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EU Battery Passport Requirements 2026

The European Union's Battery Regulation introduces the most significant traceability requirement in the history of battery manufacturing. By February 2027, every industrial battery above 2 kWh, every electric vehicle battery, and every stationary energy storage battery placed on the EU market must carry a digital battery passport — a comprehensive lifecycle record accessed via QR code. This article explains what the passport contains, who must comply, and how to prepare.

Why Battery Traceability Matters Now

The global battery market is projected to exceed 4,500 GWh of annual production by 2030. With this growth comes an urgent need for transparency across the value chain — from raw material sourcing to end-of-life management. The EU Battery Regulation (Regulation (EU) 2023/1542) responds to this need by establishing the world's first mandatory digital product passport for batteries.

Battery traceability is no longer a voluntary sustainability initiative. It is a regulatory requirement that determines whether your products can legally access the European market. Companies that treat the battery passport as a compliance checkbox will miss the strategic advantage: those who build robust data infrastructure now will lead in circular economy reporting, carbon footprint verification, and supply chain resilience.

This guide provides the engineering, compliance, and operational detail needed to understand and implement the EU battery passport requirement. Whether you manufacture cells, assemble packs, or integrate batteries into energy storage systems, the information below maps directly to the actions your organization must take before the February 2027 deadline.

What Is a Battery Passport?

A battery passport is a digital record that stores and communicates comprehensive data about a battery throughout its entire lifecycle. It functions as the battery's digital identity — a structured dataset that travels with the physical product from manufacturing through use, second-life applications, and eventual recycling.

Unlike a traditional product label, which provides static information at the point of sale, a battery passport is a living document. It is updated as the battery moves through the value chain, reflects real-time performance data, and provides different information to different stakeholders based on their role and authorization level.

Attribute Description
Definition A digital record containing lifecycle data for an individual battery or battery batch, accessible via a unique identifier
Access Method QR code or data matrix permanently affixed to the battery, linking to the digital passport
Purpose Enable traceability, transparency, circular economy participation, and regulatory compliance
Data Scope Manufacturing details, chemistry, performance metrics, carbon footprint, recycled content, supply chain information, end-of-life instructions
Update Frequency Continuous — data is updated as the battery progresses through its lifecycle
User Access Role-based — consumers, recyclers, regulators, and remanufacturers receive different data levels
Legal Basis Regulation (EU) 2023/1542, Articles 77–80 and delegated acts

Which Batteries Require a Battery Passport?

The EU Battery Regulation distinguishes between five categories of batteries. The passport requirement applies to four of them, with specific thresholds and effective dates. Understanding which category your product falls into is the first step in compliance planning.

Battery Type Passport Required? Threshold Effective Date Examples
EV Batteries Yes All (no threshold) 18 Feb 2027 Automotive traction batteries, e-bus packs, EV battery modules
Industrial Batteries Yes Capacity > 2 kWh 18 Feb 2027 Forklift batteries, telecom backup, UPS systems, industrial storage
Stationary Storage Batteries Yes Capacity > 2 kWh 18 Feb 2027 Home energy storage, C&I storage, grid-scale BESS
LMT Batteries Yes Capacity > 2 kWh 18 Feb 2028 E-bikes, e-scooters, light electric vehicles, golf carts
Portable Batteries No N/A N/A AA/AAA cells, phone batteries, laptop batteries, power tools

Note: Portable batteries are exempt from the passport requirement but must still comply with other provisions of the regulation, including registration in the EU Battery Database and recycling mark requirements. The 2 kWh threshold applies to the total capacity of the battery or battery system, not individual cells.

EU Battery Regulation Overview

Regulation (EU) 2023/1542 was adopted on June 13, 2023, entered into force on August 17, 2023, and replaces the previous Battery Directive (2006/66/EC). It is the most comprehensive battery legislation ever enacted, covering the entire lifecycle from raw material extraction to recycling.

Sustainability Requirements

Mandatory carbon footprint declarations, recycled content thresholds, and due diligence obligations for raw material sourcing. These requirements ensure batteries meet minimum environmental standards throughout their lifecycle.

Circular Economy Objectives

The regulation establishes collection, recycling, and material recovery targets. Battery passports enable these objectives by providing recyclers with the information needed for efficient material separation and recovery.

