A Battery Passport can contain critical information about a battery's composition, performance, carbon footprint, supply chain and lifecycle. But a data point has limited value if an organisation cannot explain where it came from or demonstrate why it should be trusted.
For compliance teams, auditors and data owners, this creates a fundamental question:
“Can you prove the origin of the information published in your Battery Passport?”
This is the challenge of Battery Passport data provenance. Provenance provides the evidence and context needed to connect a published data point with its original source, responsible owner, validation process and supporting records.
As organisations prepare for the EU Battery Passport requirements, establishing this connection is becoming an important part of data governance and compliance readiness.
What is Battery Passport Data Provenance?
Data provenance describes the origin and history of a specific piece of information.
Consider a battery's recycled content. The final value displayed in the Battery Passport could depend on information received from material suppliers, production records, calculations and supporting documentation.
The published value is the result. Provenance explains its basis.
A useful provenance chain can be represented as:
Data Point → Source → Evidence → Validation → Approval → Published Value
This allows an organisation to work backwards from a Battery Passport value and establish how it was created and why it was accepted.
Data provenance is closely related to Battery Passport Data Lineage, but the two concepts have different emphases. Lineage focuses on how information moves between systems and processes, while provenance focuses more specifically on its origin, evidence and trustworthiness.
Why Does Data Provenance Matter?
Article 77 of Regulation (EU) 2023/1542 requires the economic operator placing the battery on the market to ensure that Battery Passport information is accurate, complete and up to date. The Regulation also establishes requirements concerning data authentication, reliability and integrity.
These requirements make the evidence behind a data point important.
Suppose an auditor selects a carbon footprint value from a Battery Passport. The organisation should be able to explain which data and methodology produced the value, identify the responsible data owner and locate the relevant supporting evidence.
The same principle applies to technical specifications, material composition, recycled content, performance information and other Passport attributes.
Without provenance, an organisation may know what was published without being able to demonstrate why it is correct.
What Evidence Supports Battery Passport Data?
The evidence required will depend on the data attribute.
Technical information could be supported by approved specifications, test results or laboratory records. Manufacturing information could be connected to production and quality records. Sustainability information may depend on LCA calculations, environmental datasets or supplier declarations.
For example:
Battery Passport Data | Possible Evidence |
Technical characteristics | Approved specification or test report |
Manufacturing information | Production record |
Material composition | BOM and supplier documentation |
Recycled content | Supplier evidence and calculation |
Carbon footprint | LCA model and supporting datasets |
Performance data | Test or operational records |
State of Health | BMS or diagnostic data |
The objective is not necessarily to expose all this evidence publicly. Battery Passport information has different access rights, and sensitive commercial or technical information may need to remain restricted.
The objective is to maintain an appropriate connection between the published information and the evidence that supports it.
Establish a Source for Every Important Data Point
Data provenance starts with knowing where information originates.
A single Battery Passport may draw information from engineering, manufacturing, procurement, quality, sustainability and operational systems. Some information may also come from external suppliers, laboratories or other organisations.
Each relevant data point should therefore have an identifiable source and owner.
For example:
Nominal capacity → Engineering specification → Engineering data owner
Carbon footprint → LCA calculation → Sustainability data owner
Recycled material content → Supplier documentation → Supply Chain data owner
This source-to-owner relationship makes accountability clearer and helps organisations identify gaps where important information has no clearly defined custodian.
The process can be supported by a framework that defines responsibilities for creating, maintaining, reviewing and approving information.
Record the Context Behind the Value
A source alone may not provide sufficient provenance.
Organisations should also consider the context surrounding the information. Depending on the data type, a provenance record could identify:
- the source system or organisation;
- the responsible data owner;
- the relevant battery, model, component or material identifier;
- the date the information was generated or updated;
- the source record or document version;
- the methodology used for calculations;
- validation or verification performed;
- the approval status; and
- the date and version of the published value.
This information creates a more complete evidence chain.
It also helps prevent a common problem: having a document that contains a value but no reliable way to establish whether that document relates to the specific battery or production period being reported.
Protect Provenance from Uncontrolled Changes
Provenance is only useful if the evidence and records supporting it remain trustworthy.
