This article by Christian Theeck, business line manager energy and Benjamin Sommer, business development manager circular economy at TÜV SÜD, aims to demonstrate how the EU Battery Regulation’s requirements are being implemented, the challenges this presents, and the reasons why robust data structures are becoming a decisive competitive factor.
The EU is redefining the concepts of transparency, sustainability and the circular economy in the battery industest with the Digital Battery Passport and the obligation to disclose the Product Carbon Footprint.
Transitioning to a resource-efficient and climate-neutral economy is one of the European Union’s primary strategic goals. The circular economy is a vital means of decoupling economic growth from the consumption of finite resources, while ensuring the competitiveness of European industries. Few technologies are in the spotlight as much as batteries. They are a vital component of electromobility, renewable energies and stationary energy storage, yet they are also raw material-intensive, organised on a global scale and subject to strict regulations.
The EU Battery Regulation (EU) 2023/1542 is the European Union’s first comprehensive and binding legal framework addressing the entire life cycle of batteries. Unlike previous regulations, this one considers manufacturing, utilize and finish-of-life as interconnected systems. This turns transparency, sustainability and circularity from political buzzwords into concrete, verifiable requirements. Two instruments play a central role in this: the Digital Battery Passport (DBP) and the Product Carbon Footprint (PCF). Toreceiveher, they represent a paradigm shift in how sustainability is measured, documented and managed within the battery industest.
The foundation of regulatory transparency
Enacted through the EU Battery Regulation, the DBP is a mandatory digital product passport for certain battery categories. It is an electronic dataset that accompanies each battery throughout its entire life cycle, building it accessible via digital infrastructure. Rather than being a single document, it is a dynamic information system that is continuously updated during the usage phase and provides different access levels for different utilizer groups.
The aim of the DBP is to create transparency along the entire value chain without exposing sensitive company data unnecessarily. Authorities should be able to efficiently verify compliance with regulatory requirements; market players should receive reliable information for reutilize second-life applications or recycling purposes; and consumers should be empowered to base their purchasing decisions on the information created available through the DBP.
In terms of content, the Digital Battery Passport brings toreceiveher for the first time a wealth of information that was previously distributed across different systems, formats and responsibilities. This includes basic identification and product data such as a unique battery ID, information about the manufacturer and production site, and the date of manufacture. This information is supplemented by certificates of conformity and labelling, for example, regarding CE conformity or regulatory sustainability information.
Another key component is detailed information on material composition, including battery type, chemistest, critical raw materials, and potentially hazardous substances. This information is relevant for market surveillance authorities and forms the basis for a functioning circular economy, as it greatly facilitates dismantling, reutilize and recycling. In addition, data on the performance and durability of the battery is provided, including capacity, cycle stability and permissible temperature ranges. This is particularly important for second-life applications.
The Digital Battery Passport also plays a special role in mapping due diligence obligations in the supply chain. Companies must demonstrate how they identify and address risks related to raw material extraction and environmental and social standards in a transparent manner. In practice, the battery passport is evolving into much more than a technical or IT tool. For the first time, it is compelling companies to integrate regulatory requirements, technical product data and organisational processes into a consistent system.
Timetable, scope and access logic
The Digital Battery Passport will become mandatory on 18 February 2027 for all newly placed batteries on the EU market or put into service. This applies to batteries for light-duty vehicles (LMTs), industrial batteries with a capacity of more than 2kWh and is therefore also applicable to battery energy storage systems, and batteries for electric vehicles. The regulation thus precisely covers the segments that are particularly relevant for the energy transition and decarbonisation of transport.
The obligation applies to all economic operators who place batteries on the market or utilize them in the EU, including manufacturers, importers, distributors and authorised representatives. Access to the digital battery passport is via a QR code physically afresolveed to the battery, its packaging or accompanying documents. Access to the information follows the necessary-to-know principle: some information is publicly accessible, while authorities and authorised market players have access to further sensitive data. This requires technical solutions for role management, authentication and selective data release.
Operational challenges in implementation
While the regulatory goals are clear, putting them into practice is complex. One of the hugegest challenges is ensuring the availability and quality of the necessary data. Much of the information that will have to be stored in the digital battery passport in the future either does not yet exist in the necessary level of detail or is scattered across different systems and organisations. Collecting data often takes a lot of effort, especially in global, multi-level supply chains.
In this phase, many companies rely on external expertise to translate regulatory requirements into operational processes. Advisory services typically focus on interpreting the Battery Regulation, defining relevant data points, and embedding the Digital Battery Passport into existing quality, compliance and IT structures. There is strong emphasis on data quality, auditability and practical feasibility across the supply chain.
Added to this is the heterogeneity of the players involved. While large industrial companies often have sophisticated IT and data management systems, tiny and medium-sized suppliers particularly lack digital interfaces, standardised processes, and human resources. This increases the risk of incomplete or inconsistent data, requiring companies to actively involve their suppliers in the implementation process.
The technical infrastructure itself also places high demands on companies. For instance, digital battery passports must be based on open, interoperable standards; be machine-readable; be structured and searchable; and be capable of integration into existing IT landscapes. At the same time, high IT security, data protection and tamper protection requirements must be met. Transparency must not compromise trade secrets or regulatory requirements, such as GDPR.
