As the 18 February 2027 deadline for mandatory Digital Battery Passports approaches, battery manufacturers and other economic operators need to prepare for more than simply creating a digital record.
They also need to be able to demonstrate that the information in that record is accurate, complete, reliable and supported by appropriate evidence.
Under Regulation (EU) 2023/1542, each electric vehicle battery, light means of transport (LMT) battery and industrial battery with a capacity greater than 2 kWh placed on the EU market or put into service from 18 February 2027 must have a Battery Passport. The regulation also gives market surveillance authorities access to specific Battery Passport information, including test reports demonstrating compliance with the Batteries Regulation and relevant delegated or implementing acts.
This means Battery Passport readiness should be considered from two perspectives: Can the passport be accessed and checked, and can the organisation substantiate the information it contains?
What Do Market Surveillance Authorities Actually Check?
Market surveillance in the EU is based on a risk-oriented approach. Under Regulation (EU) 2019/1020, authorities can conduct documentary checks and, where appropriate, physical and laboratory checks. Their activities can be triggered by factors such as potential hazards, an operator's compliance history, consumer complaints or information indicating possible non-compliance.
For batteries, Regulation (EU) 2023/1542 provides a specific framework. Where an authority has sufficient reason to believe that a battery presents a risk to human health, safety, property or the environment, it can evaluate the battery against the relevant requirements of the regulation. If non-compliance is identified, the economic operator can be required to take corrective action, withdraw the battery from the market or recall it.
The Battery Passport therefore becomes an important part of the evidence environment surrounding a battery.
Authorities do not necessarily need every piece of information to be publicly accessible. The regulation establishes different access levels for Battery Passport information. Some information is available to the general public, while other information is restricted to notified bodies, market surveillance authorities and the European Commission. Additional information is available to parties with a legitimate interest under the conditions established by the regulation.
What Evidence Should Be Ready?
The starting point is the information that the Battery Passport itself is required to contain.
For market surveillance authorities, one particularly important category is evidence demonstrating compliance. Annex XIII specifies that Battery Passports must include test report results proving compliance with the requirements of the Batteries Regulation and applicable delegated or implementing acts. This information is specifically designated for access by notified bodies, market surveillance authorities and the Commission.
An audit-ready Battery Passport should therefore be supported by a clear evidence trail connecting the information in the passport with the underlying records.
Depending on the requirement being assessed, this may involve test reports, technical information, production records, performance data or other documentation demonstrating how a particular value or claim was established.
The important point is traceability. An organisation should be able to move from a Battery Passport data field to its source and, where relevant, to the evidence supporting that source.
Accuracy, Completeness And Currency Matter
Article 77 places responsibility on 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 allows the operator to authorise another operator to act on its behalf.
This creates an important distinction between having data and being able to trust that data.
For example, if a Battery Passport contains a performance value, an organisation should be able to identify where that value originated, when it was generated and whether it has subsequently been updated. If a battery changes status during its lifecycle, relevant information may also need to change accordingly.
Maintaining this level of traceability requires effective data governance, version control and clearly defined responsibilities for updating information.
The Battery Passport Needs To Be Accessible And Reliable
An authority cannot effectively verify a Battery Passport if the passport cannot be accessed or if its data cannot be trusted.
Article 78 establishes several technical and operational requirements. Battery Passport data must be stored by the responsible economic operator or an authorised operator acting on its behalf. The passport must remain available even if the responsible economic operator ceases to exist or stops operating in the EU. The regulation also requires data authentication, reliability and integrity, alongside appropriate security and privacy protections.
These requirements have practical implications for organisations selecting and operating Battery Passport systems.
A compliance team should be able to answer questions such as:
Where is the Battery Passport data stored? Who can modify it? How are changes recorded? Can historical information be traced? What happens if the service provider becomes unavailable?
These are not simply IT questions. They directly affect whether an organisation can demonstrate that its Battery Passport information remains reliable throughout the battery's lifecycle.
Access Controls Are Part Of Compliance
Not every Battery Passport user should have access to every piece of information.
The Batteries Regulation establishes different access rights depending on the type of information and the user. Market surveillance authorities and the Commission have access to specific regulatory information, including relevant test report results. Other information, such as detailed battery composition, dismantling information and safety measures, is subject to different access conditions.
A well-designed Battery Passport system should therefore provide controlled access rather than treating the passport as a single public information repository.
Role-based permissions, authentication and an appropriate audit trail can help organisations demonstrate that sensitive information is protected while authorised authorities and stakeholders can access the information they are entitled to see.
From Audit Request To Evidence Trail
A useful way to prepare is to imagine receiving a request from a market surveillance authority.
- Could your organisation quickly identify the relevant battery and its unique identifier?
- Could it provide the information that the authority is entitled to access?
- Could each important data point be traced back to its source?
- Could you demonstrate which version of the information was valid at a particular point in time?
- Could you provide the relevant test reports and supporting documentation? and
- Could you show that the information has been protected from unauthorised modification?
If answering these questions requires searching through disconnected spreadsheets, emails and departmental databases, the organisation may have a data governance problem rather than simply a Battery Passport problem.
An audit-ready approach means establishing these connections before an authority asks for them.
What Should Organisations Do Now?
The most effective preparation is to build evidence management into Battery Passport implementation from the beginning.
Start by mapping each required Battery Passport data attribute to its source system and responsible owner. Identify which information requires supporting evidence, where that evidence is stored and how long it needs to remain accessible.
Next, establish controls for updating and validating information. Changes should be attributable to authorised users, and organisations should be able to understand what changed and why.
Finally, test the process. Select representative batteries and attempt to reconstruct their evidence trail from the Battery Passport back to the underlying records. If the process is slow or relies heavily on manual investigation, it is a good indication that improvements are needed.
How BASE Can Help
The BASE project is working towards trusted and interoperable Digital Battery Passport solutions that can support information exchange across the battery value chain.
For market surveillance and compliance, interoperability alone is not enough. Battery Passport information also needs to be structured, traceable, secure and supported by reliable evidence. BASE's work on Battery Passport data attributes, standards and digital infrastructure contributes to this broader objective.
BASE's resources on the Battery Passport Data Attribute Longlist v1.3, DIN DKE SPEC 99100 and JTC 24 standards provide further context on how Battery Passport information can be structured and exchanged consistently. These developments are particularly relevant for organisations building systems that need to remain reliable as regulatory requirements and technical standards evolve.
Building An Audit-Ready Battery Passport
Market surveillance will ultimately focus on whether batteries placed on the EU market meet the applicable requirements. The Battery Passport provides an important digital layer for accessing and verifying relevant information, but its value depends on the quality and reliability of the underlying data.
For organisations preparing for 2027, the goal should therefore be more than creating a Battery Passport that can be opened through a QR code.
The real test is whether the organisation can prove where its information came from, demonstrate that it is accurate and up to date, protect it from unauthorised changes, and provide the appropriate evidence when requested.
Building those capabilities now can make future compliance checks considerably more manageable.
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 concerning batteries and waste batteries:https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1779247713965&uri=CELEX:32023R1542
- Regulation (EU) 2019/1020 on market surveillance and compliance of products: https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX:32019R1020
- Regulation (EU) 2024/1781 establishing a framework for the setting of ecodesign requirements for sustainable products: https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1772266756783&uri=CELEX:02024R1781-20240628
- BASE Project - Battery Passport Data Storage And Archiving Requirements: What Every Organisation Should Know: https://base-batterypassport.com/blog/blog-3/battery-passport-data-management-125
- 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