Traceability Requirements

The battery passport is the primary mechanism for achieving traceability. It creates an auditable chain of custody from raw material origin through manufacturing, distribution, use, and end-of-life processing.

Carbon Footprint Reporting

Delegated acts under the regulation specify the Product Environmental Footprint (PEF) methodology for battery carbon footprint calculation. The battery passport must include the carbon footprint value per kWh of rated capacity.

Battery Passport Compliance Timeline

The EU Battery Regulation follows a phased implementation schedule. Each phase introduces new obligations, and the battery passport requirement is among the later phases — but the preparation required to meet it begins now.

Date Requirement Affected Organizations Required Action
17 Aug 2023 Regulation enters into force All battery stakeholders Begin compliance planning; review existing data systems
18 Feb 2024 Producer registration obligation All battery producers placing batteries on EU market Register in the national battery producer register of each EU member state where batteries are sold
18 Feb 2025 Carbon footprint declaration for EV and industrial batteries EV battery and industrial battery manufacturers Complete PEF calculations; prepare carbon footprint declarations following the delegated act methodology
18 Aug 2025 Due diligence obligations All economic operators in the battery supply chain Implement due diligence policies for cobalt, lithium, nickel, and graphite sourcing per OECD guidelines
18 Feb 2026 Recycled content declarations Battery manufacturers Establish recycled content tracking systems; prepare declarations for cobalt, lithium, nickel, and lead
18 Feb 2027 Battery passport mandatory Manufacturers of EV batteries, industrial batteries >2 kWh, stationary storage batteries >2 kWh Full battery passport implementation with QR code, data architecture, and EU Battery Database integration
18 Feb 2028 LMT battery passport mandatory Manufacturers of LMT batteries >2 kWh Extend battery passport system to cover LMT battery category
18 Feb 2031 Mandatory recycled content thresholds (Phase 1) All battery manufacturers Achieve minimum 16% cobalt, 6% lithium, 6% nickel, 85% lead recycled content
18 Feb 2036 Mandatory recycled content thresholds (Phase 2) All battery manufacturers Achieve minimum 26% cobalt, 12% lithium, 15% nickel, 85% lead recycled content

What Data Must Be Included in a Battery Passport?

The regulation specifies mandatory data categories that every battery passport must address. The data is organized into functional groups, each serving a specific purpose in the battery's lifecycle management. Below is the complete data architecture required for compliance.

Category Required Data Examples Importance
Manufacturer Data Manufacturer name, country, registration number, contact information Company name, EU registration ID, address, authorized representative details Establishes legal responsibility and traceability to the producing entity
Battery Identification Battery model, serial number, date of manufacture, batch identifier Model number, unique serial, production date code, batch reference Enables individual battery tracking throughout the value chain
Chemistry & Composition Battery chemistry type, electrode materials, electrolyte type LFP, NMC, NCA, LMO; graphite anode; lithium salt electrolyte Critical for recycling, safety classification, and second-life assessment
Performance Specifications Rated capacity (Ah), energy capacity (kWh), nominal voltage, C-rate, operating temperature range 200 Ah, 76.8 kWh, 384V nominal, 0.5C, -20°C to +55°C Defines the battery's technical capabilities for matching to applications
Carbon Footprint Carbon footprint per kWh of rated capacity, PEF methodology reference, calculation boundary 45.2 kg CO₂e/kWh (cradle-to-gate), PEF Category Rules for batteries Mandatory disclosure; enables comparison and procurement decisions
Recycled Content Percentage of recycled cobalt, lithium, nickel, and lead 18% recycled cobalt, 8% recycled lithium, 7% recycled nickel Verifies compliance with mandatory recycled content thresholds
Supply Chain Information Due diligence report reference, sourcing origin, third-party audit status Cobalt sourced from DRC (audited), lithium from Australia, nickel from Indonesia Demonstrates responsible sourcing compliance per OECD due diligence guidelines
Performance & Health State of health (SoH), cycle count, capacity fade history, impedance data 92% SoH, 450 cycles, 3.2% capacity fade, 18 mΩ impedance Enables second-life assessment and residual value determination
Safety Information UN38.3 classification, safety data sheet reference, hazard warnings, transport classification UN3481 (lithium-ion pack), Class 9 hazardous material, SDS reference Ensures safe handling, transport, and storage throughout the lifecycle
End-of-Life Information Disassembly instructions, material composition for recycling, collection point information Disassembly sequence, cathode material type, nearest WEEE collection point Facilitates efficient recycling and material recovery at end of life

Battery Passport QR Codes Explained

The QR code (or equivalent data matrix) is the physical link between the battery and its digital passport. The regulation specifies precise requirements for this identifier to ensure universal accessibility and permanence throughout the battery's service life.

