The Digital Battery Passport is moving rapidly from a regulatory concept to an operational requirement. From 18 February 2027, every light means of transport (LMT) battery, industrial battery with a capacity greater than 2 kWh, and electric vehicle (EV) battery placed on the EU market or put into service will need an electronic Battery Passport under Article 77 of the EU Batteries Regulation. The European Commission's Digital Product Passport infrastructure is also now becoming operational, with the DPP Registry launched on 20 July 2026.
For battery manufacturers and other organisations preparing for this transition, one question is becoming increasingly important: how do you choose the right Battery Passport platform?
Usually, the answer would be the platform that has the most features or one with the most intuitive interface. However, a Battery Passport is expected to stay relevant throughout a battery’s entire lifecycle, which can span up to 20-30 years, depending on the platform.
A battery passport also needs to connect information across a complex value chain involving manufacturers, suppliers, vehicle and equipment producers, service providers, repairers, second-life operators, recyclers, and public authorities.
That makes choosing the technology platform a strategic decision, and we need to go beyond just the features and usability.
The goal should not simply be to find a vendor that can help create a Battery Passport today. It should be to select an approach that supports compliance, interoperability and data exchange while preserving the ability to adapt, integrate and change direction as the regulatory and technological landscape develops.
In other words, the best Battery Passport platform is one that helps you move forward without making it difficult to move later.
Why Vendor Lock-in Matters for Battery Passports
Vendor lock-in occurs when an organisation becomes so dependent on a particular technology provider that changing platforms becomes technically difficult, financially expensive, or operationally disruptive.
In the context of Battery Passports, this could happen in several ways.
A company might store all of its passport data in a proprietary format that cannot easily be exported. It might depend on a vendor-specific API that makes integration with other systems difficult. It could build its processes around a platform's proprietary data model, meaning that migrating to another solution would require substantial redevelopment.
The problem becomes more significant when the battery passport needs to remain useful throughout the battery lifecycle.
A battery can move through multiple stages and organisations during its lifetime. Information generated during manufacturing may later need to support operation, maintenance, repair, repurposing, second-life applications and recycling. The EU Battery Regulation reflects this lifecycle perspective by requiring the Battery Passport to contain information about the battery model as well as information specific to the individual battery, including information resulting from its use.
So the platform selected at the beginning needs to support a data journey that could last for years. This is why vendor evaluation should focus as much on portability and interoperability as it does on functionality.
Start with the Data, Not the Dashboard
A polished dashboard can make a platform look impressive. However, the first question should be much more fundamental:
What happens to your data if you decide to leave?
Before choosing a Battery Passport platform, organisations should understand:
- Who owns the data?
- Where is the data stored?
- Can the complete dataset be exported?
- In what format can it be exported?
- Can historical records be migrated to another platform?
- Are APIs available for automated data access and transfer?
- Can the organisation continue accessing its data if the commercial relationship ends?
These questions are particularly important because the EU's DPP architecture is designed around decentralised data storage. The European Commission describes the DPP Registry as an indexing service that stores unique identifiers, registration data and high-level metadata rather than the full detailed product information contained in the DPP itself. The detailed data remains decentralised, which makes the relationship between a company and its technology provider an important consideration.
A platform should therefore be evaluated as a data management layer, not as the permanent owner of an organisation's information.
Look for Interoperability from Day One
Interoperability is one of the most important criteria when evaluating a Battery Passport platform.
Battery data does not originate from a single source. Information can come from enterprise resource planning systems, manufacturing execution systems, product lifecycle management tools, battery management systems, laboratory equipment, supplier databases, carbon accounting tools and other specialised applications.
A Battery Passport platform that operates as an isolated data silo may create another problem while solving the first one.
The European Commission's DPP framework places strong emphasis on interoperability. The Commission has developed a set of harmonised standards that support areas such as unique identifiers, interoperability, data carriers, APIs, data exchange protocols, and data storage. Six of the eight standards have already been published, with the remaining standards addressing authentication and access rights management.
For battery companies, this means interoperability should be assessed at several levels.
At the data level, can information be exchanged using structured and recognised formats?
At the system level, can the platform connect with existing business applications through APIs?
At the semantic level, does the solution use consistent definitions and data models so that information means the same thing when exchanged between organisations?
At the ecosystem level, can the platform participate in wider data-sharing environments rather than functioning only within one vendor's technology stack?
The right questions are therefore not simply, "Does this platform integrate with our ERP?" They should include, "Can this platform continue to exchange data when our ERP changes, when our supply chain expands, or when another technology provider becomes part of the ecosystem?"