Organisations should therefore consider how changes to source information are controlled. When a value is updated, the system should retain sufficient information to understand what changed, when it changed and which version was used for the Passport.
This is particularly important when Battery Passport information evolves throughout a battery's lifecycle.
Performance, State of Health and usage information can change over time. Batteries can also undergo repair, reuse, repurposing or remanufacturing, potentially creating new information that needs to be connected with earlier records.
A Battery Passport Audit Trails and Evidence Management process can complement provenance by recording relevant changes and preserving the evidence needed to understand them.
Provenance Across the Battery Value Chain
Battery data rarely originates within a single organisation.
A manufacturer may rely on suppliers for material information. An importer may receive technical and sustainability information from a manufacturer. A recycler may subsequently generate information about recovered materials or end-of-life processing.
This creates a chain of data dependencies.
Organisations need to understand not only their immediate source, but also the provenance information available behind that source where necessary.
For example, if a supplier provides a recycled-content figure, the receiving organisation should be able to determine what the figure represents, which materials or components it covers, when it was established and what evidence supports it.
This does not mean every organisation needs direct access to every upstream dataset. Instead, the relevant evidence and provenance information should be available at the appropriate level and under appropriate access controls.
How Can Auditors Test Data Provenance?
A practical audit test is to start with the published Battery Passport and select individual data points.
The auditor can then ask the organisation to work backwards:
Published value → approved record → supporting evidence → source → responsible owner
A strong process should allow this journey to be completed consistently.
The auditor should also be able to determine whether the evidence relates to the correct battery or model, whether the source information was valid at the time of publication, whether appropriate validation took place and whether subsequent changes can be identified.
This approach tests the reliability of the data management process rather than simply checking whether the Passport contains the required fields.
Provenance and the Digital Product Passport Architecture
The European Commission's Digital Product Passport architecture reinforces the importance of managing detailed product information within the responsible economic operator's data environment.
The EU DPP Registry became operational in July 2026 and provides a central registration and indexing function. It does not serve as a repository for all detailed product information. Detailed data remains decentralised and under the responsibility of the relevant economic operator or service provider.
Consequently, organisations need their own mechanisms for managing source data, evidence, access and provenance.
The central Registry does not remove the need to understand where individual Battery Passport data points came from.
How BASE Supports Trusted Battery Data
The BASE project is developing and validating a Digital Battery Passport framework designed to support transparent, secure and interoperable data management across the battery value chain.
BASE places particular emphasis on traceability, data authenticity verification, interoperability and privacy by design. Its approach includes a DLT-based federated data space intended to help establish trust in information exchanged across different actors and lifecycle stages.
This is directly relevant to data provenance. When Battery Passport information comes from multiple systems and organisations, mechanisms for tracing information and establishing its authenticity can help create greater confidence in the resulting Passport.
BASE's work therefore contributes to the wider objective of making Battery Passport information more traceable, verifiable and trustworthy.
From Data Provenance to Data Trust
A trustworthy Battery Passport depends on more than having the right values in the right fields.
Organisations need to understand the origin of those values and maintain appropriate evidence showing how they were established.
For compliance teams, this creates a stronger basis for demonstrating regulatory readiness. For auditors, it provides a practical route for testing information. For data owners, it establishes clearer accountability for the information they manage.
As the February 2027 Battery Passport requirements approach, organisations should ask a simple question about their most important data points:
"If someone asks where this value came from, can we prove it?"
If the answer is yes, the organisation has a stronger foundation for trustworthy Battery Passport data.
The BASE project has received funding from the Horizon Europe Framework Programme (HORIZON) Research and Innovation Actions under grant agreement No. 101157200.
References & Resources
Regulation (EU) 2023/1542 - Batteries and Waste Batteries Regulation: https://eur-lex.europa.eu/eli/reg/2023/1542/oj
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 - Digital Product Passport for Batteries: https://single-market-economy.ec.europa.eu/single-market/digital-product-passport/batteries_en
European Commission - The DPP Registry Is Now Live: https://single-market-economy.ec.europa.eu/news/digital-product-passport-registry-now-live-2026-07-20_en
Regulation (EU) 2024/1781, the Ecodesign for Sustainable Products Regulation: https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng