

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?
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:
The goal is to bring transparency and accountability to battery production, prevent greenwashing, and confirm that sustainability claims are backed by verifiable data.
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.
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:
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:
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.
2) Information available to authorities and market surveillance bodies
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.
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.
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.
Non-compliance with the Battery Passport requirements carries serious consequences for OEMs and battery manufacturers.
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.
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.
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.
Companies need to decide how to store and manage the large volumes of data required for compliance. There are two main options:
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.
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.
Here’s where an IT enables can help.
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.

Databoostr - your customized solution for handling data sharing challenges
Read our blog and stay informed about the industry's latest trends and solutions.
The European Commission issued definitive guidance in September 2025 clarifying which vehicle data automotive manufacturers must share under the EU Data Act.
With enforcement beginning September 2026, OEMs must provide access to raw and pre-processed vehicle data while protecting proprietary algorithms. Direct user access is free, but B2B data sharing can be monetized under reasonable compensation rules.
As the September 2026 deadline nears, the European Commission has issued comprehensive guidance that clarifies exactly which vehicle data must be shared and how. For automotive manufacturers still planning their compliance strategy, it’s now essential to understand these details.
EU Data Act becomes enforceable in September 2026, requiring all connected vehicle manufacturers to provide direct data access to end users and their chosen third parties. While the regulation itself established the legal framework, the Commission's guidance document - published September 12, 2025 - provides automotive specific interpretation that removes much of the ambiguity manufacturers have faced.
This is no longer just a paper exercise. If you fall short, expect:
For OEMs without appropriate technological infrastructure or clear understanding of these requirements, the deadline is rapidly approaching.
At Grape Up, our expert team and Databoostr platform have already helped multiple OEMs achieve compliance before the September deadline. Learn more about our solution .
The September 2025 guidance establishes clear boundaries between data that falls within and outside the Data Act's scope, resolving one of the most contested issues in implementation planning.
Manufacturers must provide access to data that characterizes vehicle operation or status. The guidance defines two categories that must be shared:
Raw Data Examples:
Pre-Processed Data Examples:
Bottom line is this: If the data describes real-world events or conditions captured by vehicle sensors or systems, it's in scope - even when normalized, reformatted, filtered, calibrated, or otherwise refined for use.
The guidance clarifies that basic mathematical operations don't exempt data from sharing requirements. Calculating current fuel consumption from fuel flow rate and vehicle speed still produces in-scope data that must be accessible.
Data excluded from mandatory sharing requirements represents entirely new insights created through complex, proprietary algorithms:
The main difference is this: The guidance emphasizes that exclusion isn't about technical complexity alone - it's about whether the data represents new information beyond describing vehicle status. Predictions of future events typically fall out of scope due to their inherent uncertainty and the proprietary algorithms required to generate them.
However, if predicted data relates to information that would otherwise be in-scope, and less sophisticated alternatives are readily available, those alternatives must be shared. For example, if a complex machine learning model predicts fuel levels, but a simpler physical fuel sensor provides similar data, the physical sensor data must be accessible.
The Data Act takes a technology-neutral approach as of September 2025, allowing manufacturers to choose how they provide data access - whether through remote backend solutions, onboard access, or data intermediation services. However, three essential requirements apply:
Data provided to users and third parties must match the quality available to the manufacturer itself. This means:
The guidance clearly prohibits discrimination: data cannot be made available to independent service providers at lower quality than what manufacturers provide to their own subsidiaries, authorized dealers, or partners.
The "easily available" mandate means manufacturers cannot impose:
In practice: If data access requires specialized tools like proprietary OBD-II readers, manufacturers must either provide these tools at no additional cost with the vehicle or implement alternative access methods such as remote backend servers.
The guidance clarifies that “readily available data” includes:
For OEMs implementing extended vehicle concepts where data flows to backend servers, this has significant implications. Even if certain data points aren’t currently transmitted due to bandwidth limitations, cost considerations, or perceived lack of business use-case, they may still fall within scope if retrievable through simple operations.
When assessing whether obtaining data requires “disproportionate effort,” manufacturers should consider:
The September 2025 guidance distinguishes between services requiring Data Act compliance and those that don’t.
