A Digital Battery Passport is not a static record created once and left unchanged. Battery information can evolve as data is corrected, new measurements become available, ownership or responsibility changes, and the battery moves through different stages of its lifecycle.
That makes data versioning, controlled updates and lifecycle management essential parts of a reliable Battery Passport architecture.
In our previous article, we explored what organisations can expect when a battery passport’s data is found to be incorrect, and how they can resolve it. The next question is what happens when that value changes.
For IT teams, compliance professionals and data owners, the challenge is to update the current information without losing the history, context and evidence behind previous versions.
Why Does Battery Passport Data Change?
Battery Passport information can change for several reasons.
Some changes occur because new information becomes available. A battery's State of Health, performance indicators or other operational information may evolve as the battery is used.
Other changes may result from corrections. A manufacturer might discover that a technical specification was entered incorrectly, a supplier could provide updated material information, or a calculation could be revised following a data-quality review.
There can also be structural lifecycle changes. A battery may undergo repair, preparation for reuse, repurposing or remanufacturing. The EU Batteries Regulation specifically addresses these scenarios and requires a new Battery Passport for such a battery, linked to the Passport or Passports of the original battery or batteries.
The result is a simple principle:
Battery Passport data needs to evolve without becoming impossible to audit.
What Does the EU Batteries Regulation Require?
Article 77 of Regulation (EU) 2023/1542 requires the economic operator placing a battery on the market to ensure that the information in the Battery Passport is accurate, complete and up to date.
The regulation also requires Battery Passport information to use open standards and an interoperable, machine-readable, structured and searchable format. Article 78 further requires access rights for introducing, modifying and updating information to be restricted, while data authentication, reliability and integrity must be ensured.
These requirements have an important practical implication: organisations need a controlled process for managing changes rather than simply overwriting existing values.
What is Battery Passport Data Versioning?
Data versioning means maintaining identifiable versions of important information as it changes over time.
Consider a battery with a recorded State of Health of 92%.
Later, a new assessment records 89%. A basic database could simply replace 92% with 89%. A properly governed Battery Passport process should retain enough information to establish:
Element | Example |
Previous value | 92% |
New value | 89% |
Effective date | 15 March 2027 |
Source | Battery assessment system |
Reason for change | New assessment |
Responsible party | Authorised data owner |
Validation status | Approved |
Evidence | Assessment record |
The exact fields will depend on the organisation and data attribute, but the principle is broadly applicable: the current value should be distinguishable from the history that explains how it was established.
This is particularly important for data used in compliance assessments, sustainability calculations and lifecycle decisions.
Do Not Treat Every Change in the Same Way
A useful change-management model distinguishes between different types of updates.
Corrections fix information that was previously wrong. The original value should normally remain recoverable so that the organisation can explain what changed and why.
New measurements add information generated during the battery's lifecycle. These may represent a new state rather than a correction to an earlier value.
Derived-value updates occur when an underlying dataset, methodology or calculation changes. In these cases, the organisation should be able to identify the inputs and methodology used to produce the updated result.
Lifecycle changes can alter the status or responsibility associated with a battery. Reuse, repurposing, and remanufacturing can require a new Battery Passport linked to the original Passport record.
Treating all four scenarios as simple database edits can make the resulting history difficult to interpret.
Build a Controlled Update Workflow
A practical Battery Passport change process can follow a sequence such as:
Change Identified → Source Updated → Validation → Approval → Version Created → Passport Updated → History Preserved
The first step is to identify what has changed and why.
The source system should then be corrected or updated where appropriate. Changing only the published Passport can create inconsistencies between the Passport and the underlying business systems.
The new information should pass the relevant validation rules. Depending on the data, this could include format checks, range checks, consistency checks or verification against supporting evidence.
An authorised person or system can then approve the change before the updated information becomes the current Passport value.
This approach connects change management with the principles discussed in BASE’s guide on How To Validate Battery Passport Data Before Publication.
Keep the Previous Version Traceable
Versioning does not mean every historical value needs to be displayed publicly.
Instead, organisations should distinguish between the current published value and the internal history required for governance, assurance and auditability.
