The Digital Battery Passport is moving from a future regulatory requirement to an implementation task for organisations across the battery value chain.
From 18 February 2027, every electric vehicle (EV) 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 must have a Battery Passport under Regulation (EU) 2023/1542. The European Commission's Digital Product Passport Registry is already operational, providing the infrastructure for registering Digital Product Passports ahead of the 2027 deadline.
For battery manufacturers, OEMs, compliance teams and IT departments, the challenge is deciding where to start.
Implementing a Digital Battery Passport is not simply a matter of purchasing a software platform and uploading information. Organisations need to understand their regulatory obligations, identify the required data, connect existing systems, establish governance and eventually deploy a passport that can remain accurate throughout the battery's lifecycle.
A practical implementation can be approached through the following steps.
Step 1: Understand Your Regulatory Scope
Before collecting data or selecting technology, establish which batteries and activities fall within the Battery Passport requirements.
Article 77 of Regulation (EU) 2023/1542 establishes the Battery Passport requirement for LMT batteries, industrial batteries above 2 kWh and electric vehicle batteries from 18 February 2027. The Passport must contain information relating to both the battery model and the individual battery, including information resulting from its use.
This distinction is important because implementation is not limited to information available when a battery leaves the factory. Some information will develop during the battery's lifecycle.
The first task should therefore be to map your battery portfolio and identify which products, markets and business processes are within scope.
Step 2: Map The Required Battery Passport Data
Once the scope is clear, organisations need to determine what information they must collect and where it currently exists.
The Battery Passport covers a broad range of information, including battery identification and technical characteristics, manufacturer and economic operator information, performance and durability, sustainability and circularity information, and information supporting repair, reuse and recycling.
The European Commission has also published guidance on Battery Passport data points by category, providing a useful starting point for understanding the information landscape.
BASE's Battery Passport Data Attribute Longlist v1.3: Which Fields Matter Now And Why can provide additional context when reviewing which data attributes need to be considered and how they relate to current implementation priorities.
The objective at this stage is to create a clear data inventory:
What data is required? Where does it come from? Who owns it? How often does it change? Who needs access to it?
Without these answers, technology selection can easily happen before the organisation understands the problem it is trying to solve.
Step 3: Identify Your Existing Data Sources
Battery information is rarely stored in one system.
Manufacturing data may sit in an ERP or Manufacturing Execution System. Engineering information may be maintained in a Product Lifecycle Management system. Laboratory systems may contain test results, while Battery Management Systems can generate information during the battery's use.
Supplier information may come from entirely different organisations and systems.
The next step is therefore to map these systems and identify how information currently moves between them.
This exercise can reveal duplicated records, missing information, inconsistent identifiers and manual processes that could create problems later.
A Battery Passport platform should sit within this wider data environment rather than becoming another isolated database.
Step 4: Establish Data Ownership And Governance
Good Battery Passport implementation requires clear responsibility for the information being published.
For each important data attribute, organisations should identify an owner responsible for its accuracy and maintenance. They should also establish who can create, approve, modify and access information.
This becomes particularly important because the Batteries Regulation requires Battery Passport information to remain accurate, complete and up to date.
Governance should cover areas such as:
- Data ownership and accountability
- Validation and approval
- Access permissions
- Version control
- Audit trails
- Data retention
- Supplier data management
- Handling of corrections and updates
These processes should be agreed before deployment rather than added after the system is already in production.
Step 5: Design The Integration Architecture
The Battery Passport should be able to exchange information with the systems that already support your business.
This makes APIs and interoperable data formats important considerations. Instead of manually copying information between systems, organisations should aim to automate data flows wherever practical.
For example, when a battery's manufacturing identifier is created in an internal system, the information should be capable of flowing into the relevant Battery Passport process without unnecessary manual re-entry.
The same principle applies to lifecycle information received from other actors.
BASE's DIN DKE SPEC 99100 Explained: The Technical Standard Behind Battery Passport Data Fields and JTC 24 Standards Explained For Battery Passport Teams: What They Mean In Practice provide useful background for organisations considering how Battery Passport information can be structured and exchanged consistently.
Step 6: Choose The Right Battery Passport Technology
Only after understanding your data, processes and integration requirements should you evaluate technology platforms.
The right solution will depend on the organisation, but important considerations include interoperability, scalability, security, access control, data governance, API capabilities and the ability to adapt to evolving regulatory requirements.
The platform should also support the decentralised nature of the wider DPP architecture. The EU DPP Registry acts as an indexing service, while detailed product information remains under the responsibility of the relevant economic operator or its service provider.
Organisations should also consider how easily data can be exported or transferred. Battery Passport implementation is a long-term commitment, so avoiding unnecessary vendor lock-in should form part of the technology evaluation.
For a more detailed approach to platform selection, see BASE's How To Choose a Battery Passport Platform Without Vendor Lock-In.