Purpose

The QR code provides instant access to the battery's digital passport. Any stakeholder — from a consumer checking battery provenance to a recycler identifying chemistry — can scan the code to retrieve the relevant data. The code must be unique to each battery or battery batch.

Data Access

Different user roles receive different data levels. Consumers see safety information, basic specifications, and carbon footprint. Recyclers see chemistry details and disassembly instructions. Regulators see full audit trails. The passport platform must enforce these access controls.

Permanence

The QR code must be permanently affixed and readable throughout the battery's expected lifetime. This requires durable materials and methods — laser engraving, metal plates, or high-durability adhesive labels rated for the battery's operating environment (temperature, UV exposure, chemical contact).

Security

The QR code must link to a secure endpoint. While the code itself is not encrypted, the platform it connects to must ensure data integrity, prevent unauthorized modifications, and maintain an auditable record of all data updates. Tamper-evident mechanisms are recommended.

QR Code Workflow Example

Step 1: Manufacturer generates QR code → links to battery passport in EU Battery Database
Step 2: QR code is permanently affixed to battery pack during assembly
Step 3: Distributor scans QR code → verifies passport data and updates distribution records
Step 4: End user scans QR code → views specifications, safety data, and carbon footprint
Step 5: At end of life, recycler scans QR code → accesses chemistry data and disassembly instructions
Step 6: Recycler updates passport with recycling event → material recovery data recorded

Battery Passport Data Architecture

Implementing a battery passport requires a robust data architecture that collects, validates, stores, and distributes information across the battery's lifecycle. The architecture must support real-time updates, role-based access control, and interoperability with the EU Battery Database.

Data Collection

Data originates from multiple sources: manufacturing execution systems (MES), battery management systems (BMS), supply chain management platforms, and third-party audit reports. The architecture must ingest structured data from each source and map it to the regulation's data schema.

Data Validation

Before data enters the passport, it must be validated against the regulation's data requirements. Missing fields, out-of-range values, and inconsistent formats must be flagged. Validation rules should be versioned to track changes as delegated acts refine the data specifications.

Data Storage

Passport data must be stored in a system that guarantees availability for the battery's expected lifetime (often 10-20 years). This requires redundant storage, data backup procedures, and a clear data retention policy. Cloud-based solutions with contractual uptime guarantees are the pragmatic choice.

Access Control

The architecture must implement role-based access control (RBAC). Different stakeholders receive different data levels. API endpoints must be authenticated, rate-limited, and logged. The platform must support data portability requirements under the regulation.

Implementation Process Flow

1. Map internal data fields to regulation schema → identify gaps
2. Establish data collection interfaces with MES, BMS, and supply chain systems
3. Implement validation engine with regulation-specific business rules
4. Configure role-based access control and API authentication
5. Integrate QR code generation and permanent marking process
6. Connect to EU Battery Database for passport registration
7. Test end-to-end workflow with pilot battery batch

Battery Passport Compliance Checklist

Use this checklist to track your organization's progress toward battery passport compliance. Each item maps to a specific regulation requirement. Complete all items before the February 2027 deadline.

Requirement Status Responsible Team Priority
Register in EU Battery Database Not Started Legal / Compliance High
Map internal data fields to regulation schema Not Started Engineering / Data High
Identify and fill data gaps Not Started Engineering / Quality High
Establish carbon footprint calculation (PEF) Not Started Sustainability / LCA High
Implement recycled content tracking system Not Started Procurement / Supply Chain High
Complete supply chain due diligence reports Not Started Procurement / Compliance High
Select or build passport platform Not Started IT / Engineering High
Implement QR code generation system Not Started Manufacturing / IT Medium
Establish permanent marking process Not Started Manufacturing Medium
Configure role-based access control Not Started IT / Security Medium
Connect BMS data feeds for SoH updates Not Started Engineering / Software Medium
Test end-to-end with pilot batch Not Started Quality / Engineering Medium
Train staff on passport data requirements Not Started HR / Compliance Medium
Prepare end-of-life and disassembly data Not Started Engineering / Sustainability Medium
Document data retention and update procedures Not Started Quality / Compliance Medium
Conduct internal compliance audit Not Started Quality / Compliance Low

Common Battery Passport Compliance Mistakes

Organizations frequently underestimate the complexity of battery passport implementation. Below are the most common mistakes, their consequences, and how to prevent them.