For an important data attribute, the historical record could capture:
- Previous and current values
- Date and time of change
- Source system or organisation
- Reason for the change
- Validation and approval status
- Supporting evidence
- Person, organisation or authorised system responsible
This creates a connection between versioning and the audit trail.
As explored in Battery Passport Audit Trails And Evidence Management, an audit-ready system should make it possible to understand how information was created, changed and supported by evidence.
Link Changes to Data Lineage and Provenance
Versioning becomes much more useful when it is connected to data lineage.
Suppose a carbon footprint value changes after an upstream dataset is updated. Knowing that the value changed is useful, but it is even more valuable to know which source changed, which calculation was affected and which Passport records subsequently required updating.
This creates a chain such as:
Source Change → Transformation → Validation → New Version → Published Value
Data provenance adds another layer by recording the evidence and origin behind the value.
Together, lineage, provenance and versioning give data owners a much clearer picture of how information evolves.
This is why Battery Passport Data Provenance complements the previous discussion of lineage. Lineage explains how data moves. Provenance explains where it came from and why it can be trusted. Versioning explains how it changes over time.
Manage Lifecycle Transitions Carefully
Some of the most significant changes occur when a battery moves beyond its original application.
Under Article 77, when a battery undergoes preparation for reuse, preparation for repurposing, repurposing or remanufacturing, responsibility for fulfilling the Battery Passport obligations transfers to the relevant economic operator. The battery must have a new Battery Passport linked to the Passport or Passports of the original battery or batteries.
This means lifecycle management cannot be separated from identity and relationship management.
The new Passport should be connected to the previous record in a way that preserves the battery's history without confusing the new lifecycle state with the original one.
The same principle applies when organisations design their systems for long-term traceability. A battery's digital history should remain understandable even when responsibility, application or lifecycle status changes.
Give Data Owners Clear Responsibilities
Version control is ultimately a governance issue as well as a technical one.
Each important data attribute should have a defined owner or responsible role. That owner should understand when the information can change, what evidence is required, which validation rules apply and who can approve an update.
Technical controls should then enforce those decisions.
Article 78 requires rights to access, introduce, modify and update Battery Passport information to be restricted according to the applicable access rights.
This makes role-based permissions, approval workflows and controlled interfaces important components of Battery Passport architecture.
BASE's article on Battery Passport Data Governance explores these responsibilities in more detail.
How BASE Supports Lifecycle Data Management
The BASE project is developing, validating and implementing a trusted and interoperable Digital Battery Passport framework designed to support secure data management across the battery value chain.
Managing change is closely connected to BASE's broader work on traceability, data authenticity, interoperability and lifecycle information. A reliable Digital Battery Passport needs to maintain the relationship between data, its source, its history and the battery to which it belongs.
BASE's approach considers information across different stages of the battery lifecycle, including manufacturing, use, maintenance, reuse, repurposing and recycling. Its work on data structures, traceability and secure data exchange provides a foundation for understanding how information can remain connected as the battery and its associated data evolve.
This is particularly relevant to versioning. When information changes, the system needs to recognise the new state while retaining sufficient context to understand the previous one.
Build for Change, Not Just Initial Compliance
A Battery Passport that works only at the point of publication is not enough for a battery with a multi-stage lifecycle.
Organisations should design their systems around the expectation that data will change. New measurements will appear. Corrections will be required. Calculations may be revised. Responsibilities can move between economic operators. Batteries can enter new applications.
A robust approach therefore combines version control, validation, access management, lineage, provenance and audit trails.
The objective is straightforward: when a Battery Passport value changes, an organisation should be able to explain what changed, when it changed, why it changed, who authorised it, what evidence supports the new value and how the change relates to the battery's wider lifecycle.
That is what turns an evolving dataset into a trustworthy Digital Battery Passport.
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/legal-content/EN/TXT/?uri=CELEX:32023R1542
European Union - Regulation (EU) 2024/1781: https://eur-lex.europa.eu/eli/reg/2024/1781/oj
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 Project - What Happens When Battery Passport Data is Found to be Incorrect?: https://base-batterypassport.com/blog/traceability-9/what-happens-when-battery-passport-data-is-wrong-140