Step 7: Connect The Battery To Its Digital Passport
The Digital Battery Passport needs to be connected to the physical battery through an appropriate data carrier.
Under the Batteries Regulation, the relevant batteries must carry a QR code providing access to the Battery Passport from 18 February 2027. The data carrier needs to remain visible, legible and durable.
This means organisations need to consider the physical implementation alongside the digital one.
The identifier printed or engraved on the battery needs to correspond reliably with the digital record. Production processes should therefore be tested to ensure that identifiers are generated, assigned and associated with the correct battery without introducing errors.
Step 8: Test The Complete Data And Evidence Chain
Before deployment, organisations should test the entire process rather than testing the Passport interface alone.
Select representative batteries and follow their information from the original source systems through to the final Digital Battery Passport.
Ask the following questions:
- Can we trace each important data field to its source?
- Can we identify who provided or approved the information?
- Can we update information without losing the necessary history?
- Can authorised stakeholders access the information they need?
- Can the Passport be accessed through its data carrier?
- Can supporting evidence be retrieved when required?
Testing these scenarios can expose integration, data quality and governance problems before the system reaches production.
BASE's work on auditability, data structures and interoperability is particularly relevant here. An effective Battery Passport needs to remain reliable as information moves between systems and across different stages of the battery lifecycle.
Step 9: Deploy In Stages And Monitor Performance
A phased deployment can make implementation more manageable, particularly for organisations with complex product portfolios or supply chains.
Rather than attempting to connect every system and battery model simultaneously, organisations can begin with a representative product line or business process. Lessons from the initial deployment can then inform wider implementation.
Once deployed, the Passport should be treated as a living information system. Data quality, system availability, integration performance and access controls should be monitored continuously.
The objective is to ensure that the Passport remains accurate and accessible throughout the battery's lifecycle.
How BASE Can Help
Implementing a Digital Battery Passport requires organisations to bring together regulatory requirements, data management, interoperability and lifecycle traceability. The BASE project is addressing these challenges by developing and validating a trusted and interoperable Digital Battery Passport framework designed for practical use across the battery value chain.
BASE's approach goes beyond creating a digital record for regulatory reporting. The project is exploring how Battery Passport information can be structured, exchanged and maintained throughout a battery's lifecycle, from manufacturing and use through maintenance, second-life applications and end-of-life. This includes work on digital identity, structured data management, secure data exchange, traceability and interoperability.
For organisations preparing for regulatory compliance, this provides a useful connection between the requirements of the EU Battery Regulation and the practical systems needed to implement them. BASE is also examining how Battery Passport data can support wider objectives such as circularity, sustainability assessment, ESGE indicators, battery performance and safety, helping organisations consider the longer-term value of their data infrastructure.
The project is validating its approach through real-world pilots across different battery applications, including automotive, marine and stationary energy storage. These pilots are being used to test areas such as secure access to federated DBP infrastructure, automated identification, interoperable data sharing, battery performance indicators and lifecycle information.
BASE is also producing practical resources to help organisations understand the technical foundations of Battery Passport implementation. Its work on the Battery Passport Data Attribute Longlist v1.3, DIN DKE SPEC 99100 and CEN-CENELEC JTC 24 standards helps connect regulatory requirements with the data structures and interoperability principles needed for implementation.
For businesses beginning their DBP implementation journey, the key takeaway is that regulatory compliance depends on more than having a Battery Passport interface. Organisations need reliable data, clear ownership, interoperable systems and processes that can maintain information throughout the battery lifecycle. These are precisely the areas where BASE's research and demonstrations can provide practical insight.
From Data Collection To Deployment
Implementing a Digital Battery Passport is best approached as a structured transformation programme rather than a single IT project.
The journey starts with understanding regulatory scope and mapping required information. It then moves through data ownership, system integration, technology selection, physical identification, testing and deployment.
For manufacturers, OEMs, compliance teams and IT departments, starting early provides an opportunity to identify data gaps and integration challenges while there is still time to address them.
The organisations best prepared for 2027 will be those that have already connected their people, processes, data and technology into a coherent Battery Passport implementation strategy.
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 on batteries and waste batteries: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023R1542
European Commission - Digital Product Passport for Batteries (Battery Passport): https://single-market-economy.ec.europa.eu/single-market/digital-product-passport/batteries_en
European Commission - The DPP Registry: https://single-market-economy.ec.europa.eu/single-market/digital-product-passport/dpp-registry_en
European Commission - Digital Product Passport Registry Is Now Live: https://single-market-economy.ec.europa.eu/news/digital-product-passport-registry-now-live-2026-07-20_en
European Commission - Digital Product Passport Guidance and Data Points: 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 - The EU Digital Product Passport: Implications and Practical Guidance for the Battery Industry: https://single-market-economy.ec.europa.eu/events/digital-product-passport-batteries-2026-05-27_en