With 2027 on the horizon, the EU Battery Regulation is moving closer to full implementation. Many organisations are currently asking the same question: “Who is actually responsible for the Digital Battery Passport?”
The answer is not always straightforward.
A modern battery may involve multiple actors before reaching the European market. Cells may be manufactured in one country, assembled into battery packs in another, integrated into vehicles elsewhere, and imported into the European Union by a different organisation altogether. Throughout this process, data relating to sustainability, performance, carbon footprint, safety, traceability and lifecycle management must remain accurate and accessible.
Under Regulation (EU) 2023/1542, the Digital Battery Passport (DBP) is becoming a central component of battery compliance and transparency. However, responsibility for the passport does not sit with a single organisation throughout the battery lifecycle. Instead, obligations are distributed across several economic operators, each contributing different responsibilities at different stages.
Understanding these roles is essential for manufacturers, OEMs, battery pack assemblers, importers and authorised representatives preparing for Digital Battery Passport compliance.
Why Battery Passport Responsibility Matters
The Digital Battery Passport is one of the most significant requirements introduced under the Battery Regulation (EU) 2023/1542.
The passport is designed to provide transparent, accessible and reliable information about a battery's sustainability, performance, safety and lifecycle history. This information supports regulators, manufacturers, operators, recyclers and consumers throughout the battery's journey.
However, the value of a Battery Passport depends on the quality and accuracy of the underlying data. If responsibilities are unclear, data gaps can emerge, records may become inconsistent, and compliance risks can increase.
For this reason, organisations need to understand not only what information must be collected, but also who is responsible for ensuring it is available.
The EU Battery Regulation and the Concept of “Economic Operators”
The EU Battery Regulation follows a familiar European regulatory approach based on economic operators.
Instead of assigning all responsibilities to a single party, the regulation distributes obligations across different actors depending on their role within the supply chain.
These economic operators may include:
- Manufacturers
- Importers
- Distributors
- Authorised representatives
- Fulfilment service providers in certain circumstances
The specific responsibilities associated with the Battery Passport will depend on which entity places the battery on the EU market and which organisation controls the relevant lifecycle information.
This means responsibility should be viewed as a shared ecosystem rather than a single compliance obligation.
Who Creates the Digital Battery Passport?
For most batteries, the manufacturer carries the primary responsibility for compliance.
Manufacturers are typically responsible for generating the initial Battery Passport data, assigning a unique battery identifier and ensuring that required information is available when the battery is placed on the market.
This includes technical specifications, sustainability information, carbon footprint data, due diligence information, where applicable and other mandatory data elements required under the regulation.
For electric vehicle batteries, Original Equipment Manufacturers (OEMs) often play a critical role because they may integrate battery systems into larger products while maintaining responsibility for certain lifecycle information.
As a result, OEMs frequently become central participants in Battery Passport governance and data management.
The Role of Battery Pack Assemblers
Battery pack assemblers occupy a particularly interesting position within the Battery Passport ecosystem.
Many organisations purchase cells, modules or components from multiple suppliers and assemble them into final battery systems.
In these situations, the assembler may become responsible for creating a new battery identity and ensuring that relevant information from upstream suppliers remains connected to the finished product.
This creates important data governance challenges.
The assembler must ensure that information relating to materials, components, performance characteristics and compliance documentation remains traceable throughout the assembly process.
As battery systems become more sophisticated, maintaining these digital relationships will become increasingly important. For many industrial battery manufacturers, the assembler effectively becomes the organisation responsible for transforming component-level information into a coherent Digital Battery Passport structure.
What Happens When Batteries are Imported into the EU?
Importers have important responsibilities under the EU Battery Regulation.
When a battery is manufactured outside the European Union and placed on the EU market, the importer must verify that regulatory requirements have been fulfilled.
This includes ensuring that the battery complies with applicable requirements and that the necessary documentation is available.
Importers cannot assume that compliance obligations rest solely with overseas manufacturers.
