Preparing for the Digital Battery Passport often starts with the wrong question:
What new data do we need to create?
A better starting point is:
What information do we already have, where is it stored, who owns it, and can it be connected and trusted?
From 18 February 2027, every electric vehicle battery, every LMT battery and every industrial battery with a capacity greater than 2 kWh placed on the EU market or put into service will require a Battery Passport under Regulation (EU) 2023/1542. The economic operator placing the battery on the market is responsible for ensuring that its Battery Passport information is accurate, complete and up to date.
The European Commission's updated August 2026 guidance brings together 71 Battery Passport data points, indicating which data points apply to different battery categories and whether they are mandatory, optional, or applicable only in specific circumstances from February 2027.
For organisations preparing for implementation, this means that having a list of regulatory requirements is only the beginning. The next challenge is mapping those requirements to existing business systems, data owners and operational processes.
Start With the Requirements, Not the IT Systems
Before deciding which systems need to be connected, organisations should first establish which Battery Passport requirements apply to their particular battery category and role in the value chain.
For each applicable data point, it is useful to identify:
- What information is required?
- Where does it currently exist?
- Who owns or manages it?
- In what format is it stored?
- Does it apply to a battery model, batch or individual battery?
- How frequently does it change?
- Who should be able to access it?
- What evidence demonstrates that it is accurate?
This creates a Battery Passport data-requirement map.
More importantly, it can reveal that an organisation does not necessarily need to create large amounts of new information. In many cases, the required data already exists, but is distributed across different departments, systems or supply chain partners.
BASE's Battery Passport Data Attribute Longlist v1.3 provides a useful starting point for understanding the range of attributes that organisations may need to consider.
Look Across the Business
Battery Passport information rarely comes from a single database.
Engineering, production, procurement, sustainability, quality, service and battery-management teams may all hold pieces of the battery's digital record. Existing systems can therefore become important sources for Battery Passport information.
Existing Business Source | Potential Battery Passport Information |
PLM and engineering systems | Battery design, chemistry, components and technical specifications |
Bills of Materials | Materials, component hierarchy, part numbers, quantities and mass |
ERP and supplier systems | Suppliers, sourcing information, manufacturing locations and organisational data |
MES and production systems | Manufacturing date, batch information and as-built configuration |
Quality and laboratory systems | Test results, conformity information, safety data and performance evidence |
LCA and sustainability tools | Carbon footprint, recycled-content and circularity information |
Battery Management Systems | State of health, capacity, power, resistance, charging cycles and operating conditions |
Service and repair systems | Repairs, replacements, accidents and changes in battery status |
Document repositories | Declarations of conformity, instructions, dismantling information and supporting reports |
The mapping exercise is not only for locating the required data. Organisations also need to understand how this data will reach the Battery Passport, how it will be validated, and how it will remain current throughout the battery’s lifecycle.
A BOM is a Source, Not the Battery Passport
A Bill of Materials (BOM) can be an important source of Battery Passport information. It may contain component structures, materials, part numbers, quantities and mass data relevant to composition, repair, dismantling or lifecycle assessment.
However, a complete BOM should not automatically be treated as Battery Passport content.
BOMs can contain commercially sensitive information and intellectual property, including product architecture, material combinations, supplier relationships and manufacturing knowledge. Different BOMs may also describe different stages of a product's lifecycle, such as as-designed, as-built or as-maintained configurations.
Which means the practical question is not “Can we upload the BOM?” but rather:
“Which BOM fields are required, how should they be mapped and validated, and what information should remain protected?”
A sensible approach is to extract only the information needed for the applicable Battery Passport requirements, while preserving the original source, version and appropriate access restrictions.
Connect BOM and LCA Data, But Keep Their Roles Distinct
The BOM describes what a battery contains. A Life Cycle Assessment (LCA) interprets the environmental impacts associated with those materials, components and processes.
These systems can therefore work together without becoming the same system:
BOM data → Mapping and validation → LCA calculation → Selected LCA results → Battery Passport
This connection requires organisations to establish how materials and components are matched with LCA datasets, how supplier-specific and estimated data are distinguished, how uncertainty is handled and whether the BOM and LCA relate to the same product version.
The BOM should remain an authoritative engineering source. The LCA system should perform the relevant environmental calculations, while the Battery Passport provides controlled access to the information required for the applicable regulatory and lifecycle purposes.
Distinguish Between Static and Changing Data
Not all Battery Passport information changes at the same rate.
Some information is relatively stable, such as the manufacturer, battery model, chemistry or original manufacturing information. Other information evolves during the battery's use and subsequent lifecycle stages.