1. Treating the Passport as a Labeling Exercise

Consequence: Incomplete data, failed audits, non-compliance findings. A battery passport is a dynamic digital record, not a static label. Organizations that approach it as a labeling task produce documents that lack the lifecycle data the regulation requires.

Prevention: Build a data architecture that supports continuous updates from MES, BMS, and supply chain systems. Treat the passport as a data management project, not a documentation task.

2. Starting Too Late

Consequence: Rushed implementation, missing data fields, platform integration failures. Many organizations begin compliance work 6-12 months before the deadline, which is insufficient for the data infrastructure required.

Prevention: Begin data mapping and gap analysis immediately. The regulation entered into force in August 2023 — organizations should have started planning by early 2024.

3. Ignoring Carbon Footprint Calculation Complexity

Consequence: Inaccurate carbon footprint values in the passport, potential greenwashing allegations, and procurement disqualification. PEF calculation requires detailed lifecycle data that many manufacturers do not yet collect.

Prevention: Engage LCA consultants early. Establish data collection for raw material extraction, transportation, and manufacturing energy. Use the EU's Product Environmental Footprint Category Rules (PEFCRs) as the calculation framework.

4. Assuming QR Codes Are Simple

Consequence: Codes that degrade in operating environments, become unreadable, or fail to link to the correct passport. A QR code that cannot be scanned renders the entire passport inaccessible.

Prevention: Specify QR code durability based on the battery's operating environment. Test codes under real-world conditions (temperature cycling, UV exposure, chemical contact). Use laser engraving or metal plates for industrial and EV applications.

5. Neglecting Data Interoperability

Consequence: Passport data that cannot be exchanged with the EU Battery Database or other stakeholders' systems. Proprietary data formats create silos that violate the regulation's interoperability requirements.

Prevention: Adopt the data schema specified in the regulation's delegated acts. Use standardized APIs and data formats. Evaluate established platforms like Catena-X or the Battery Pass consortium's specifications.

6. Incomplete Supply Chain Due Diligence Data

Consequence: Passport entries that lack sourcing information, exposing the company to regulatory penalties and reputational risk. Due diligence is a mandatory passport component.

Prevention: Implement OECD Due Diligence Guidance-compliant processes for cobalt, lithium, nickel, and graphite. Require suppliers to provide traceability documentation. Maintain audit-ready records.

7. Not Planning for Data Updates Over Battery Lifetime

Consequence: Stale passport data that does not reflect current state of health, cycle count, or operational history. The passport must remain accurate throughout the battery's 10-20 year service life.

Prevention: Integrate BMS telemetry feeds with the passport platform. Establish automated data update workflows. Define data retention policies that cover the battery's expected lifetime plus regulatory retention periods.

8. Forgetting Role-Based Access Control

Consequence: Exposing sensitive commercial data (pricing, supplier names, proprietary chemistry details) to unauthorized parties, or failing to provide required data to authorized stakeholders.

Prevention: Define data access levels for each user role before implementation. Consumers need safety and specification data. Recyclers need chemistry and disassembly data. Regulators need full audit trails. Implement API authentication and access logging.

9. Ignoring End-of-Life Data Requirements

Consequence: Recyclers receive batteries without adequate disassembly instructions or chemistry information, reducing material recovery rates and increasing safety risks during processing.

Prevention: Include end-of-life data in the passport from initial production. Document disassembly procedures, material composition, and hazardous material locations. Update this data if the battery is remanufactured or repurposed.

10. Selecting a Platform Without Interoperability Verification

Consequence: Investment in a passport platform that cannot communicate with the EU Battery Database or exchange data with industry partners. Vendor lock-in creates long-term compliance risk.

Prevention: Before selecting a platform, verify its integration with the EU Battery Database. Confirm support for open data standards. Evaluate the platform's track record with other battery manufacturers. Prefer platforms that participate in interoperability consortia.

11. Overlooking the Difference Between Declaration and Verification

Consequence: Submitting self-declared values for carbon footprint or recycled content without the supporting evidence required for verification. Declarations without audit trails are insufficient for compliance.

Prevention: Maintain supporting documentation for every data point in the passport. Carbon footprint calculations must reference the PEF methodology and underlying data sources. Recycled content must be traceable to the recycling facility and batch.

12. Failing to Account for Imported Batteries

Consequence: Importers placing non-compliant batteries on the EU market. The regulation applies to all batteries placed on the EU market regardless of manufacturing origin.

Prevention: Importers must require battery manufacturers (especially outside the EU) to provide compliant passport data before placing batteries on the market. Authorize an EU-based representative if manufacturing occurs outside the EU.

How to Prepare for Battery Passport Compliance

Battery passport compliance requires coordinated action across engineering, procurement, IT, sustainability, and legal functions. The following roadmap provides a structured approach for organizations beginning their preparation.

Step 1: Regulatory Assessment

Identify which of your battery products fall under the passport requirement. Classify each product by battery type and capacity. Determine the applicable compliance deadline (February 2027 or February 2028). Map the regulation's data requirements to your existing data landscape.

Step 2: Data Gap Analysis

Compare the regulation's mandatory data fields against your current data collection capabilities. Identify missing fields, particularly for carbon footprint calculation, recycled content tracking, and supply chain due diligence. Quantify the effort required to close each gap.

Step 3: Platform Selection

Evaluate battery passport platforms based on interoperability with the EU Battery Database, support for the regulation's data schema, integration capabilities with your MES and BMS systems, and role-based access control features. Consider established platforms (Catena-X, Battery Pass) or custom solutions if your requirements are unique.

Step 4: Data Infrastructure Build

Implement data collection interfaces for each source system. Build validation logic aligned with the regulation's data schema. Establish data storage with lifecycle-appropriate retention. Configure role-based access control and API authentication.

Step 5: Carbon Footprint Calculation

Engage LCA consultants or internal sustainability teams to perform PEF-compliant carbon footprint calculations for each battery model. Establish data collection for raw material extraction, transportation, manufacturing energy, and end-of-life treatment. Document calculation boundaries and assumptions.

Step 6: Supply Chain Integration

Require suppliers to provide traceability data for raw materials (cobalt, lithium, nickel, graphite). Implement OECD Due Diligence Guidance-compliant processes. Establish supplier audit programs and maintain documentation for passport inclusion.

Step 7: QR Code Implementation

Select QR code technology appropriate for your battery's operating environment. Establish the marking process in your manufacturing line. Test code durability under real-world conditions. Verify that scanning correctly links to the correct passport record.

Step 8: Pilot and Validate

Run a complete passport generation cycle with a pilot battery batch. Verify data completeness, QR code functionality, platform integration, and access controls. Identify and resolve issues before full-scale deployment.

Step 9: Full Deployment

Roll out the battery passport system across all affected product lines. Train production, quality, and compliance staff on data entry and maintenance procedures. Establish ongoing monitoring and data quality assurance processes.

Step 10: Continuous Improvement

Monitor regulatory updates as delegated acts refine data requirements. Improve data quality and automation over time. Use passport data to identify supply chain optimization opportunities and support sustainability reporting beyond minimum compliance.

Use Our Battery Passport Generator

Our Battery Passport Generator helps you create a comprehensive battery passport with compliance scoring and missing field identification. Enter your battery specifications and the generator produces a structured passport document that maps directly to the EU Battery Regulation's data requirements.

What It Does

The generator evaluates your battery data against the regulation's mandatory fields, calculates a compliance readiness score, identifies missing fields, and produces a printable passport document with QR code placeholder.

Open Battery Passport Generator

Early Readiness

Use the generator now to assess your current data readiness. Identify gaps before they become compliance risks. The tool provides a structured starting point for your battery passport implementation project.

Start Assessment

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Frequently Asked Questions

What is the EU battery passport?

The EU battery passport is a digital record containing comprehensive data about a battery's lifecycle — from manufacturing and chemistry to carbon footprint, recycled content, and end-of-life instructions. It is accessed via a QR code or data matrix permanently attached to each battery, enabling transparent traceability across the entire value chain.

Which batteries require a battery passport under EU regulation?

From February 18, 2027, all industrial batteries with a capacity above 2 kWh, all EV batteries, and all stationary energy storage batteries placed on the EU market must carry a battery passport. LMT (light means of transport) batteries above 2 kWh will follow from February 18, 2028.

