New EU Battery Passport Rules: What’s Changing for OEMs?

The road to electrification isn’t straightforward, and concerns about battery sustainability, safety, and lifecycle management are growing. For years, battery manufacturers, automotive OEMs, and other industries have faced a key challenge: tracking and verifying a battery’s entire lifecycle, from production to recycling.

Until now, important details about a battery’s origin, carbon footprint, and material makeup have been hard to access. This has led to inconsistent sustainability claims, challenges in second-life applications, and regulatory confusion.

Now, consumers, industries, and regulators are demanding more transparency. To meet this demand, the EU is introducing the Digital Battery Passport as part of the Eco-design for Sustainable Products Regulation (ESPR) and the EU Battery Regulation.

This new approach could bring benefits like increased recycling revenue, reduced carbon emissions, and lower recycling costs. It will also give consumers the information they need to make more sustainable choices.

But what does the Digital Battery Passport actually entail, and how will it impact the entire battery value chain?

Understanding the Digital Battery Passport

The Digital Battery Passport is an electronic record that stores critical information about a battery, providing transparency across its entire lifecycle.

It serves as a structured database that allows different stakeholders (including regulators, manufacturers, recyclers, and consumers) to retrieve relevant battery data.

This passport is part of the EU’s broader effort to support a circular economy and making sure that batteries are sourced sustainably, used responsibly, and recycled properly.

The information stored in the Battery Passport falls into several key areas:

• General battery and manufacturer details such as model identification, production date, and location.

• Carbon footprint data, including emissions generated during production and expected lifetime energy efficiency.

• Supply chain due diligence, ensuring responsible sourcing of raw materials like lithium, cobalt, and nickel.

• Battery performance and durability – State of Health (SoH), charge cycles, and degradation tracking.

• End-of-life management – Guidance for battery recycling, second-life applications, and disposal.

The goal is to bring transparency and accountability to battery production, prevent greenwashing, and confirm that sustainability claims are backed by verifiable data.

How the Battery Passport’s implementation will affect OEMs

While the responsibility varies, OEMs must verify that all batteries in their vehicles meet EU regulations before being sold. This includes confirming supplier compliance, tracking battery data, and preparing for enforcement.

The responsibility for issuing the Battery Passport lies with the economic operator who places the battery on the market or puts it into service in the EU.

Meeting the Battery Passport requirements

OEMs must incorporate Battery Passport requirements into procurement strategies, data infrastructure, and compliance processes to avoid supply chain disruptions and regulatory penalties.

Here’s what OEMs must do to comply:

FAQs about the Digital Battery Passport

Who needs to implement a Battery Passport, and by when?

Starting February 18, 2027, all EV batteries, industrial batteries over 2 kWh, and light means of transport (LMT) batteries (including those used in e-bikes, e-scooters, and other lightweight electric vehicles) sold in the EU must include a Digital Battery Passport.

OEMs, battery manufacturers, importers, and distributors will need to comply by this deadline.

However, some requirements take effect earlier:

• February 18, 2025 – Companies must start reporting the carbon footprint of their batteries.

• August 18, 2026 – The European Commission will finalize the implementation details and provide further technical clarifications.

What information must be included in the Battery Passport?

The Battery Passport stores comprehensive battery lifecycle data, structured into four access levels:

1) Publicly available information (Accessible to everyone, including consumers and regulators)

This section contains general battery identification and sustainability data, which must be available via a QR code on the battery.

• Battery model, manufacturer details, and plant location
• Battery category, chemistry, and weight
• Date of manufacture (month/year)
• Carbon footprint declaration and sustainability data
• Critical raw materials content (e.g., cobalt, lithium, nickel, lead)
• Presence of hazardous substances

2) Information available to authorities and market surveillance bodies

• Safety and compliance test results
• Detailed chemical composition (anode, cathode, electrolyte materials)
• Instructions for battery dismantling, recycling, and repurposing
• Risk and security assessments

3) Private information (Available to battery owners & authorized third parties)

This section contains real-time performance and operational data and is accessible to the battery owner, fleet operators, and authorized maintenance providers.

• State of Health (SoH) & expected lifetime
• Charge/discharge cycles and total energy throughput
• Thermal event history and operational temperature logs
• Warranty details and remaining usable life in cycles
• Original capacity vs. current degradation rate
• Battery classification status: “original,” “repurposed,” “remanufactured,” or “waste”

4) Information available only to the European Commission, National Regulatory Bodies & market surveillance authorities

This is the most restricted category, which contains highly technical and competitive data that is only accessible to designated authorities for compliance verification and regulatory oversight.

