The EU Battery Regulation is transforming how battery information is collected, managed and shared across the value chain. At the centre of this transformation is Article 77, which introduces the Digital Battery Passport (DBP) as a mandatory requirement for LMT batteries, industrial batteries with a capacity greater than 2 kWh and electric vehicle batteries placed on the European market.
While most of the attention has focused on compliance deadlines and technical implementation, many organisations face a more fundamental challenge: how should a Battery Passport data model actually be structured?
Building a Digital Battery Passport is not simply a matter of collecting documents and uploading them to a database. Organisations must create a scalable data architecture capable of supporting lifecycle traceability, interoperability, regulatory reporting and future circular economy requirements.
As the industry moves towards implementation, companies that establish robust data models early will be better positioned to manage compliance, support business operations and unlock new value from battery lifecycle information.
What is Article 77 of The EU Battery Regulation?
Article 77 of Regulation (EU) 2023/1542 requires that specific categories of batteries placed on the EU market be accompanied by a Digital Battery Passport (DBP) containing information relevant to sustainability, performance, durability, safety, and circularity.
The regulation requires that battery information be accessible through a unique identifier and stored in a structured electronic record.
Importantly, Article 77 is not simply about storing data. It is about ensuring that information remains available, interoperable and usable throughout the battery's lifecycle.
This means companies must think carefully about how information is organised, connected and updated over time.
Why Data Models Matter More Than Databases
Many organisations initially focus on selecting software platforms or storage technologies. However, the most important decision often comes much earlier.
A data model defines how information is structured and how different data elements relate to one another. If the underlying model is not properly designed, even the most sophisticated platform will struggle to deliver reliable traceability.
A strong Battery Passport data model should support information throughout manufacturing, operation, maintenance, repurposing, reuse and recycling.
It should also be flexible enough to accommodate future delegated acts, evolving standards and new regulatory requirements.
Start With the Battery's Digital Identity
Every Battery Passport begins with a unique battery identity.
This digital identity acts as the foundation that connects all subsequent lifecycle information. It should remain persistent throughout the battery's existence, regardless of ownership changes, geographic movement or second-life applications.
The passport identifier should link to information such as:
- Battery model
- Manufacturer details
- Production date
- Manufacturing location
- Serial number
- Battery chemistry
Instead of treating these as isolated records, they should form the core entity around which all future data is organised.
Create Separate Data Layers for Different Lifecycle Stages
One of the most common mistakes in Battery Passport design is placing all information into a single flat structure.
A more scalable approach is to organise information into lifecycle layers.
Manufacturing data may include material composition, carbon footprint information and conformity assessments.
Operational data may contain usage history, charging patterns and performance metrics.
Maintenance records can document repairs, software updates and component replacements.
End-of-life data may capture dismantling instructions, recycling information and material recovery outcomes.
Separating these layers improves maintainability and supports future interoperability.
Design for State-of-Health and Performance Tracking
Article 77 is closely connected to battery durability and performance transparency.
For this reason, the data model should include structures capable of recording evolving battery performance indicators throughout the lifecycle.
This may include state-of-health measurements, capacity retention data, cycle counts, energy throughput and operational efficiency metrics.
Rather than storing only the latest value, organisations should preserve historical records that enable trend analysis and predictive modelling.
This approach supports second-life decision-making and future circular economy applications.
Ensure Traceability at the Material Level
One of the key objectives of the EU Battery Regulation is to improve supply chain transparency.
A modern Battery Passport data model should support traceability down to the material and component level where required.
This includes information relating to critical raw materials, recycled content and sourcing documentation.
With the regulatory requirements evolving, material-level traceability is expected to become increasingly important for sustainability reporting and due diligence processes.
Build Interoperability into the Architecture
A Battery Passport will not exist in isolation.
Manufacturers, vehicle producers, logistics providers, service centres, second-life operators and recyclers may all need access to relevant information.
The data model needs to support standardised data exchange formats and machine-readable structures.
The European Commission has repeatedly emphasised interoperability as a key requirement for future Digital Product Passport ecosystems.
Organisations that design for interoperability from the beginning will face fewer integration challenges as the regulatory landscape matures.
Plan for Data Governance and Access Control
Not every stakeholder should have access to every piece of information.
Some data may be publicly accessible, while other information may be commercially sensitive or restricted to regulators and authorised parties.
A well-designed Battery Passport data model should include governance rules that define:
- Who can access information?
- What information can be modified?
- Which records must remain immutable?
- How are data updates validated?
These governance structures become increasingly important as battery ecosystems become more connected and data sharing expands.
Prepare for Digital Twin Integration
Many organisations are beginning to connect Digital Battery Passports with battery digital twins.
This creates opportunities for predictive maintenance, performance forecasting and lifecycle optimisation. To support this future, data models should be capable of handling both static and dynamic information.
Static data may include manufacturing specifications and compliance records, while dynamic data may include operational metrics, sensor readings and real-time performance indicators.
The ability to combine these datasets creates a stronger foundation for advanced analytics and AI-driven battery management.
How BASE is Supporting Battery Passport Data Architecture
At BASE, we understand that effective Digital Battery Passports depend on more than compliance reporting. They require robust, interoperable and scalable data foundations.
Our Digital Battery Passport framework is designed to support lifecycle traceability, circular economy objectives and secure data exchange across the battery value chain.
We are developing methodologies for structured battery data management, interoperability and digital identity. BASE is contributing to building practical Battery Passport architectures that can support future regulatory and industry requirements through industry collaboration and pilot programs.
Looking Ahead
Article 77 of Regulation (EU) 2023/1542 represents one of the most significant digitalisation requirements ever introduced for the battery industry.
Compliance will require more than document management systems or isolated databases. Organisations must create structured data models capable of supporting transparency, traceability and lifecycle intelligence over many years.
Organisations that start building these foundations today will be better prepared for future regulatory developments and better positioned to capture value from the growing battery data economy.
As Battery Passports evolve from compliance tools into strategic digital assets, the quality of the underlying data model may become one of the most important factors determining long-term success.
The BASE project has received funding from the Horizon Europe Framework Programme (HORIZON) Research and Innovation Actions under grant agreement No. 101157200.
References
EU Battery Regulation (Regulation EU 2023/1542): https://eur-lex.europa.eu/eli/reg/2023/1542/oj
European Commission – Batteries: https://environment.ec.europa.eu/topics/waste-and-recycling/batteries-and-accumulators_en
European Commission – European Data Strategy: https://ec.europa.eu/commission/presscorner/api/files/attachment/862109/European_data_strategy_en.pdf
BASE – What is a Digital Battery Passport? A Closer Look Inside: https://base-batterypassport.com/blog/sustainability-6/what-is-a-digital-battery-passport-a-closer-look-inside-23
European Commission – EU's Digital Product Passport: https://data.europa.eu/en/news-events/news/eus-digital-product-passport-advancing-transparency-and-sustainability