As the European Union moves closer to full implementation of its new Battery Regulation (EU) 2023/1542, manufacturers and economic operators will need to develop robust safety documentation and hazardous materials reporting to meet regulatory requirements. A Digital Battery Passport (DBP) can support the battery industry in managing this complex challenge.
A Digital Battery Passport is a central component of the EU Battery Regulation (EUBR), playing a crucial role in how safety information and hazardous substance details are recorded, verified and shared across value chains. Effective preparation of this documentation not only supports compliance but also improves safety, transparency and circularity in battery supply chains.
In this article, we explain the regulatory context for safety documentation and hazardous materials reporting, why accurate data matters, and how Digital Battery Passports will help transform compliance practices. We also discuss how the BASE project contributes to this emerging ecosystem through its Digital Battery Passport framework.
Safety Documentation Under EU Battery Regulation
The Battery Regulation 2023/1542 replaces the former Batteries Directive with a directly applicable legal framework covering battery design, manufacture, use and end-of-life management. One of its core pillars is the requirement for manufacturers to prepare and retain comprehensive technical documentation, demonstrating conformity with essential safety, performance and materials requirements.
This documentation must include evidence that the battery has been designed and manufactured in accordance with applicable safety standards, that risks have been identified and mitigated, and that hazardous substances comply with regulatory limits. Manufacturers are required to retain this information for at least ten years after placing the battery on the EU market and to make it available to market surveillance authorities upon request.
The regulation also requires economic operators to maintain accurate records of material information, including hazardous substances that may affect human health or safety or recycling processes. EU law restricts the use of certain substances, such as mercury, cadmium and lead, to very low thresholds in battery components, and further reporting may be required for other hazardous chemicals identified under future delegated acts.
In addition to technical documentation, manufacturers must produce a EU declaration of conformity and a CE marking for each battery model to confirm adherence to applicable requirements before placing the product on the market. These elements form the core of safety and regulatory compliance.
Why Safety Documentation and Hazardous Materials Data Matter
Safety documentation and hazardous materials reports serve multiple purposes. At the most basic level, they provide evidence that a battery is safe to use under normal operating conditions and that risks from hazardous substances have been assessed and managed. Technical documentation describing design, manufacturing processes, test results and risk assessments supports confidence in compliance.
Hazardous materials reporting is equally important. Batteries contain a complex mix of metals, chemicals and compounds, some of which may pose dangers during use, handling, storage or recycling. Detailed information about the types and concentrations of hazardous substances is essential for safe transport, workplace safety, waste handling and recycling operations. It also supports the enforcement of EU restrictions on hazardous substances under the Batteries Regulation and related legislation such as the REACH Regulation.
From a lifecycle perspective, this information is particularly important for logistics providers, repair operators and recyclers. Without reliable data, these actors may need to assume worst-case scenarios, conduct additional testing, or limit processing options, all of which increase cost and risk. Structured hazardous materials reporting, therefore, supports both regulatory enforcement and operational efficiency.
Why Data Quality Matters Across the Battery Value Chain
High-quality safety documentation and hazardous materials data ensure trust in the battery market. For regulators, they provide a basis for effective market surveillance and enforcement. For manufacturers, they reduce compliance risk and support smoother product approvals. For downstream actors, they enable informed decision-making and safer working practices.
Poor data quality, on the other hand, can lead to delays, unnecessary efforts and increased safety risks. Inconsistent formats, missing substance identifiers or unverified supplier data can undermine confidence and complicate compliance checks. As regulatory scrutiny increases, the ability to demonstrate data accuracy and traceability is becoming as important as the data itself.
How Digital Battery Passports Help in Regulatory Compliance
The Digital Battery Passport is designed to address these challenges by acting as a structured digital repository for battery lifecycle information, such as materials, performance and safety data. When implemented properly, DBPs will include data on chemical composition, presence of hazardous substances, and link to safety documentation and conformity evidence that supports both regulatory compliance and safe handling practices.
The regulation requires that batteries above a certain capacity have a digital passport accessible via a QR code or similar digital identifier. By 2027, these passports must be operational for light means of transport (LMT), industrial batteries over 2 kWh and electric vehicle batteries. The passport will hold both public and non-public data, allowing authorised parties such as market surveillance authorities, recyclers and repurposing operators to access the required information.
