What the passport actually requires

The battery passport under Regulation (EU) 2023/1542 is a battery-level digital record, reachable through a QR code on the battery, carrying data across the whole lifecycle: identity and composition, carbon footprint, due-diligence information, performance and durability, state of health, and end-of-life information including recycled content. Access is tiered — some attributes are public, others restricted to those with a legitimate interest or to authorities.

Around the legal text, an ecosystem of standards is forming: the Battery Pass consortium's content guidance and DIN DKE SPEC 99100, the CIRPASS projects preparing the wider Digital Product Passport, and carrier standards such as GS1 Digital Link for the QR layer. Whatever platform an OEM chooses, interoperability with this ecosystem is the safe bet.

The checklist

  • Data inventory. Map every passport attribute to a source system — and be honest about the gaps. Most OEMs find first-life data (BOM, carbon footprint, performance) is hard but locatable; end-of-life data usually has no source at all.
  • Unique identification. Each battery needs a persistent unique identifier that survives resale, repair, repurposing and collection. If your serialisation stops at the warranty database, it stops too early.
  • QR and access tiers. Plan the public / legitimate-interest / authority views from the start; retrofitting access control onto a flat data model is expensive.
  • End-of-life evidence. Decide now who will write the passport's final chapters — collection, treatment, recovery, recycled content. This is where a documented waste-stream partner matters: the data must be captured where the material is handled, not asserted afterwards.
  • Recycled-content arithmetic. From August 2031, new industrial, EV and SLI batteries must declare minimum recycled content (broadly 16% cobalt, 85% lead, 6% lithium, 6% nickel). The passport is where that claim meets its evidence. Secure verified recovered-material supply early.
  • The recycler's burden. If you are a recycler: count the OEM passports you may be expected to update. If the answer is "one system per manufacturer", raise it with your suppliers now — or work through a wallet layer that lets you comply once.

The wallet question

The regulation mandates the passport; it does not mandate that every manufacturer's passport must be a separate operational burden for the recycling chain. RAW TG is building a wallet approach for exactly this reason: OEMs keep their own passports, and the downstream chain reads and writes through one connected view. See the wallet approach.

Talk to the desk. Building a passport, or expecting to comply with everyone else's? Contact RAW TG.

This article is general commentary from a trading desk, not legal or regulatory advice. Verify requirements against the applicable legislation before acting.