Check Alignment with the EU Battery Passport Framework
A platform may be technically sophisticated and still be unsuitable for a company operating under EU Battery Passport requirements.
The starting point should be the legal framework.
Article 77 of Regulation (EU) 2023/1542 establishes the Battery Passport requirement from 18 February 2027 for each LMT battery, industrial battery above 2 kWh, and EV battery placed on the market or put into service. The Battery Passport must contain both battery model information and information specific to the individual battery.
The Regulation also establishes different levels of access to information. Some data is accessible to the general public, while other information is restricted to notified bodies, market surveillance authorities and the European Commission, or to parties with a legitimate interest for specific purposes such as dismantling, repair, remanufacturing, second-life applications and recycling.
A platform should therefore be assessed against the actual regulatory requirements rather than a generic checklist of DPP features.
Ask whether the solution can support:
- The required battery and product identifiers
- Individual battery records and model-level information
- Data access based on user roles and legitimate interests
- Lifecycle updates
- Data relevant to repair, reuse, repurposing and recycling
- Appropriate security and authentication
- Regulatory reporting and market surveillance requirements
- Future updates to technical specifications and implementing legislation
The European Commission itself continues to develop guidance through delegated acts and implementation support, meaning that flexibility should be treated as a core platform requirement.
Evaluate the Platform's Approach to Data Ownership
Data ownership should be explicitly addressed before signing a contract.
A battery passport platform may provide the infrastructure for collecting, managing and sharing information, but that does not necessarily mean the platform provider should control the underlying data.
A strong vendor evaluation should establish clear contractual and technical arrangements covering data ownership, access rights, data export, retention, backups and termination.
The organisation should be able to answer a straightforward question:
If we change our Battery Passport provider in five years, can we take our data with us?
If the answer is unclear, the platform presents a potential lock-in risk.
The same principle applies to the identifiers associated with Battery Passports. A company should understand how identifiers are created, managed and maintained, and whether these processes remain portable if the underlying software changes.
Examine the Commercial Model
Technology lock-in is not always caused by technical architecture. It can also emerge through commercial arrangements.
Before selecting a platform, organisations should understand the full cost of ownership.
This includes:
- Initial implementation
- Per-passport or per-product fees
- Data storage
- API usage
- Integration costs
- User licences
- Data exchange costs
- Support and maintenance
- Migration or exit costs
A pricing model that appears affordable during a pilot may become significantly more expensive when passport volumes increase.
For battery manufacturers, scalability is particularly important. A platform that works for a limited pilot involving a few thousand batteries may need to support millions of individual records as production expands.
The commercial model should therefore be tested against realistic future scenarios, not just today's requirements.
Test the Exit Strategy Before You Need it
One of the simplest ways to evaluate vendor lock-in is to ask the vendor to demonstrate how a customer would leave.
Request a practical explanation of:
- How data is exported
- Which formats are supported
- How identifiers are handled
- How relationships between records are preserved
- How data can be transferred to another provider
- How long the process takes
- What happens to historical passport records
Ideally, this should be tested during procurement or a pilot.
A platform that claims to be interoperable should be able to demonstrate interoperability in practice.
This is particularly important for Battery Passports because the regulatory environment is still evolving. The European Commission's DPP infrastructure is being implemented alongside ongoing work on standards, access rights and technical specifications. A platform that is flexible enough to accommodate these developments is likely to be more resilient than one built around a rigid, proprietary architecture.
Consider the Entire Battery Lifecycle
Choosing a Battery Passport platform should not be treated as a narrow compliance exercise.
The real value of the Battery Passport lies in connecting information across the battery lifecycle.
At the beginning of the chain, passport data may support traceability of materials, components and manufacturing processes. During the use phase, it can provide information relevant to battery performance and durability. Later, the same data can support maintenance, repair, repurposing, second-life applications and recycling.
The European Commission highlights the role of the Battery Passport in making relevant information more accessible to economic operators, consumers, repairers, recyclers and public authorities. The Battery Passport is therefore expected to support wider transparency and circularity across the battery value chain.
A platform that only addresses the initial compliance requirement may therefore provide limited long-term value.
When evaluating vendors, companies should ask how the solution will support the battery after it leaves the factory.
- Can a second-life operator access relevant information?
- Can a recycler obtain the data needed for safe dismantling?
- Can information be updated as the battery's condition changes?
- Can data be shared with authorised stakeholders without exposing commercially sensitive information?
These questions help distinguish a platform built for long-term lifecycle management from one designed primarily as a regulatory reporting tool.
Do Not Confuse Platform Features With Ecosystem Readiness
A Battery Passport platform can have excellent technical features and still struggle to operate within a broader ecosystem.