Vehicle-related services require bi-directional data exchange affecting vehicle operation:
Traditional aftermarket services generally aren't considered related services:
The key distinction: services must affect vehicle functioning and involve transmitting data or commands to the vehicle to qualify as "vehicle-related services" under the Data Act.
The guidance issued in September 2025 draws a clear line in the Data Act's cost structure that directly impacts business models.
When vehicle owners or lessees request their own vehicle data - either directly or through third parties they've authorized - this access must be provided:
Under Article 9 of the Data Act, manufacturers can charge reasonable compensation for B2B data access. This applies when business partners request data, including:
For context: The Commission plans to issue detailed guidelines on calculating reasonable compensation under Article 9(5), which will provide specific methodologies for determining fair pricing. This forthcoming guidance will be crucial for manufacturers developing their data plans to monetize data while ensuring compliance.
Key Limitation: These compensation rights have no bearing on other existing regulations governing automotive data access, including technical information necessary for roadworthiness testing. The Data Act's compensation framework applies specifically to the new data sharing obligations it creates.
The extended vehicle concept, where data continuously flows from vehicles to manufacturer backend servers, creates both opportunities and obligations. This architecture makes data readily available to OEMs, who must then provide equivalent access to users and third parties.
Action items:
Data processed "on the edge" within the vehicle and immediately deleted isn't subject to sharing requirements. However, the September 2025 guidance encourages manufacturers to consider the importance of certain data points for independent aftermarket services when deciding whether to design these data points as retrievable.
Critical data points for aftermarket services:
Making these retrievable benefits the broader automotive ecosystem and may provide competitive advantages in partnerships.
While the Data Act is technology-neutral, chosen access methods must meet quality requirements. If a particular implementation - such as requiring users to physically connect devices to OBD-II ports - results in data that is less accurate, complete, or timely than backend server access, it fails to meet the quality obligation.
Manufacturers should evaluate access methods based on:
Grape Up's Databoostr platform was developed specifically to address the complex requirements of the EU Data Act. The solution combines specialized legal, process, and technological consulting with a proprietary data sharing platform designed for automotive data compliance.
Learn more about Databoostr and how it can help your organization meet EU Data Act requirements.
Databoostr's architecture directly addresses the key requirements established in the Commission's guidance:
Quality Equivalence: The platform ensures data shared with end users and third parties matches the quality available to manufacturers, with built-in controls preventing discriminatory access patterns.
Ease of Access: Multiple access methods—including remote backend integration and user-friendly interfaces - eliminate technical barriers for end users while supporting sophisticated B2B integrations.
Readily Available Data Management : The platform handles both currently collected data and newly accessible data points, managing the complexity of determining what constitutes "readily available" under the guidance.
Check our case studies : EU Data Act Connected Vehicle Portal and Connected Products Data Sharing Platform
Databoostr's modular design addresses both immediate compliance needs and strategic opportunities. Organizations implementing the platform for EU Data Act requirements can seamlessly activate additional modules for data monetization:
This setup supports both compliance and revenue growth from a single platform, reducing IT complexity while meeting the guidance's technical requirements.
The Databoostr implementation approach aligns with the guidance's requirements through:
Legal Consulting
Process Consulting
Technical Consulting
Platform Customization
Comprehensive Testing
With the extended vehicle concept creating readily available data obligations, manufacturers need ongoing platform management. Databoostr provides:
Now - March 2026: Complete data inventory, classify according to guidance definitions, design technical architecture, begin platform implementation
March - July 2026: Finalize platform integration, conduct comprehensive testing, establish B2B partnership frameworks, train internal teams
July - September 2026: Run parallel systems, validate compliance, prepare documentation for regulatory authorities, establish monitoring processes
September 2026 and Beyond: Full enforcement begins, ongoing compliance monitoring, response to Commission's forthcoming compensation calculation guidelines
The Commission's September 2025 guidance removes ambiguity that has delayed planning for some organizations. With regulatory requirements now precisely defined and less than eleven months until enforcement begins, manufacturers should be finalizing their compliance plans and beginning implementation.
The guidance encourages affected industry stakeholders to engage in dialogue achieving balanced implementation. The Commission also emphasizes coordination between Data Act enforcement authorities and other automotive regulators, including those overseeing type approval and data protection, to ensure smooth interplay between regulations.
