The European Union’s Digital Battery Passport (DBP) is gradually becoming one of the most transformative regulatory developments for the battery industry. Established under Regulation (EU) 2023/1542, the Battery Passport will require detailed lifecycle data on materials, performance, safety and sustainability for batteries placed on the EU market from 2027 onwards. DBPs will be digital records, linked to batteries with a unique identifier such as a QR code, making detailed information available to regulators, authorised stakeholders and, in some cases, the public.

Organisations that operate across multiple EU member states need to meet these requirements, presenting an additional layer of complexity. The core rules may be harmonised at the EU level, but differences in enforcement practices, language expectations, technical implementation and market surveillance can affect how compliance is achieved in practice.

This article explains why cross-border compliance is needed, the specific challenges of cross-border compliance, and how Digital Battery Passports can support consistent outcomes across EU Member States.

Why Cross-Border Battery Passport Compliance Matters

Regulation (EU) 2023/1542 was adopted as a regulation rather than a directive to ensure uniformity in the internal market. Unlike directives, regulations apply directly and consistently across all EU member states without requiring national transposition. This means the legal obligations for Battery Passports are the same in principle in Paris, Warsaw or Madrid.

Despite this shared legal framework, companies still need to manage multiple enforcement environments. Each member state will establish market surveillance authorities that check data accuracy, conformity and risk management. How these authorities operate, their priorities and the focus of their enforcement actions can vary. Some may emphasise safety documentation in detail, while others prioritise lifecycle data on carbon footprint and recycled content. In practice, compliance teams must engage with different processes and expectations in each jurisdiction.

National authorities also have responsibility for taking corrective action if a battery or product is found non-compliant. For example, national market surveillance officers can evaluate risks and initiate actions to remove products from the market if they fail safety or conformity checks. That means exporters and EU-based manufacturers alike must prepare for interaction with multiple authorities operating under the same regulation but with their own enforcement practices.

Language and Documentation Challenges

Another challenge is the language and documentation requirements. The EU Battery Regulation notes that all necessary information and labelling must be accessible to users and authorities. Some national authorities may expect supporting documents, such as declarations of conformity, safety information or hazardous substance reports, to be provided in local languages. While EU harmonisation reduces variation, companies may need to localise documentation to meet national expectations for readability and legal clarity.

Ensuring that translated, verified data remains fully aligned with the underlying technical content and regulatory meaning is critical. Inconsistent or inaccurate translations can create confusion for market surveillance authorities and increase the risk of enforcement action.

Data Interoperability and Technical Standards

Digital Battery Passports are intended to be machine-readable and interoperable across digital systems. The regulation explicitly mandates interoperability in format and access, with clear rules for public access, authorities, and authorised downstream stakeholders.

However, many technical standards and implementing acts that set out detailed formats, data schemas and interfaces are still being developed. Until these technical frameworks are fully agreed and published, companies face uncertainty about how best to structure and manage their data for compliance. Larger organisations with mature data systems may build flexibility to adapt to future standards, while smaller companies or suppliers with manual systems may struggle to scale their capabilities.

Technical readiness also varies between member states. Some national authorities are investing in advanced digital infrastructure to validate and monitor passport data, while others may initially rely on manual or semi-automated checks. Creating passport data that integrates seamlessly with multiple systems requires careful planning and robust interoperability strategies.

Supply Chain Complexity and Data Quality Risk

Battery supply chains are inherently global and multi-tiered. Components such as cells and modules may be produced in different countries, with raw materials sourced worldwide. Collecting accurate data on material composition, carbon emissions, recycled content and due diligence compliance from this extended network is already challenging. Converting that information into a standard format that meets the expectations of authorities in different EU countries adds further complexity.

For example, data on carbon footprint, recycled content and due diligence compliance must be verifiable and reflect common methodologies. If suppliers in one country provide data in a non-standard format, the company responsible for the Battery Passport must convert and verify that information in a way that is acceptable to market surveillance in another country.

Market Surveillance and Enforcement Variance

Although the regulation sets a common legal baseline, member state authorities can adopt different approaches to market surveillance. Some countries may conduct proactive audits and request data samples periodically, while others may respond primarily to complaints or triggers such as safety incidents. Regulatory timelines, audit frequencies and risk focus areas can differ, requiring companies to monitor and adapt to multiple enforcement landscapes.

A unified, digitally enabled approach to passport data storage improves readiness for audits in all jurisdictions. Companies that centralise and standardise their documentation, while making it accessible in a structured digital format, are better positioned to respond to questions from diverse authorities.

Strategies for Managing Cross-Border Compliance

Several practical strategies can help organisations manage the complexity of compliance across EU member states:

• Establish a central data governance hub within the organisation to manage passport data creation, verification and updates.
• Implement interoperable digital systems that can generate, store and share passport data in standard formats aligned with evolving technical requirements.
• Engage with national market surveillance authorities early to understand specific expectations and preferred documentation practices.
• Build supplier engagement programmes to ensure upstream data is accurate, verifiable and consistently formatted.

These strategies are essential for companies that place large volumes of batteries on the market in multiple EU countries.

How Base Supports Cross-Border Battery Passport Readiness

At the BASE project, we recognise that managing Battery Passport requirements across several EU member states is a significant challenge for manufacturers, importers, repurposing actors and other economic operators. Our Digital Battery Passport framework is designed to support consistent and interoperable data collection, storage and governance across jurisdictions.

BASE provides tools and methodologies that help organisations prepare passport data in standardised digital formats, verify supplier information and maintain lifecycle records that can withstand scrutiny from different market surveillance authorities. We emphasise data integrity, structured tagging and secure access control to ensure that passport information is reliable and compliant with Regulation (EU) 2023/1542 expectations. By providing a unified platform adaptable to evolving technical standards, BASE helps companies streamline cross-border compliance and focus on operational productivity rather than administrative complexity.

Closing Thoughts

Managing cross-border Battery Passport compliance will continue to be a defining challenge as the 2027 battery passport requirements deadline approaches. The benefits of harmonised battery data are clear: improved safety, enhanced circularity, market transparency and greater consumer confidence. At the same time, cross-border differences in enforcement practices, language use, digital infrastructure readiness and regulatory interpretation require careful planning and proactive management.

Organisations that invest in robust data governance, flexible digital systems and strong supplier partnerships will be better placed to meet their obligations efficiently and confidently. Early engagement with technology partners, suppliers and regulatory bodies will help companies build resilient compliance frameworks that support long-term success within the European battery ecosystem.

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/2023/1542/2024-07-18/eng

BASE Project – EU Battery Passport Regulation (Regulation (EU) 2023/1542): What You Need to Know in 2026: https://base-batterypassport.com/blog/regulations-4/eu-battery-passport-regulation-57

Centre for European Policy Studies (CEPS) Analysis on Implementing the EU Digital Battery Passport: https://cdn.ceps.eu/wp-content/uploads/2024/03/1qp5rxiZ-CEPS-InDepthAnalysis-2024-05_Implementing-the-EU-digital-battery-passport.pdf

EUROBAT Position Paper on the EU Battery Passport: https://eurobat.org/wp-content/uploads/2025/09/EUROBAT-battery-passport-omnibus-position-paper-.pdf

Joint Research Centre – Making the battery value chain safe and sustainable: https://joint-research-centre.ec.europa.eu/jrc-highlights-report-2024/batteries_en