• Additional technical compliance reports and proprietary safety testing results
• Performance benchmarking and lifecycle assessment reports
• Detailed breakdown of emissions calculations and regulatory certifications

A note on secure access and retrieval   Each Battery Passport must be linked to a QR code with a unique identifier to allow standardized and secure data retrieval via a cloud-based system.   QR codes “shall be printed or engraved visibly, legibly and indelibly on the battery.” If the battery is too small to have a QR code engraved on it, or it is not possible to engrave it, the code should be included with the battery’s documentation and packaging.

What happens if an OEM fails to comply?

Non-compliance with the Battery Passport requirements carries serious consequences for OEMs and battery manufacturers.

• Batteries without a passport will be banned from sale in the EU starting in 2027.

• Fines and penalties may be imposed for missing transparency and reporting obligations.

• Legal and reputational risks will increase, particularly if battery safety, sustainability, or performance issues arise.

Given these risks, proactive compliance planning is essential. OEMs must act now to integrate Battery Passport requirements into their supply chains and product development strategies.

Will repaired or second-life batteries need a new passport?

Yes. Batteries that are repaired, repurposed, or remanufactured must receive a new Battery Passport linked to the original battery’s history. Recycled batteries entering the market after 2027 must also follow passport regulations, keeping second-life batteries traceable. This allows used batteries to be resold or repurposed in energy storage applications.

Will the Battery Passport apply to older batteries?

No. The regulation only applies to batteries placed on the market after February 18, 2027. However, OEMs that remanufacture or recycle batteries after this date must take care of compliance before reselling or repurposing them.

How to store EU Battery Passport data: Two approaches

Companies need to decide how to store and manage the large volumes of data required for compliance. There are two main options:

1. Blockchain-based systems – A decentralized ledger where data is permanently recorded and protected from tampering. This preserves long-term transparency and integrity.
2. Cloud-based systems – A centralized storage model that allows for real-time updates, scalability, and flexibility. This makes managing compliance data easier.

Each option has its benefits.

Blockchain offers security and traceability, which makes it ideal for regulatory audits and builds consumer trust. Cloud storage provides flexibility, which allows companies to manage and update battery lifecycle data efficiently.

Many companies may choose a hybrid solution, using blockchain for immutable regulatory data and cloud storage for real-time operational tracking.

Regulatory landscape: A complex web of compliance

The Digital Battery Passport is part of a broader effort to improve data transparency, sustainability, and resource management. However, it doesn’t exist in isolation. Companies working in global supply chains must navigate a growing web of regulations across various jurisdictions.

The EU Battery Regulation aligns with major policy initiatives like the EU Data Act, which governs access to and sharing of industrial data, and the Ecodesign for Sustainable Products Regulation (ESPR), which broadens sustainability requirements beyond energy efficiency. These laws reflect the EU’s push for a circular economy, but they also present significant compliance challenges for OEMs, battery manufacturers, and recyclers.

Outside the EU, similar regulatory trends are emerging. Canada’s Consumer Privacy Protection Act (CPPA) expands on the country’s existing privacy framework, while the California Consumer Privacy Act (CCPA) and China’s Personal Information Protection Law (PIPL) set strict rules for how businesses collect, store, and share data.

While these laws focus on privacy, they also signal a global move toward tighter control over digital information, which is closely tied to the requirements for battery passports.

How an IT partner can help OEMs prepare for the EU Battery Passport

Here’s where an IT enables can help.

• Make Battery Passport data easy to access – Set up systems that store and connect passport data with Battery Management Systems (BMS) and internal databases.

• Make sure QR codes work properly – Integrate tracking so every battery’s passport is linked and scannable when needed.

• Simplify compliance reporting – Automate data collection for regulators, recyclers, and customers to reduce manual work.

• Manage second-life batteries – Track when batteries are repurposed or remanufactured and update their passports without losing original data.

• Choose the right storage – Whether it’s cloud, blockchain, or a hybrid approach, IT support ensures that battery data stays secure and available.

With the 2027 deadline approaching, OEMs need systems that make compliance manageable.

Let’s talk about the best way to integrate the Battery Passport requirements.

Get in touch to discuss your needs.