For automotive manufacturers, three facts are now clear:
Organizations that haven't yet begun implementation should treat the Commission's guidance as a final call to action.

The EU Data Act is about to change the rules of the game for many industries, and automotive OEMs are no exception. With new regulations aimed at making data generated by connected vehicles more accessible to consumers and third parties, OEMs are experiencing a major shift. So, what does this mean for the automotive space?
First, it means rethinking how data is managed, shared, and protected . OEMs must now meet new requirements for data portability, security, and privacy, using software compliant with the EU Data Act.
This guide will walk you through how they can prepare to not just survive but thrive under the new regulations.
The EU Data Act deadlines OEMs can’t miss
- Chapter II (B2B and B2C data sharing) has a deadline of September 2025.
- Article 3 (accessibility by design) has a deadline of September 2026.
- Chapter IV (contractual terms between businesses) has a deadline of September 2027.
The EU Data Act establishes specific obligations for automotive OEMs to ensure secure, transparent, and fair data sharing with both consumers (B2C) and third-party businesses (B2B). The following key provisions outline the requirements that OEMs must fulfill to comply with the Act.
a) The identity of the third party
b) The purpose of data use
c) The type of data that will be shared
d) The right of the user to withdraw consent for the third party to access the data
1. Fair access to data:
2. Compliance with security and privacy regulations:
3. Protection of trade secrets
Understanding the specific obligations is only the first step for automotive OEMs. Based on this information, they can build software compliant with the EU Data Act. To navigate these new requirements effectively, OEMs need to adopt an approach that not only meets regulatory demands but also strengthens their competitive edge.
Automotive OEMs must take a strategic approach to both their software and operational frameworks, balancing compliance requirements with innovation and customer trust. The key is to prioritize solutions that improve data accessibility and governance while minimizing costs. This starts with redesigning connected products and services to align with the Act’s data-sharing mandates and creating solutions to handle data requests efficiently.
Another critical focus is balancing privacy concerns with data-sharing obligations . OEMs must handle non-personal data responsibly under the EU Data Act while managing personal data in accordance with GDPR. This includes providing transparency about data usage and giving customers control over their data.
To achieve this balance, OEMs should identify which data needs to be shared with third parties and integrate privacy considerations across all stages of product development and data management. Transparent communication about data use, supported by clear policies and customer controls, helps to reinforce this trust.
The EU Data Act presents compliance challenges, but it also offers significant opportunities for OEMs that are prepared to adapt. By meeting the Act’s requirements for fair data sharing, OEMs can expand their services and build new partnerships. While direct monetization from data access fees is limited, there are numerous opportunities to leverage shared data to develop new value-added services and improve operational efficiency.
To move to implementation, OEMs must take targeted actions that address the compliance requirements outlined earlier. These steps lay the groundwork for integrating broader strategies and turning compliance efforts into opportunities for operational improvement and future growth.
Integrate data accessibility into vehicle design
Start integrating data accessibility into vehicle design now to comply by 2026. This involves adapting both front and back-end components of products and services to enable secure and seamless data access and transfer according to the EU Data Act.
Provide user and third-party access to generated data
Introduce easy-to-use mechanisms that let users request access to their data or share it with chosen third parties. Access control should be straightforward, involving simple user identification and making data accessible to authorized users upon request. Develop dedicated data-sharing solutions, applications, or portals that enable third parties to request access to data with user consent.
Implement trade secret protection measures
OEMs should protect their trade secrets by identifying which vehicle data is commercially sensitive. Implement measures like data encryption and access controls to safeguard this information when sharing data. Clearly communicate your approach to protecting trade secrets without disclosing the sensitive information itself.
Implement transparent and secure data handling
Provide clear information to users about what data is collected, how it is used, and with whom it is shared. Transparent data practices help build trust and align with users' data rights under the EU Data Act.
Remember about the non-personal data that is being collected, too. Apply appropriate measures to preserve data quality and prevent its unauthorized access, transfer, or use.
Enable data interoperability and portability
The Act sets out essential requirements to facilitate the interoperability of data and data-sharing mechanisms, with a strong emphasis on data portability. OEMs need to make their data systems compatible with third-party services, allowing data to be easily transferred between platforms.