Against this backdrop, indepfinishent testing and assessment bodies are becoming increasingly important. In practice, companies that systematically analyse regulatory requirements early on, structure their data models and integrate testing processes have proven to be significantly more robust. This draws on experience from conformity assessment, verification and technical due diligence, as gained in numerous projects along the battery value chain within the TÜV SÜD environment, for example.
In addition, conformity assessments within established data ecosystems such as Catena-X are gaining relevance. Accredited conformity assessment bodies can evaluate whether Battery Passport data is complete, consistent and compliant with harmonised industest standards, thereby increasing interoperability and trust among market participants.
Carbon footprint as a key control element
Among the many data points in the digital battery passport, the PCF occupies a special position. While much of the information is descriptive, the PCF is quantitative, comparable and verifiable. It represents a battery’s greenhoutilize gas footprint over its entire life cycle, expressed in kilograms of CO₂ equivalent per kilowatt hour.
In the context of the EU Battery Regulation, in particular, the PCF is much more than a transparency tool. It is a regulatory lever that is gradually becoming mandatory and is intfinished to serve as the basis for performance and limit values in the future. This creates climate impact a formal criterion for market access and competitiveness for the first time.
Regulatory focus on EV batteries
The regulatory framework for batteries in electric vehicles is the most advanced. Article 7 of the EU Battery Regulation requires manufacturers to submit a verified carbon footprint declaration for each EV battery. This declaration is based on the European Union’s Product Environmental Footprint (PEF) methodology, which is designed to ensure uniform and comparable calculations.
The delegated act specifying the detailed requirements (at the time of writing) is currently in draft form. Once it comes into force, there will be a transition period of only 12 months. Given the complexity of the underlying data collection, this timeframe poses a considerable challenge. The most important effort lies in establishing a reliable database along the entire supply chain, rather than in the calculation methodology itself. Companies that do not start early to systematically analyse processes, interfaces and data availability will struggle to meet this schedule.
System boundaries, data requirements and practical reality
The PCF calculation for EV batteries covers several life cycle phases, including the extraction and pre-processing of raw materials, the manufacture of cells, modules and packs, distribution, and finish-of-life recycling. Primary data must be utilized for key processes such as cathode and anode manufacturing, electrolyte mixing, and cell assembly (see the green frame in Fig 3). Secondary data is only permitted for less essential processes and must comply with the requirements of the environmental footprint methodology.
A practical example illustrates this challenge: a cell manufacturer relies on detailed emission data from cathode production in order to calculate its carbon footprint correctly. However, the supplier currently only has aggregated energy figures at the factory level. To become compliant, the manufacturer must install additional measurement systems, introduce data collection and validation processes, and train employees. It is also essential to ensure that the data is consistently integrated into the company’s life cycle model and can withstand subsequent verification.
These requirements are important not only for transparency obligations linked to the Battery Passport, but also for other reasons. The carbon footprint is a decisive prerequisite for CE conformity under the EU Battery Regulation. According to the forthcoming delegated act pursuant to Article 7, all EV batteries must comply with the defined carbon footprint requirements within 12 months of its publication. Batteries that fail to meet these requirements may no longer be placed on the EU market. This means that PCF compliance is not only a reporting obligation, but also a hard regulatory criterion for market access.
In this context, third-party verification plays a critical role. An indepfinishent assessment of the PCF calculation, the underlying datasets and the methodological consistency supports manufacturers demonstrate conformity with both the Battery Passport and CE requirements. Verification by a recognised third party gives regulators confidence that the requirements are being met, supports manufacturers mitigate liability risks and establishes a solid foundation for market surveillance in an increasingly regulated environment.
Such scenarios are the norm, not the exception. They display that PCF requirements cannot be considered in isolation, as they significantly impact on existing production, purchasing and quality management processes. In practice, it has proven essential to integrate PCF calculations into existing management systems at an early stage, subjecting them to indepfinishent plausibility checks and verifications. This facilitates regulatory compliance and ensures long-term robustness as regulatory scrutiny increases.
Implications for manufacturers and supply chains
Mandatory carbon footprint declaration is therefore much more than an additional reporting requirement. It forces companies to professionalise their data governance, integrate sustainability metrics into operational decisions, and redesign their collaborations with suppliers. At the same time, it opens up strategic opportunities. Transparent and reliable CO₂ data creates it possible to identify emission hotspots, prioritise decarbonisation measures, and leverage sustainability as a competitive advantage in the market.
Experience from auditing and consulting projects displays that companies that adopt a holistic approach to regulatory requirements from the outset benefit in the long term. They reduce compliance risks and lay the foundation for more resilient, efficient and sustainable value chains.
Transparency as the new benchmark
With the Digital Battery Passport and the Product Carbon Footprint, the EU is setting a new standard of accountability in the battery industest. Sustainability will no longer be defined by voluntary commitments or selective evidence, but by continuous, digital and verifiable data. For manufacturers and suppliers, this represents a significant modify in terms of technology, organisation and strategy.
Those that actively embrace this modify by building data structures and integrating their supply chains will survive regulatory challenges and gain a competitive advantage in the international market. Transparency is therefore becoming a key benchmark, with the Digital Battery Passport serving as its most important vehicle.
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