For many small and medium-sized enterprises (SMEs), the Digital Battery Passport (DBP) can sound like a major IT project involving dozens of data fields, supplier information, QR codes and lifecycle updates.
The practical starting point is simpler: understand whether your company is responsible for a Battery Passport and, if so, which information you actually need to provide.
From 18 February 2027, Battery Passports will become mandatory for electric vehicle (EV) batteries, light means of transport (LMT) batteries and industrial batteries with a capacity over 2 kWh that are placed on the EU market or put into service. The responsibility for creating and maintaining the Battery Passport lies with the economic operator placing the finished battery on the market, rather than every supplier of materials, components or modules.
For SMEs, preparation does not necessarily mean replacing existing systems or collecting every possible data point. It means establishing a clear route from applicable requirements to the data, people and systems needed to fulfil them.
A Practical SME Readiness Check
If you are an SME preparing for Battery Passport requirements, start with eight questions:
- Are any of our batteries covered, and are we the responsible economic operator?
- Which Battery Passport data requirements apply to our products?
- Who inside our company will lead the preparation?
- Where does the required information already exist?
- Which information must come from suppliers?
- How will we create, register and maintain the Passport?
- How will we protect confidential and commercially sensitive information?
- Can we test the complete process with one product before scaling?
Answering these questions in sequence can turn a broad compliance exercise into a manageable implementation process.
1. Confirm Your Product And Role
Being part of the battery value chain does not automatically mean that your company must create a Battery Passport.
Start by asking whether you manufacture, import, put into service or place a finished covered battery on the EU market under your own name or trademark. If you only supply materials, cells, components, software or services, you may not be responsible for creating the Passport. Still, you may need to provide reliable information to the organisation that is.
Your company size alone does not determine the obligation. The battery category and your legal role in the value chain matter more.
A useful first step is therefore to select one representative product and establish exactly where your organisation sits in its value chain.
2. Identify The Applicable Requirements
The European Commission's updated Battery Passport guidance brings together 71 data points relevant to the covered battery categories. It indicates whether individual data points are mandatory, optional, applicable only in specific circumstances, or not required to be completed or displayed as of February 2027.
This means SMEs should not assume that every potential data field needs to be collected immediately.
Create a simple requirements list showing:
- which requirements apply to your battery;
- which are mandatory from February 2027;
- which are conditional or will apply later; and
- which information requires public or restricted access.
BASE's Battery Passport Data Attribute Longlist v1.3 article can also help teams understand the wider landscape of Battery Passport attributes, although the European Commission's regulatory guidance should remain the reference point for legal applicability.
3. Assign Responsibility
Battery Passport preparation can cross engineering, production, procurement, sustainability, quality, IT and service functions.
Even in a small company, someone needs to coordinate these contributions. Nominate an internal owner who can maintain the requirements list, identify data owners, follow up on gaps, coordinate suppliers and technical providers, and help ensure that information remains accurate and up to date.
This is fundamentally a data governance issue as well as a compliance task.
As explored in Battery Passport Data Governance, organisations need clear ownership of information, including responsibility for maintaining and approving data.
Technology can support this process, but it cannot replace clear internal responsibility.
4. Map The Data You Already Have
Much of the required information may already exist across your organisation.
Engineering specifications and Bills of Materials may contain technical information. ERP and procurement systems may contain supplier and sourcing records. Production and quality systems can hold manufacturing and testing information, while lifecycle assessment tools may contain environmental data. Service records and battery-management systems can provide information generated during the battery's use.
For every applicable data point, record its source, owner, format, quality and update frequency.
A spreadsheet can be sufficient for this first exercise. The objective is to understand the existing data landscape before deciding what needs to be automated.
This is also the focus of How To Map Existing Business Data To Battery Passport Requirements. The key questions are straightforward: where does the information come from, who owns it, how is it validated, when is it updated, and who can access it?
5. Close Supplier Data Gaps
SMEs often depend on suppliers for material composition, component information, sustainability indicators or performance data.
Rather than asking suppliers for "all Battery Passport information", define the specific information required. Clarify the component or material concerned, the required value and unit, the expected format, whether supporting evidence is needed, how frequently the information should be updated and whether it can be shared publicly or only through restricted access.
Supplier agreements may also need to address data quality, confidentiality, permitted use and responsibility for updates.
The goal is to create a reliable data flow between suppliers and the organisation responsible for the Battery Passport.
6. Choose A Practical Technical Route
The Battery Passport is linked to the battery through a data carrier such as a QR code and a unique identifier. The wider DPP system uses a decentralised approach, with detailed product information maintained by the responsible economic operator or a relevant service provider, while the EU DPP Registry provides an indexing and registration function.