For example, if a car owner wants to switch from an OEM-provided app to a third-party app for vehicle diagnostics, OEMs must not create technical, contractual, or organizational barriers that would make this switch difficult.
Prepare the data
Choose a data format that fulfills the EU Data Act’s requirement for data to be shared in a “commonly used and machine-readable format.” This approach supports data accessibility and usability across different platforms and services.
The EU Data Act is bringing new obligations but also offering valuable opportunities. Navigating these changes may seem challenging, but with the right approach, they can become a catalyst for growth.
Cars used to just get us from point A to point B. Today, they function more like high-tech hubs that track GPS locations, store phone contacts, and gather details about our driving habits. This shift hasn’t escaped the attention of lawmakers and regulators. In Canada, conversations about data privacy have become louder and more urgent , especially with the Consumer Privacy Protection Act (CPPA) on the way.
Even though the CPPA is designed to handle personal data in general, it still lays down important rules for handling personal information. In other words, if you’re in the automotive business, you’ll want to pay close attention. Understanding how this new legislation applies to the data you collect and protect is critical for maintaining trust with customers and staying on the right side of the law.
Think of the Consumer Privacy Protection Act as the next chapter in Canada’s privacy story. Currently, the Personal Information Protection and Electronic Documents Act (PIPEDA) guides how companies handle personal data. But as online services grow more complex, the government wants to give Canadians stronger rights and clearer protections.
CPPA aims to refine or replace key parts of PIPEDA, focusing on three main things: giving people more control over their data, making sure businesses are upfront about what they do with it, and creating tougher consequences for those who violate the rules.
Key provisions
Under the CPPA, organizations must get informed, meaningful permission before collecting or using someone’s personal data.
The CPPA allows individuals to direct the secure transfer of their data, which simplifies switching providers. Plus, you can request that a company delete your information if it’s no longer needed or you no longer agree to its use.
Companies using AI and machine learning must be prepared to explain how they arrive at certain conclusions if they rely on personal information. No more mystery algorithms making big calls without any explanation.
In the past, fines for privacy violations could be sizable, but the CPPA raises the stakes. Businesses that break the rules could face penalties of up to 5% of their global revenue or CAD 25 million, whichever is greater.
Modern vehicles collect a surprising amount of personal information, from real-time locations to driver preferences. Although the CPPA doesn’t single out car manufacturers or dealers, it covers any organization that handles personal data. That puts the automotive industry on notice for meeting these new standards, and here’s what that might look like:
1. Consent and transparency
2. Data minimization and retention
3. Data security measures
4. Rights to erasure and portability
5. Enforcement and fines
Privacy compliance isn’t the only area automakers need to watch.
Bill C-27 introduced the CPPA, but it also includes the Artificial Intelligence and Data Act (AIDA), which sets rules for AI-powered systems. While the CPPA focuses on protecting personal data, AIDA applies to high-impact AI applications like those used in autonomous driving, predictive maintenance, and driver behavior analysis.
If AI plays a role in setting insurance rates, making in-car recommendations, or adjusting vehicle safety settings, companies may need to document AI training methods, track potential biases, and provide explanations for automated decisions that affect individuals.
The CPPA already requires transparency when personal data feeds into AI-driven outcomes, but AIDA adds another layer of oversight.
The Consumer Privacy Protection Act already affects modern vehicles, which capture everything from location data to driver habits and phone contacts.
However, because the CPPA is designed for all businesses, many people anticipate future rules specifically tailored to connected cars. Such regulations would go beyond the CPPA’s general standards, addressing the unique ways automotive data flows through telematics, in-car apps, and onboard sensors.
On the international front, the EU Data Act sets out rules for cross-border data handling, which matters if your cars or data move beyond Canada’s borders. The US Right to Repair Act also gives drivers and independent repair shops greater access to diagnostic information, raising new questions about how personal data is managed.
With these overlapping developments, it’s wise for automotive companies to adopt a comprehensive approach to privacy and data sharing. One that covers both home-grown regulations and global shifts.
As an OEM, you need to balance international obligations, regional privacy laws, and the technical demands of connected vehicles.
We’re here to assist. Our team not only provides IT consulting but also develops custom software solutions to help you meet complex regulatory requirements.
Reach out for tailored solutions and expert guidance.