The Battery Passport is part of a wider digital environment involving manufacturers, suppliers, customers, service providers, regulators and circular economy actors. The platform therefore needs to work beyond the boundaries of one organisation.
The European Commission's DPP framework is explicitly designed around interoperability and common technical standards. Its DPP Registry also provides a central indexing function while detailed product information remains decentralised.
This makes ecosystem compatibility an important part of vendor evaluation.
Companies should consider whether a platform can connect with external data spaces, supply chain partners and other DPP implementations. They should also examine whether the provider actively participates in relevant standardisation and interoperability initiatives.
The more a solution depends on proprietary connections, the greater the risk that its usefulness will be limited to a closed ecosystem.
A Practical Vendor Evaluation Framework
A useful procurement process can begin with a simple scorecard. Rather than focusing on the number of features, companies can assess each potential platform across six areas:
Evaluation Area | Key Questions |
Regulatory Readiness | Does the platform support applicable EU Battery Passport requirements and adapt to regulatory updates? |
Data Ownership | Does the organisation retain control of its data and have unrestricted access to it? |
Interoperability | Can the platform exchange data through recognised standards and APIs? |
Lifecycle Capability | Can it support information from manufacturing through use, reuse and recycling? |
Security and Access | Can it manage authentication, permissions and role-based access appropriately? |
Portability | Can data and passport records be migrated to another system without unreasonable cost or disruption? |
The exact weighting will depend on the organisation. However, portability should not be treated as an optional feature.
The ability to change vendors is valuable even if a company may never need it. It creates negotiating power, reduces dependency and encourages providers to compete on service quality rather than making migration difficult.
BASE’s Approach to the Digital Battery Passport
The BASE project is working towards a functional Digital Battery Passport service designed to support a more transparent, secure and cost-efficient battery value chain. Its objective is to develop, validate and implement a working Digital Battery Passport that can strengthen traceability, sustainability, resilience and circularity across the battery lifecycle. The project also focuses on methodologies for battery performance and ESGE indicators, with traceability extending to the critical raw material level.
From the BASE perspective, the question of platform selection is closely connected to the wider challenge of building a trusted and interoperable Digital Battery Passport ecosystem. A successful Battery Passport environment needs to allow relevant data to move securely between value chain actors while supporting the regulatory, technical and circularity requirements that emerge throughout a battery's lifecycle.
The emphasis on interoperability, secure data management and lifecycle traceability within BASE reflects the importance of building Battery Passport solutions that can participate in a broader ecosystem rather than becoming isolated data silos.
Choosing a Platform that Leaves Your Options Open
The Battery Passport landscape is developing quickly. The EU's DPP Registry is now operational, harmonised standards are being introduced, and the mandatory Battery Passport deadline is approaching.
For organisations evaluating technology providers, the most important decision may therefore be less about choosing the platform with the longest feature list and more about choosing an architecture that preserves future options.
A strong Battery Passport platform should support compliance without restricting innovation. It should connect with existing systems without creating another silo. It should enable data sharing without giving up control of the underlying information. And it should make it possible to change direction if business needs, technology or regulations evolve.
The Battery Passport is intended to remain relevant across the battery lifecycle. The platform supporting it should be built with the same long-term perspective.
Ultimately, choose a solution that can work with your ecosystem today, adapt to tomorrow's requirements, and let you remain in control of your data throughout the journey.
The BASE project has received funding from the Horizon Europe Framework Programme (HORIZON) Research and Innovation Actions under grant agreement No. 101157200.
References
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 - The Digital Product Passport Registry Is Now Live: https://single-market-economy.ec.europa.eu/news/digital-product-passport-registry-now-live-2026-07-20_en
European Commission - Digital Product Passport: https://single-market-economy.ec.europa.eu/single-market/digital-product-passport_en?prefLang=pt
European Commission - DPP Harmonised Standards: https://single-market-economy.ec.europa.eu/single-market/goods/european-standards/harmonised-standards/digital-product-passport-dpp_en?prefLang=sv
Regulation (EU) 2023/1542, Article 77, Battery Passport: https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1771630714268&uri=CELEX%3A32023R1542
BASE Project - The EU Digital Product Passport Registry Goes Live: What it Means for the Battery Industry: https://base-batterypassport.com/blog/news-2/the-eu-digital-product-passport-registry-goes-live-what-it-means-for-the-battery-industry-122
BASE Project - Article 77 Explained: Building a Compliant Digital Battery Passport Data Model: https://base-batterypassport.com/blog/regulations-4/article-77-explained-building-a-compliant-digital-battery-passport-data-model-111