As the Battery Passport becomes a mandatory requirement across the European Union, organisations are naturally focusing on collecting the right information. However, an equally important question is often overlooked: how should Battery Passport data be stored, maintained and archived throughout a battery's lifecycle?
Under Regulation (EU) 2023/1542, Battery Passports are designed to provide trusted information that supports traceability, sustainability, repair, repurposing and recycling. The value of a passport therefore depends not only on the quality of its data but also on whether that information remains accessible, accurate and secure over time. With the EU's Digital Product Passport (DPP) Registry now operational, manufacturers and other economic operators should also consider how their data management strategies align with the wider DPP ecosystem. (EUR-Lex,European Commission)
The DPP Registry Does Not Store Your Battery Passport
One common misunderstanding is that the European Commission's DPP Registry stores the complete Battery Passport.
In reality, the Registry acts as a central indexing service. It stores the unique identifier and registration information required to locate a Digital Product Passport, while the detailed battery data remains under the responsibility of the economic operator or its authorised service provider. This decentralised architecture allows organisations to maintain control over their information while supporting secure data discovery across the EU. (European Commission)
This means organisations need a reliable strategy for storing, maintaining and protecting Battery Passport data long after the passport has been created.
Plan for the Entire Battery Lifecycle
A Battery Passport is not a static document. Information may evolve throughout manufacturing, distribution, operation, maintenance, repurposing and end-of-life processing.
The EU Battery Regulation requires both model-level information and, where applicable, information specific to the individual battery. As batteries move through different lifecycle stages, new data may need to be added while previous records remain available for traceability and regulatory purposes. (EUR-Lex)
Organisations should therefore design storage systems that preserve historical records alongside the latest updates. This helps maintain an auditable history of the battery without losing important lifecycle information.
Build a Robust Backup and Recovery Strategy
Battery Passport data may support regulatory compliance, customer information, product servicing and recycling activities. Losing that information due to hardware failure, cyber incidents or accidental deletion could create operational and compliance risks.
A robust backup strategy should therefore be considered an essential part of Battery Passport management.
Rather than relying on a single storage location, organisations should implement resilient backup processes with routine testing to verify that information can be recovered when needed. Backup schedules, retention policies and recovery procedures should align with the organisation's wider information governance framework and cybersecurity practices.
Since Battery Passport data may remain relevant for many years, backup strategies should also consider long-term preservation rather than only short-term disaster recovery.
Prepare for Data Handover Across the Value Chain
Battery Passports are intended to support information sharing across multiple stakeholders.
Throughout a battery's lifecycle, authorised users may include manufacturers, vehicle producers, repairers, second-life operators, recyclers, market surveillance authorities and other parties with legitimate access rights under the Regulation. (EUR-Lex)
For this reason, organisations should think beyond internal storage.
Data should be managed in a way that enables secure handover between authorised parties while preserving integrity, version history and access controls. Standardised data models, interoperable interfaces and clearly defined governance processes can significantly reduce the complexity of these transitions.
Planning for data handover from the outset also helps avoid situations where important information becomes inaccessible when responsibilities change, or service providers are replaced.
Retention Should Support Compliance and Circularity
Battery Passport information supports much more than regulatory reporting.
Manufacturers may rely on historical data to investigate quality issues, while repairers and second-life operators may need access to service histories or battery characteristics. Recyclers can benefit from information about battery composition and dismantling requirements to improve material recovery and safe processing.
For this reason, organisations should establish retention policies that reflect both regulatory obligations and the practical value of lifecycle information. A clear data governance policy helps ensure that records remain available for authorised users while preventing unnecessary duplication or inconsistent versions across different systems.
How BASE Supports Trusted Battery Data Management
As the Battery Passport ecosystem continues to develop, the BASE project is helping demonstrate how trusted, interoperable Digital Battery Passports can support secure information exchange across the battery value chain.
By developing and validating Digital Battery Passport solutions, BASE is contributing to approaches that strengthen traceability, interoperability and lifecycle data management. These capabilities will become increasingly important as organisations prepare for mandatory Battery Passports and the growing demand for transparent battery information across manufacturing, use, repair and recycling.
Looking Ahead
Creating a Battery Passport is only the beginning. The information behind that passport must remain accurate, available and accessible throughout the battery's lifecycle.
Organisations that establish clear strategies for data storage, retention, backups and secure handover will be better prepared for future regulatory requirements while supporting more efficient collaboration across the battery value chain. As Digital Product Passports become an integral part of Europe's circular economy, good data management will be just as important as collecting the data itself.
The BASE project has received funding from the Horizon Europe Framework Programme (HORIZON) Research and Innovation Actions under grant agreement No. 101157200.
References
Regulation (EU) 2023/1542 Concerning Batteries and Waste Batteries (EUR-Lex): https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1771630714268&uri=CELEX%3A32023R1542
European Commission - Digital Product Passport for Batteries: https://single-market-economy.ec.europa.eu/single-market/digital-product-passport/batteries_en
European Commission - The DPP Registry: https://single-market-economy.ec.europa.eu/single-market/digital-product-passport/dpp-registry_en
European Commission - Digital Product Passport: https://single-market-economy.ec.europa.eu/single-market/digital-product-passport_en?prefLang=pt
BASE Project: https://base-batterypassport.com/about