Digital Battery Passports (DBPs) are designed to improve transparency across the battery value chain. They help manufacturers, regulators, recyclers, businesses and consumers access reliable information about a battery's origin, sustainability, performance and lifecycle.
However, transparency does not mean that every piece of information should be publicly available.
Battery manufacturers invest heavily in research, production methods and supply chain optimisation. Many of these details represent valuable intellectual property (IP) and commercially sensitive information. At the same time, regulators, recyclers and consumers need enough information to make informed decisions and verify compliance with the EU Battery Regulation.
Finding the right balance between openness and confidentiality is therefore one of the biggest challenges facing Digital Battery Passport implementation.
Rather than asking whether Battery Passport data should be public, organisations should ask a more practical question: which information should be public, which should be restricted and who should have access to each category of data?
Why Data Governance Matters
A Digital Battery Passport is far more than a digital document. It is a structured collection of information that evolves throughout a battery's lifecycle.
As batteries move from manufacturers to vehicle producers, distributors, fleet operators, second-life applications and recycling facilities, different stakeholders require access to different types of information.
Consumers may want to understand the battery's sustainability credentials before purchasing a vehicle.
Service centres need maintenance and diagnostic records.
Recyclers require material composition and dismantling guidance.
Market surveillance authorities need evidence that the battery complies with applicable legislation.
Trying to satisfy every stakeholder with a single level of access would either expose confidential business information or limit the usefulness of the Battery Passport.
This is why data governance plays such a central role in Digital Battery Passport design.
What Information Should Be Public?
The EU Battery Regulation promotes transparency, particularly for information that helps support sustainability, circularity and informed purchasing decisions.
Although detailed technical specifications continue to evolve through delegated acts and standards, publicly accessible Battery Passport information is expected to focus on data that benefits users without exposing commercially sensitive information.
Examples include the battery's unique identifier, manufacturer details, battery category, manufacturing date, applicable conformity information and selected sustainability indicators such as the carbon footprint declaration where required.
Public access may also include general information that helps consumers and downstream operators understand the battery's intended use, expected lifetime and responsible end-of-life management.
Making this information readily available improves trust while supporting the objectives of the circular economy.
Reference:
https://eur-lex.europa.eu/eli/reg/2023/1542/oj
What Information Should Remain Confidential?
Not every data field belongs in the public domain.
Battery manufacturers often possess information that provides a competitive advantage. Detailed cell chemistry formulations, manufacturing processes, supplier relationships, quality control procedures and proprietary performance models may all represent valuable intellectual property.
Similarly, commercially sensitive operational data generated throughout the battery lifecycle may reveal business strategies or customer information.
Protecting this data is essential for encouraging innovation while maintaining fair competition.
The EU Battery Regulation recognises this balance by supporting transparency without requiring disclosure of trade secrets or confidential business information beyond what is necessary to achieve regulatory objectives.
Reference:
https://eur-lex.europa.eu/eli/reg/2023/1542/oj
Different Stakeholders Need Different Levels Of Access
A successful Digital Battery Passport should not operate as an "all or nothing" information system.
Instead, access should be based on legitimate business or regulatory needs.
A consumer purchasing an electric vehicle needs very different information from a recycler dismantling the battery several years later.
Likewise, a market surveillance authority may require access to compliance documentation that would not be relevant to the general public.
Modern Battery Passport systems therefore rely on role-based access control.
Rather than publishing every data field openly, organisations can provide different levels of access depending on the user's identity and responsibilities.
This approach improves security while ensuring that stakeholders receive the information they genuinely need.
Protecting Intellectual Property Without Reducing Trust
Some manufacturers worry that increased transparency could expose years of research and development to competitors.
Fortunately, Digital Battery Passports are not intended to reveal proprietary manufacturing knowledge.
Instead, they focus on providing trustworthy evidence that regulatory requirements have been met.
For example, a Battery Passport may confirm that recycled material targets or carbon footprint reporting obligations have been satisfied without disclosing confidential production methods used to achieve those outcomes.
This distinction allows transparency and innovation to coexist.
Companies remain able to protect intellectual property while demonstrating regulatory compliance and sustainability performance.
Secure Data Sharing Is Essential
Balancing transparency with confidentiality depends not only on policy but also on technology.
Battery Passport platforms should include secure authentication, authorisation and encryption mechanisms that ensure information is accessed only by authorised users.
Comprehensive audit logs can record when data is viewed, updated or shared, creating additional confidence for both regulators and industry participants.
These technical safeguards help establish trust across the battery value chain while reducing the risk of unauthorised access.
As Digital Product Passport initiatives continue to evolve, secure and interoperable data exchange will remain a key design principle.
Reference:
Why Governance Will Become Increasingly Important
The volume of Battery Passport data is expected to grow significantly over time.
Future passports may include more detailed lifecycle information, predictive maintenance records, state-of-health assessments, second-life history and recycling outcomes.
As more information becomes available, organisations will need clear governance policies defining who owns the data, who can update it and who can access specific categories.
Without these governance frameworks, transparency may become inconsistent and confidentiality more difficult to maintain.
Organisations that establish clear data governance strategies today will be better prepared as Digital Battery Passport ecosystems continue to mature.
How BASE Supports Trusted Battery Data Governance
At BASE, we recognise that successful Digital Battery Passports depend not only on collecting accurate information but also on managing it responsibly.
Our work explores Digital Battery Passport frameworks that support secure data exchange, interoperability and lifecycle traceability while respecting legitimate confidentiality requirements across the battery value chain.
By promoting practical approaches to digital identity, access management and structured data governance, BASE contributes to Battery Passport ecosystems that balance transparency with commercial protection.
This balanced approach helps organisations build trust while protecting valuable intellectual property and supporting long-term regulatory compliance.
Looking Ahead
Transparency is one of the defining principles of the Digital Battery Passport, but effective transparency requires thoughtful governance.
Some information should be openly accessible because it supports informed purchasing decisions, sustainability and regulatory confidence.
Other information should remain protected because it represents intellectual property or commercially sensitive business knowledge.
The organisations that succeed in implementing Digital Battery Passports will be those that understand the difference.
By combining structured data governance, secure access controls and interoperable digital systems, they can create Battery Passports that are transparent where necessary, confidential where appropriate and trusted by every stakeholder.
The BASE project has received funding from the Horizon Europe Framework Programme (HORIZON) Research and Innovation Actions under grant agreement No. 101157200.
References
EU Battery Regulation (Regulation (EU) 2023/1542): https://eur-lex.europa.eu/eli/reg/2023/1542/oj
EU Battery Regulation Consolidated Text: https://eur-lex.europa.eu/eli/reg/2023/1542/2023-07-28/eng
European Commission – Batteries: https://environment.ec.europa.eu/topics/waste-and-recycling/batteries-and-accumulators_en
European Commission – Sustainable product policy & ecodesign: https://single-market-economy.ec.europa.eu/industry/sustainability/sustainable-product-policy-ecodesign_en
European Data Protection Board (EDPB): https://www.edpb.europa.eu/
European Union Agency for Cybersecurity (ENISA): https://www.enisa.europa.eu/
World Intellectual Property Organisation (WIPO) – Intellectual Property Resources: https://www.wipo.int/