Article 77 specifically provides for individual-battery information relating to areas such as performance and durability, state of health, battery status and data resulting from use, including charging and discharging cycles and certain operating conditions.
Each relevant data point should therefore have an update rule.
The organisation should know what event triggers an update, which system provides the new information and who is responsible for ensuring its accuracy.
Without this structure, a Battery Passport can be correct when first created but become outdated as the battery changes.
Build Access Rights into the Data Map
Battery Passport information is not intended to be equally accessible to everyone.
The Batteries Regulation establishes different access levels, including information available to the general public, information accessible to notified bodies, market surveillance authorities and the Commission, and information available to persons with a legitimate interest for defined purposes.
Access considerations should therefore form part of the data-mapping exercise from the beginning.
For example, an organisation may need to make a particular environmental indicator publicly available while keeping the underlying supplier information or detailed engineering data restricted.
Where possible, access rules should be considered at data-field level rather than treating the entire Battery Passport as either public or confidential.
Test the Mapping With One Real Use Case
Organisations do not need to connect every system at once.
A focused pilot using one battery model or representative dataset can test whether the proposed approach works in practice.
A pilot could identify the applicable data points, map each one to its source and owner, transfer selected information into the Battery Passport, connect relevant material data to an LCA process, and test what happens when a source record changes.
The objective is not simply to demonstrate that data can be uploaded.
It is to establish that the right information can move from its authoritative source to the Battery Passport, remain traceable and be updated when the underlying battery information changes.
This can also expose data-quality issues, unclear ownership, integration gaps and inappropriate access permissions before the approach is scaled across a wider product portfolio.
What Good Data Mapping Looks Like
A successful mapping exercise should allow an organisation to answer five questions for every relevant Battery Passport data point:
- Where does the information come from?
- Who is responsible for it?
- How do we know it is correct?
- When and how is it updated?
- Who is allowed to access it?
If these questions cannot be answered, the problem may not yet be a Battery Passport technology issue. It may indicate a gap in data governance, business processes or organisational readiness.
This is why mapping existing data should happen before selecting or configuring a Battery Passport platform.
How BASE Can Help
The BASE project is working towards a trusted, interoperable Digital Battery Passport ecosystem that connects battery information across the value chain while supporting secure data exchange, traceability and regulatory requirements.
This makes the relationship between existing business systems and the Battery Passport particularly important. Organisations should not have to rebuild every existing data system simply to meet Battery Passport requirements. Instead, relevant information needs to be identified, structured, validated and connected in a way that supports interoperability across the battery lifecycle.
BASE's work explores these practical challenges through its Digital Battery Passport framework and platform. The project is also developing resources to help organisations understand the data and standards underpinning implementation.
For example, DIN DKE SPEC 99100 Explained: The Technical Standard Behind Battery Passport Data Fields provides background on structuring Battery Passport information, while JTC 24 Standards Explained For Battery Passport Teams: What They Mean In Practice explores the wider standardisation and interoperability landscape.
BASE's approach is aligned with the broader requirement in Article 77 that Battery Passport information be based on open standards, interoperable, machine-readable and transferable through an open interoperable data exchange network without vendor lock-in.
From Existing Data to a Connected Battery Passport
The path towards Battery Passport readiness does not necessarily begin with buying new software or creating new databases.
It begins with understanding the information an organisation already has.
By mapping regulatory requirements to existing systems, identifying data owners, protecting sensitive information and establishing how data will be updated, organisations can build a clearer and more efficient route towards Battery Passport implementation.
The objective is to create a reliable bridge between existing business data and the information required throughout the battery lifecycle.
For manufacturers, OEMs and other economic operators preparing for 2027, starting that mapping exercise now can make the transition to a functioning Digital Battery Passport 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
European Union - Regulation (EU) 2023/1542: https://eur-lex.europa.eu/eli/reg/2023/1542/2025-07-31/eng
European Commission - Digital Product Passport for Batteries: https://single-market-economy.ec.europa.eu/single-market/digital-product-passport/batteries_en
European Commission - Guidance to support preparations for the Digital Batteries Passport: https://single-market-economy.ec.europa.eu/news/guidance-support-preparations-digital-batteries-passport-2026-08-21_en
BASE - Article 77 Explained: Building A Compliant Digital Battery Passport Data Model: https://base-batterypassport.com/blog/regulations-4/article-77-explained-building-a-compliant-digital-battery-passport-data-model-111
BASE - How To Implement A Digital Battery Passport: A Step-By-Step Guide: https://base-batterypassport.com/blog/regulations-4/how-to-implement-a-digital-battery-passport-132