This is part of our series recapping sessions from the 2024 Hybrid IMDS, Product Compliance & Sustainability Conference.
Do you have a general understanding of the European Union Battery Regulation and Passport and what data needs to be collected to meet their requirements? The 2024 Hybrid IMDS, Product Compliance & Sustainability Conference session “EU Battery Regulation/Passport” addressed this timely topic.
Here are highlights from virtual presenter Ellen Carey, Chief External Affairs Officer for Circulor, a United Kingdom-based global supply chain traceability company.
EU Battery Regulation
“Over the next five years, the operating environment will become more complex, requiring increasingly stringent proof of sustainable, responsible, and circular sourcing,” Carey said. That is in part due to the passage of the EU Battery Regulation, EU Ecodesign for Sustainable Product Regulation, and the U.S. Clean Vehicle Tax Credit.
The EU Battery Regulation requires a Battery Passport and transparent battery supply chains, increasing accountability of downstream participants for responsible, sustainable, and circular sourcing. Data is accessible to different actors with financial and reputational risks if the industry cannot comply.
“The regulation sets an important global precedent for responsibility and transparency of battery production,” Carey said. To comply and access the European marketplace, businesses across the battery value chain must implement traceability.
EU Battery Regulation Compliance Deadlines
Increasingly stringent threshold requirements and continuous monitoring requirements will be rolled out over the next decade.
In 2025 alone, companies will have to meet a minimum recycling efficiency of 65% for lithium-based batteries by December; declare carbon footprint with third-party verification by September; and have an ongoing system of controls and transparency in place, including a traceability system.
“Efforts on both battery passports and Digital Product Passports are expected to join forces in requiring digital passports for entire vehicles by 2031,” Carey said.
EU Battery Passport Specifics
The EU Battery Passport has seven categories and 104 data attributes along the entire value chain. The categories are general battery and manufacturer information; compliance, label, and certifications; battery carbon footprint; supply chain due diligence; battery materials and composition; circularity and resource efficiency; and performance and durability.
Battery passport data shall be stored by the economic operator or by the operator authorized to act on their behalf.
The data must be accessible if the economic operator ceases to exist or ceases activity in the Union. It also must be accessible through a QR code linked to a unique identifier with different access rights for the different stakeholders.
Data on provenance, due diligence, responsible sourcing, recycled content, and carbon emissions must be verifiable. The market surveillance authorities in each member state will verify compliance.
Plus, battery passport data must be fully interoperable with other digital product passports required by the EU ESPR. New battery passports must be linked to the battery passport or passports of the original battery.
Recommended Resources
Carey highlighted the following helpful websites for more information:
- Content and technical guidance from the Battery Pass project — https://thebatterypass.eu
- Kumi’s latest writeup on due diligence for EUBR — https://kumi.consulting
REGISTER FOR THE 2025 IMDS CONFERENCE
This topic and more will be covered at the 2025 Hybrid IMDS, Product Compliance & Sustainability Conference October 8–10, 2025, at Suburban Collection Showplace in Novi, Michigan. Registration is now open, so don’t miss the early registration discount.