Critically, the DBP links safety and hazardous materials data with other lifecycle information such as battery chemistry, manufacturer details, performance history and end-of-life status. This integrated dataset helps operators quickly understand a battery’s design and risks, avoiding unnecessary manual data gathering and reducing ambiguity.
Integrating Safety Documentation and Hazardous Materials Data
Safety documentation integrated into a Digital Battery Passport typically includes records of design assessments, hazard identification studies, results of testing and certification evidence. It may also refer to instructions for safe use, storage and disposal that must accompany every battery placed on the EU market, contributing to user and worker safety.
Hazardous materials reporting through a DBP involves detailed data on substances that exceed certain thresholds or are otherwise relevant to health, environmental or recycling considerations. Although EU legislation does not yet specify the full reporting format for all substances beyond those already restricted, guidance from industry experts suggests that substance names, hazard classes, concentration ranges and location within the battery should be recorded and made accessible.
In practice, linking this hazardous materials data with safety documentation via the DBP allows regulators, downstream partners and recyclers to make informed decisions. A recycler, for example, can assess risks associated with dismantling a particular battery type and plan appropriate protective measures before handling begins.
Practical Challenges in Preparing DBP Documentation
Collecting and organising the documentation and materials data required for DBPs presents challenges for many organisations. Siloed data systems, inconsistent reporting formats, and a lack of standardisation across suppliers can slow the process. Some actors also find it hard to verify third-party information on material composition and safety testing. These issues can affect the quality, completeness and accuracy of the documentation that ultimately goes into a DBP.
To meet these challenges, many companies are revising internal processes to ensure that data collection, verification and digital reporting align with regulatory expectations. This often involves cross-functional collaboration between design, compliance, quality assurance and supply chain teams to gather and consolidate required documents and material information.
How BASE Project Supports Safety Documentation and Hazardous Materials Reporting
The BASE Project is developing and validating a Digital Battery Passport framework that is designed to help economic operators manage safety documentation and hazardous materials data in a structured and compliant manner. BASE integrates detailed materials data, safety test results, conformity reports and risk assessments into a digital record that aligns with EU regulatory expectations.
BASE’s approach includes workflows that support data verification and standardised tagging of hazardous substances, making it easier for manufacturers and downstream actors to prepare and maintain accurate documentation. Our pilots demonstrate how structured DBPs can reduce the burden of manual reporting, improve data quality, and ensure that safety and materials information is reliable and traceable throughout the battery lifecycle.
By providing a unified platform for lifecycle data, BASE helps organisations navigate the complexities of documentation preparation, supports better compliance outcomes, and enhances safety across supply chains.
Looking Ahead
As the Battery Regulation moves from adoption to enforcement, the Digital Battery Passport will become a central reference point for safety and hazardous materials information. Organisations that invest early in robust data collection, documentation and digital integration will be better positioned to meet compliance deadlines and adapt to future delegated acts.
Beyond compliance, high-quality safety documentation and hazardous materials reporting support broader EU objectives on recycling, reuse and sustainable battery design. Digital Battery Passports, when implemented effectively, have the potential to improve safety, enhance transparency and contribute to a more circular and resilient battery ecosystem.
The BASE project has received funding from the Horizon Europe Framework Programme (HORIZON) Research and Innovation Actions under grant agreement No. 101157200
References:
EUR-Lex – Battery Regulation (EU) 2023/1542: https://eur-lex.europa.eu/eli/reg/2023/1542/2025-07-31/eng
BEPA – Batteries Regulation Brief Overview: https://bepassociation.eu/batteries-regulation-brief-overview/
European Commission – REACH Regulation: https://environment.ec.europa.eu/topics/chemicals/reach-regulation_en
BASE – Understanding the Scope of the Digital Battery Passport: EV, LMT, and Industrial Batteries: https://base-batterypassport.com/blog/technology-7/understanding-the-scope-of-the-digital-battery-passport-ev-lmt-and-industrial-batteries-60
BASE – EU Battery Passport Regulation (Regulation (EU) 2023/1542): What You Need to Know in 2026: https://base-batterypassport.com/blog/technology-7/understanding-the-scope-of-the-digital-battery-passport-ev-lmt-and-industrial-batteries-60