When does the battery passport requirement become mandatory?

The battery passport requirement under Regulation (EU) 2023/1542 becomes mandatory on February 18, 2027 for industrial batteries >2 kWh, EV batteries, and stationary storage batteries. LMT batteries >2 kWh follow on February 18, 2028. The regulation entered into force on August 17, 2023.

What data must be included in a battery passport?

A battery passport must include manufacturer identification, battery model and serial number, date of manufacture, chemistry type, rated capacity, energy rating, carbon footprint per kWh, percentage of recycled content, supply chain due diligence information, state of health, expected lifetime, safety classifications, and end-of-life handling instructions.

How is battery passport data accessed?

Each battery must carry a QR code or data matrix that links to the battery passport. The QR code must be permanently affixed, machine-readable, and accessible without specialized software. Different user roles (consumers, recyclers, regulators) receive different levels of data access depending on their needs.

Do consumer batteries require a battery passport?

Consumer batteries (portable batteries) are not required to have a battery passport under the current EU Battery Regulation. However, portable battery producers must register in the EU Battery Database and provide basic information. The passport requirement applies to industrial batteries >2 kWh, EV batteries, stationary storage batteries, and LMT batteries >2 kWh.

What happens if a company does not comply with battery passport requirements?

Non-compliant batteries cannot be placed on the EU market. Companies face potential market withdrawal, fines determined by individual member states, loss of access to the European market, and reputational damage. The regulation empowers national market surveillance authorities to enforce compliance.

How does the battery passport affect battery recycling?

The battery passport provides recyclers with critical information about battery chemistry, disassembly procedures, and hazardous material locations. This enables more efficient and safer recycling processes, improves material recovery rates, and supports circular economy objectives by facilitating second-life applications.

Is the battery passport the same as a battery label?

No. A battery label provides basic identification information (capacity, chemistry, manufacturer). A battery passport is a comprehensive digital record containing lifecycle data, carbon footprint calculations, supply chain information, and performance history. The label is physical; the passport is primarily digital, accessed via the QR code.

What is the EU Battery Database?

The EU Battery Database is a centralized digital repository established under the EU Battery Regulation. It stores battery passport data, manufacturer registrations, due diligence reports, and carbon footprint declarations. It enables authorities, producers, and authorized users to access and verify battery information across the European market.

How do I calculate the carbon footprint for my battery passport?

Carbon footprint calculation must follow the Product Environmental Footprint (PEF) methodology as specified in the EU Battery Regulation delegated acts. You need to account for raw material extraction, manufacturing processes, transportation, and end-of-life treatment. The European Commission will publish specific category rules (PEFCRs) for batteries.

What recycled content must be reported in the battery passport?

The battery passport must disclose the percentage of recycled cobalt, lithium, nickel, and lead in the battery. The EU Battery Regulation sets mandatory minimum recycled content thresholds: 16% cobalt, 6% lithium, 6% nickel, and 85% lead by February 2031, increasing to 26% cobalt, 12% lithium, 15% nickel, and 85% lead by February 2036.

Can I use a third-party platform for my battery passport?

Yes. Multiple battery passport platforms and consortia exist, including the Battery Pass initiative, Catena-X, and other interoperable solutions. The regulation requires that passport data be accessible through the EU Battery Database and that any platform used ensures data interoperability, security, and compliance with the regulation's data architecture requirements.

Do imported batteries require a battery passport?

Yes. Any battery placed on the EU market — whether manufactured within the EU or imported — must comply with the battery passport requirement. Importers and authorized representatives are responsible for ensuring that batteries they bring into the European market carry valid battery passports.

How does the battery passport support the circular economy?

The battery passport enables second-life assessment by providing state-of-health data, facilitates efficient recycling by disclosing chemistry and disassembly information, supports remanufacturing by tracking component history, and creates transparency that encourages responsible sourcing and sustainable manufacturing practices across the battery value chain.

Engineering Disclaimer: This article provides general information about EU battery passport requirements under Regulation (EU) 2023/1542. It does not constitute legal advice. The specific data requirements and compliance obligations may vary based on delegated acts that are still being finalized. Consult qualified legal counsel and regulatory specialists for advice specific to your organization and products. Data presented reflects regulation provisions as of the publication date and may be subject to change.