Digital Battery Passport (DBPs) is opening new doors for better traceability, circularity, second-life usability, and recyclability in the battery sector. However, meeting the data requirements of DBPs is quickly becoming one of the most demanding challenges for battery manufacturers, importers, and downstream operators.
With the EU implementing new rules requiring comprehensive lifecycle information for better sustainability, traceability, and circularity, organisations are being asked to collect, verify, and share detailed battery data across global and highly fragmented supply chains.
For many organisations, the difficulty lies not in understanding the regulation, but in making high-quality data available in a consistent, auditable, and scalable way.
The EU Battery Regulation places data at the centre of compliance. It requires companies to rethink how battery information is captured, governed and exchanged over the entire lifecycle.
Today, we’ll discuss why battery passport data collection is so challenging, where the main barriers lie, and how Digital Battery Passports can help transform compliance from a regulatory obligation into a source of operational and strategic value.
EU Digital Battery Passport Requirements
Regulation (EU) 2023/1542 introduces mandatory Digital Battery Passports for electric vehicle batteries, industrial batteries and light mobility batteries above 2 kWh, with obligations applying from 2027 onwards. Each battery placed on the EU market must be linked to a digital record containing structured and verified lifecycle data.
The regulation requires information on material composition, recycled content, carbon footprint, performance and durability, as well as supply chain traceability. This data must be accurate, kept up to date, and stored in interoperable, machine-readable formats. Importantly, the passport must remain accessible even as the battery changes ownership or status, including during reuse, repurposing or preparation for recycling.
These requirements are designed to support safer battery use, enable circular economy practices, and allow regulators to monitor compliance with sustainability and recovery targets. However, they also expose significant weaknesses in existing data collection practices.
Challenges of Battery Passport Data Collection
Battery supply chains are complex and multi-tiered. A single battery can involve raw materials sourced from several regions, components produced by different suppliers, and assembly across multiple facilities. Each actor holds a fragment of the data required for the passport, yet that information is often stored in incompatible systems or not recorded at all.
Industry consultations and studies consistently show gaps in data availability. Information on recycled content, hazardous substances and precise material composition is frequently incomplete or based on estimates rather than verified records. Many organisations still rely on manual processes such as spreadsheets or static documents, which are not suitable for continuous lifecycle updates or regulatory audits.
A report by the European Commission highlights that traceability and data availability remain major barriers to effective battery circularity, particularly across upstream supply chains.
These challenges are escalated by the fact that many suppliers, especially outside the EU, are not directly subject to the regulation. Without contractual or technical mechanisms to ensure data sharing, critical information can remain locked in silos.
Technical, Standardisation and Regulatory Challenges
Even when the data is available, it is often recorded using different definitions, formats and calculation methods. This lack of standardisation makes integration difficult and increases the risk of inconsistencies.
While the EU Battery Regulation calls for interoperable and open standards, many of the technical specifications are still being developed through implementing acts and standardisation bodies.
At the same time, many organisations lack the digital infrastructure required to support real-time data capture, secure storage and controlled data exchange. Legacy IT systems were not designed for cross-company traceability or regulatory reporting at this level of detail. Upgrading these systems requires investment, technical expertise and organisational change.
Regulatory uncertainty adds another layer of complexity. Methodologies for carbon footprint calculation, data verification processes and access rights for different stakeholders are still evolving. Companies must therefore prepare for compliance while remaining flexible enough to adapt as guidance becomes clearer.
Organisational and Supply Chain Barriers
Data collection challenges also reflect organisational and cultural issues. Sharing detailed information across borders and corporate boundaries raises concerns about confidentiality and competitive sensitivity. Without trusted governance frameworks, some actors are reluctant to disclose data on sourcing, materials or processes.
Cost is another important factor, particularly for small and medium-sized enterprises. Investments in digital systems, staff training and ongoing compliance monitoring can be significant. Without efficient tools and clear processes, compliance may be perceived as a burden rather than an opportunity.
Turning Compliance into Long-Term Value
Despite these challenges, robust data collection offers clear benefits. High-quality, machine-readable data improves compliance readiness and reduces the risk of penalties or market access restrictions. It also supports better operational decisions, from safer battery reuse to more efficient recycling.
Standardised data enables automation, reduces duplication of effort and improves data accuracy. It also builds trust with regulators, customers and partners. In the longer term, reliable battery data supports circular business models, secondary materials markets and sustainability reporting under frameworks such as the Corporate Sustainability Reporting Directive (CSRD).
How BASE Supports Efficient Battery Passport Data Collection
At the BASE project, we focus on making battery passport data collection practical, reliable and scalable. Our Digital Battery Passport framework is designed to support structured data capture across the entire battery lifecycle, from design and manufacturing to use, reuse and end-of-life management.
BASE integrates data collection with existing enterprise systems to reduce manual effort and improve accuracy. We place strong emphasis on interoperability, verification and data governance, ensuring that information is auditable, secure and aligned with EU regulatory requirements. Through real-world pilot deployments, we demonstrate how improved data collection supports compliance while also enabling safer reuse, better recycling outcomes and stronger circular value chains.
Addressing technical, organisational and governance challenges together allows BASE to help organisations move from fragmented records to streamlined, future-ready compliance.
Looking Ahead
As the 2027 deadline approaches, data readiness will become a defining factor for access to the EU battery market. Organisations that invest early in robust data collection and Digital Battery Passport frameworks will be better positioned to manage regulatory risk, improve operational efficiency and unlock circular economy value.
Effective battery passport compliance depends on more than technology alone. It requires coordinated action across supply chains, clear data governance and digital systems designed for transparency. Through initiatives like BASE, the transition towards data-driven, compliant and circular battery value chains is already underway.
The BASE project has received funding from the Horizon Europe Framework Programme (HORIZON) Research and Innovation Actions under grant agreement No. 101157200.
References:
EUR-Lex - Regulation (EU) 2023/1542 on batteries and waste batteries: https://eur-lex.europa.eu/eli/reg/2023/1542/eng
European Commission - Waste & Recycling - Batteries: https://environment.ec.europa.eu/topics/waste-and-recycling/batteries_en
European Commission - Green Deal: Sustainable batteries for a circular and climate-neutral economy: https://ec.europa.eu/commission/presscorner/detail/en/ip_20_2312
BASE Project - Digital Battery Passport: Enabling Battery Lifecycle Traceability from Mining to Recycling: https://base-batterypassport.com/blog/traceability-9/digital-battery-passport-enabling-battery-lifecycle-traceability-from-mining-to-recycling-73
BASE Project - The Six Pillars of Digital Battery Passport Content: How BASE Project Strengthens Trust, Transparency, and Circularity: https://www.base-batterypassport.com/blog/circularity-8/the-six-pillars-of-digital-battery-passport-content-how-base-project-strengthens-trust-transparency-and-circularity-65