If required Battery Passport information is missing, inaccurate or inaccessible, importers may face significant compliance risks when placing products on the European market.
For this reason, many importers are already strengthening their supply chain data management processes in preparation for future Digital Battery Passport obligations.
What is the Role of an Authorised Representative?
An authorised representative acts on behalf of a manufacturer in specific regulatory matters.
For the EU, this role is particularly important for manufacturers located outside the European Union.
The authorised representative can assist with regulatory documentation, communication with market surveillance authorities and compliance-related obligations specified within their mandate.
However, appointing an authorised representative does not automatically transfer all compliance responsibilities. Their precise responsibilities depend on the scope of authority granted and the requirements established under the regulation.
For this reason, manufacturers should carefully define responsibilities and ensure that all parties understand which obligations remain with the manufacturer and which activities may be performed by the authorised representative.
Who Maintains the Battery Passport After Market Placement?
One of the most misunderstood aspects of Digital Battery Passports concerns lifecycle management.
A Battery Passport is not a static document created once and then forgotten. Throughout a battery's operational life, new information may be generated through maintenance activities, software updates, state-of-health assessments, ownership transfers, repurposing projects and recycling processes.
This raises an important governance challenge.
While the original manufacturer may create the passport, other stakeholders may contribute information later in the lifecycle.
The most effective Battery Passport systems will therefore require clear governance frameworks that define who can access, update and validate specific categories of information.
Without these governance structures, lifecycle continuity may become difficult to maintain.
Shared Responsibility Will Define Successful Compliance
One of the biggest misconceptions surrounding Digital Battery Passports is the assumption that a single organisation owns the entire process.
In reality, successful implementation depends on collaboration across the value chain.
Manufacturers generate foundational data. Importers verify compliance. Assemblers connect component-level information. Service providers contribute operational records. Recyclers may eventually add end-of-life and material recovery information.
Each stakeholder contributes a piece of the battery's digital history.
The challenge is ensuring that these contributions remain connected through a consistent and interoperable Battery Passport framework.
How BASE Supports Battery Passport Governance
At BASE, we recognise that Digital Battery Passport implementation is not just a technical challenge. It is also a governance challenge that requires clear roles, responsibilities and data-sharing processes across the battery value chain.
The BASE Digital Battery Passport framework supports secure data exchange, lifecycle traceability and interoperability between stakeholders involved in battery manufacturing, operation, reuse and recycling.
We are exploring practical approaches to Battery Passport governance and data management, contributing to building systems that can support regulatory compliance while enabling long-term lifecycle transparency.
As Battery Passport obligations continue to evolve, establishing clear responsibility structures will remain essential for successful implementation.
Looking Ahead
The question of who is responsible for the Battery Passport cannot be answered with a single job title or organisation type.
Responsibility is distributed across multiple economic operators, each contributing different information and compliance functions throughout the battery lifecycle.
Manufacturers, OEMs, importers, assemblers and authorised representatives all play important roles in ensuring that Battery Passport information remains accurate, accessible and trustworthy.
Organisations that define these responsibilities early will be better prepared for future compliance requirements and better positioned to participate in Europe's emerging battery data ecosystem.
As Digital Battery Passports become an integral part of battery regulation, responsibility management may prove just as important as the technology itself.
The BASE project has received funding from the Horizon Europe Framework Programme (HORIZON) Research and Innovation Actions under grant agreement No. 101157200.
References
Regulation (EU) 2023/1542 Concerning Batteries and Waste Batteries:
https://eur-lex.europa.eu/eli/reg/2023/1542/oj
Consolidated Text of Regulation (EU) 2023/1542:
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_en
European Commission: Questions and Answers on Sustainable Batteries Regulation:
https://ec.europa.eu/commission/presscorner/detail/en/qanda_20_2311
European Commission: Circular economy of batteries:
BASE Project: https://base-batterypassport.com/