Bing Xu, senior director of Catena-X, presented a session called “Battery Passport Updates” at AIAG’s 2025 Responsible Materials Conference. In case you missed it, here’s his overview.
Let’s take a look at regulation updates, what a Battery Passport must include, the risk of non-compliance, and the ecosystem, standards, and solutions.
Battery Passport Regulation Updates
Regulation (EU) 2023/1542 is now in effect and already has been in the implementation phase. Replacing the old 2006 Battery Directive, this regulation directly applies across the EU (no need for national implementation) and governs the full battery lifecycle — from raw material extraction to recycling. It covers electric vehicles, industrial, portable, and light means of transport batteries.
Looking back on another notable milestone, CE (European Conformity) marking and conformity assessments became mandatory starting August 18, 2024. As for the future, Battery Passport becomes mandatory in February 2027 for all EV, LMT, and industrial batteries with a capacity of over 2 kWh.
What is a Battery Passport?
A Battery Passport must include eight key elements: material origin and sourcing data, carbon footprint data, recycled and renewable content, end-of-life performance history, materials and composition, removability/replaceability, QR-code-enabled access, and due diligence and human rights compliance.
The material origin and sourcing data are needed for lithium, cobalt, nickel, and graphite (country of origin, supplier traceability). 3TGs are not key compositions in batteries. Thus, 3TGs were not a direct requirement, but were included in conflict minerals requirements.
Carbon footprint data have been required since February 2025 for newly produced EV batteries. IMDS implemented PCF reporting, primary data is not mandatory, and secondary PCF is OK now.
As for recycled and renewable content, IMDS has asked for recycled contents already.
End-of-life performance history (for reuse and second-life applications) is also needed, i.e., disposal routes, end-user participation in collection, and information on take-back and collection points.
Materials and composition include substances of concern, which IMDS already collected.
Regarding removability/replaceability, many OEMs/battery suppliers provided this data already.
When it comes to QR-code-enabled access, each battery must have a QR code that links to a cloud-hosted data repository accessible by authorized parties across the value chain (OEMs, recyclers, regulators, etc.).
Lastly, due diligence and human rights compliance are based on Omnibus IV. Original August 2025 implementation timing was delayed to August 2027. OEMs and suppliers must implement and report on human rights and environmental, social, and governance due diligence measures. Third-party supply chain audits may become necessary for compliance, especially in high-risk regions.
Risk of Non-Compliance
Non-compliance may result in prohibition from selling batteries or EVs in the EU, hefty fines under market surveillance enforcement, loss of competitive edge due to reduced transparency or delays in data readiness, and negative public image and reputation damage.
Ecosystem, Standards, and Solutions
Catena-X and Battery Pass Consortium are actively defining technical standards for data exchange in battery passports, promoting interoperability across brands and tiers. The Global Battery Alliance is also contributing with frameworks aligned to OECD Due Diligence Guidance.
Catena-X and OPC Foundation join forces for the Digital Product Passport for meeting 2027 requirements. Also, platforms like Circularise and Catena-X certified solutions developed by Siemens, Denso, etc., are creating battery passport-ready ecosystems for automotive deployment.
No single OEM/industry can do the job due to the secondary and tertiary lives involved and the complexity of more than 100 data sets required, while Catena-X provides a better tool to transfer and integrate all the data sets needed. There are Catena-X certified solutions developed for support.
The best ways to fulfill compliance requirements are supporting each other in a collaborative manner and integrating these various existing tools/databases.
SAVE THE DATE FOR AIAG’S 2026 RESPONSIBLE MATERIALS CONFERENCE
AIAG’s 2026 Responsible Materials Conference will be held on August 26, 2026, at the AIAG offices and virtually. Registration is now open.