An SME does not necessarily need to build its own platform. Depending on its circumstances, it may use an external Battery Passport provider, an existing product-data system, a customer or sector platform, or a combination of internal systems and an external interface.
Before selecting a solution, however, check whether it supports the required data, access rights, version history, lifecycle updates and data transfer if the technical provider changes.
The technical solution should fit the company's existing data environment rather than creating another isolated information system.
7. Protect Sensitive Information
Battery Passport transparency does not mean publishing a company's complete underlying records.
Bills of Materials, supplier lists, manufacturing data and other business information may contain intellectual property, trade secrets, product architecture or commercially sensitive information. SMEs should therefore identify what must be disclosed and what can remain within the original internal systems.
Depending on the applicable requirement, information may need to be selectively extracted, aggregated, made available only to authorised users or retained as supporting evidence without being publicly displayed.
The European Commission confirms that Battery Passport information is accessed according to applicable user roles and that detailed battery information remains decentralised.
The practical principle is simple: provide the information required for the Battery Passport while maintaining appropriate control over information that is not intended for unrestricted access.
8. Test One Product And One Complete Data Flow
Before scaling across a product portfolio, test the process with one battery model or representative dataset.
Confirm that your organisation can identify the applicable requirements, locate and validate the necessary information, collect missing supplier data, transfer it to the Passport solution, apply appropriate access rights, connect it to the correct battery identifier and update the information when the product or battery status changes.
This pilot can reveal the real implementation gaps: missing data, inconsistent formats, unclear ownership, confidentiality restrictions or systems that cannot communicate effectively.
BASE has previously explored the value of Battery Passport Test Environments for SMEs, highlighting how controlled testing can help organisations identify data, interoperability and compliance issues before moving to a live implementation.
Start Small, But Start Clearly
An SME does not need to transform every system, collect every potential data point, upload complete engineering files or automate everything immediately.
It does need a clear scope, an accountable person, an applicable data list, reliable sources and a tested process.
The European Commission's current guidance is designed to help organisations identify which data points apply to their battery category and begin aligning their internal processes and systems ahead of implementation.
The practical path towards Battery Passport readiness is therefore to understand your role, identify the requirements that actually apply, map the data you already have, close the necessary gaps and test the complete flow before scaling.
How BASE Supports Practical Battery Passport Implementation
The BASE project is working towards a trusted and interoperable Digital Battery Passport ecosystem that connects battery information across the value chain while supporting secure data exchange, traceability and regulatory requirements.
For SMEs, this approach is particularly relevant because Battery Passport implementation needs to work with existing business systems and data sources rather than requiring every organisation to start from scratch. BASE's work addresses the practical challenges of connecting, validating and exchanging battery information while supporting data authenticity, interoperability and secure access.
This aligns with the broader BASE approach of building a Digital Battery Passport framework that can support organisations as they move from existing business data towards a connected, reliable and lifecycle-oriented Passport.
From Uncertainty To Battery Passport Readiness
Battery Passport preparation can seem complicated when viewed as one large technology project.
For an SME, a more practical approach is to break it down into manageable decisions: Do we have an obligation? What information applies? Where does that information already exist? Who owns it? What is missing? How will it be shared securely? Can we test the process before scaling?
Answering those questions provides a clearer starting point for compliance and helps ensure that investment in technology follows a well-understood data and business requirement.
The objective is not to build the most complicated system possible. It is to establish a reliable, secure and maintainable process for providing the Battery Passport information required for the products your organisation places on the market.
The BASE project has received funding from the Horizon Europe Framework Programme (HORIZON) Research and Innovation Actions under grant agreement No. 101157200.
References & Resources
European Union - Regulation (EU) 2023/1542: https://eur-lex.europa.eu/eli/reg/2023/1542/oj
European Commission - Digital Batteries Passport – data points by category: https://single-market-economy.ec.europa.eu/document/download/cd1e5e6c-4a4a-4b99-995a-49eb6916187e_en?filename=Digital+Batteries+Passport+-+data+point+by+category.pdf
European Commission - Digital Product Passport for Batteries: https://single-market-economy.ec.europa.eu/single-market/digital-product-passport/batteries_en
European Commission - Guidance To Support Preparations For The Digital Batteries Passport: https://single-market-economy.ec.europa.eu/news/guidance-support-preparations-digital-batteries-passport-2026-08-21_en
European Commission - EU Digital Product Passport FAQ for Batteries: https://single-market-economy.ec.europa.eu/single-market/digital-product-passport/eu-digital-product-passport-faq-batteries_en
European Commission - DPP Registry: https://single-market-economy.ec.europa.eu/single-market/digital-product-passport/dpp-registry_en
European Commission - The Digital Product Passport (DPP) for Economic Operators: https://single-market-economy.ec.europa.eu/single-market/digital-product-passport/economic-operators_en