-life battery recovery

Requirements to report on recycled battery component content links to the EU targets for battery material recovery and moves the industry to meet targets and improve material recovery systems.

Ensure fair working conditions

Supply chain due diligence requirements will help to ensure ethical work practices across the battery supply chain, regardless of location.

Maintain safe working conditions

Similarly, reporting on safety requirements and conformity will ensure fair and safe working environments in the battery industry.

Circular battery economy and value chain cooperation

Extended producer responsibility and the associated take back and waste processing requirements will drive more circular business practices and value chain cooperation.

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How to implement a battery passport system

1. The first step is to identify what information you need to gather and from whom, so that you can meet the battery passport data requirements.
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2. Next, you need to ascertain if your suppliers are prepared to give you the information you need and if the data will be reliable. It's possible some suppliers will have no interest in sharing this data, and therefore will no longer be active in the European market. Changing suppliers for critical materials is not only time-consuming, but could also require a product redesign to support the new material supply, so it is best to start this process as soon as possible.
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3. Ensure you have a QR code on the battery casing to act as a unique identifier and link to the battery passport. This will require slight changes to product design and production processes if a QR code is not already present, so again, it is best to start planning for these operational changes early in order to avoid mistakes and disruption.
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4. Choose a reliable and scalable system to act as the data storage and distribution medium. More information will need to be included in the battery passport over time which will need to be selectively shared with members of the value chain. Therefore choosing a system which can adapt to the evolving requirements is key. Decentralisation is one of the most promising ways in which this can be achieved.

Learn more about the considerations to be made when implementing a digital product passport system

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The future of battery passports

The Battery Regulation Amendment will still have many other associated acts to outline the specific requirements mentioned in this regulation. This means that while we have a good idea about the future of battery passports, the requirements will increase in the coming years. Areas of development for battery passports will likely include:

Vehicle passport adoption

Batteries are a key component of the future of the mobility industry, but there is a great deal still to improve with the sourcing, production, and end-of-life processing of many other materials in vehicles. In the coming years, we expect to see material passports for steel, aluminium, glass, tyres, plastics, paints, textiles, and rare earth elements¹¹. All of these will contribute to a more holistic vehicle passport, which also includes the battery passport. This aggregated information will then be used for more efficient processing of end-of-life vehicles; a concept that Audi has been trialling in their MaterialLoop project. 

International cooperation for battery passport creation

This regulation is the most advanced of its kind, with many other countries looking to the EU to set an example for sustainable production regulations. However with a globalised economy and supply chains crossing multiple continents, a system-wide approach must be adopted if a truly sustainable battery production system is to be created.

• China plays a key role in the battery market. From the 1st of January 2020, battery material recycling requirements were introduced, ensuring rare earth elements have a recovery rate of no less than 97%.⁷ But despite China’s influence on the global battery market, collaborative international agreements remain to be seen.
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• As highlighted by the European Raw Material Alliance (ERMA) Action Plan and the Critical Raw Materials Act, boosting supply security through better cooperation among stakeholders is a top priority.⁸ For rare earth metals suppliers, this means not only becoming more sustainable but also proving their compliance and quality criteria to customers and regulators.
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• The US Inflation Reduction Act introduced in 2023 incentivises the production of EV batteries within the United States. Battery passports are one of the ways to prove the sourcing of the battery components to qualify for the tax credits. Such a system creates a clear return on investment for achieving traceability of the battery value chain, aligning with the US approach to creating incentives for more sustainable business practices. 

Play an active role in battery passport standards

Battery passports and best practices are still being defined. Establishing practical and reliable standards for sustainable battery production will require cross-sector and cross-continental cooperation. Various organisations are working to shape the future of sustainable battery production and the regulations which govern this, so if you want to play an active role in how battery passports develop, consider joining the Global Battery Alliance, Catena-X, MOBI, or work with Circularise on battery passport implementation (who is also part of all of these key working groups).

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Summary of the EU Battery Regulation

The Battery Regulation Amendment lays out a range of plans to create a sustainable battery industry, including structures for more effective battery recycling, supply chain due diligence, and GHG emissions reduction. The battery passport system will initially only require a small proportion of this information, relating to basic battery information and statistics. But with many subsequent acts to follow the Battery Regulation Amendment, and the clear direction from the Ecodesign Regulation¹⁰ that digital product passports will be a key tool in creating a more circular economy in the EU, we will see battery passport information requirements increase substantially over time.

Members of EU battery value chains need to gain visibility into their supply chains in order to collect the technical and environmental impact data that will soon become a legal requirement. Companies also need to get ready to implement a battery carbon footprint and digital passport system in order to share information with members of the supply chain who require it.

Contact us to discuss battery passport implementation and how to securely share data with members of your value chain.