Episode 53 | EU Battery Passport | Compliance, Technology and Opportunity

Welcome to the Battery Technology Podcast. My name is Ken Davis, I'm your host and this is your regular exploration of topics across the world of battery development, sustainability, energy storage systems and charging and everything else related to the transition to a greener future. And the Battery Technology Podcast is brought to you by Battery Tech Europe Expo at Fira de Barcelona in September 2026, showcasing European innovation in battery technology. It's a new event in a rapidly developing region that focuses on the future of battery applications and it puts European innovation and the European battery technology ecosystem right at the front and centre. See the show notes for more details. Episode 53, the EU Battery Passport, preparation, implementation and challenges. The 17th of February 2027 is a very important date for anybody who is involved in any aspect of the battery industry in Europe or indeed supply batteries or any componentry into Europe because it's the date that's been set for the introduction of the EU Battery Passport, a mandatory digital record that is accessed through a QR code of key technical data across every stage of a battery's life and it's a huge, ambitious project aimed at fundamentally improving transparency, the circular economy and responsible sourcing. So in this episode of the Battery Technology Podcast, we're going to take a deep dive into every aspect of the Battery Passport because it's coming our way and we're going to be talking about objectives and implications for the industry, the state of readiness, who does it affect, what information is required, how will it work and how we are all going to implement it. Now, to help me do this, I'm joined by Dr. Suzanne Goote Orlowski who is an expert not only in the Battery Passport, in fact a very wide array of technology involved in digital passports across all kinds of industries. She's also a technical advisor to the Global Battery Alliance, so we are in very safe hands to help us guide us through everything you need to know about the Battery Passport. So firstly, a very warm welcome to the Battery Technology Podcast, Suzanne. Thank you very much for the invitation, Ken. Great, so a lot to talk about, very much looking forward to this. I suppose though it might be worthwhile just starting with your own background in the wider field of digital product passports because of course they do apply across a very wide range of products and then specifically how you became involved specifically in the battery space. So I'm actually an IT security professional by education and an expert in decentralized technologies. Today, I'm the CEO for the Record, a digital product passport consultancy agency because that allows me to look into different fields in the area of digital product passports. I was engaged in the battery regulation from the beginning as an external consultant of the European Commission in digital product passport projects. And I was working there because I strongly believe in the fact that only sustainable production and consumption can preserve our wealth and our well-being. And it was the first concept of the European Commission where data was stored decently in other projects such as REACH. You had to upload your data to a central platform. The digital product passport is the first concept where data is held decently and as an expert in decentralized technologies, this struck me and interested me a lot. So in 2021, I was actually the first professional that published a technical concept how to build a decentralized digital product passport. And I've been very busy building that concept since today. The concept is actually driving around in electric buses in Berlin today in the public transport. And after the battery regulation came out, the European Commission also needed to standardize the technology that should be used around digital product passports. So they initialized the standardization activity of CENSELELIC, which is the JTC 24. And apart from that, I'm also working with the United Nations Economic Commission for Europe to define how digital product passports can actually be filled with data upstream. And therefore I had the honor to be the lead author of the recommendation 49 that gives actually advice to policy makers on how to make sustainability data electronically exchangeable and trustworthy so that we have something worldwide to fill digital product passports. And finally, I'm an external technical advisor to the Global Battery Alliance, helping them to understand the technical requirements to build battery passports and rolling out their operational trials. So that's a lot of things I'm working on. But you can see this is only possible as an external independent advisor, which is why I like the role. I can imagine you do. And I'm very pleased you've taken us through that because it just reinforces that we're in very safe hands in relation to talking about the battery passport, which is a big thing. There's so much to unpick. But I think the first thing to say is to define exactly what's going to happen, what people will need to prepare for come 2027. So first things first, let's talk about the critical date. Let's talk about the key objectives at a political level of what the passport is there to do. So let's just talk about that initially so people understand exactly the framework. The battery passport regulation did not start at the day that it was published, of course. Started much longer before that date. And all these projects at the European Commission start with a preparatory study. That means the commission looks at product segments, in this case, the battery, which was the first segment. And they looked at the environmental concerns of the battery as a product. They saw that in this preparatory study, they saw that in the era of batteries, water depletion is an issue, habitat destruction, CO2 emissions from extraction processes, furthermore, social and human rights issues such as forced labor, child labor, human health risks, like exposure to toxic lead dust. And those are all significant risks in the mining and processing of battery materials. Of course, there's also some other structural risks that we see, we see that we have a supply chain concentration, we see that if we do not get the materials for our batteries, that is also causing a risk to our industries. So with those risks identified, they came up with the requirements for the battery passport. And that is also giving a good counter reason for the people that say, I don't think digital product passports are good because my entire supply chain then becomes transparent. That's not the case. It's really information that is required to mitigate the risks that I just mentioned. So not everything is a product passport, only the information that can help understand and manage the risks I mentioned. Understood. And we're talking about it coming into force on the 17th of February, 2027, if I understand it correctly. Have I got that date correct? Absolutely. Excellent. So just to paraphrase, primarily, the passport is providing a degree of visibility that will help informed consumers make choices about how this product has been made. Presumably, people then can make better informed decisions about their own supply chain and the CSR credentials, the environmental or the ecological sustainability credentials of their individual supply chain choices. I guess the other thing to add is it also will provide a huge amount of information that is usable at the end of the product's life in terms of being able to recycle this product in a way which is knowledgeable about the materials and the production of that individual battery. Does that kind of encapsulate it? That's absolutely right. And we have to see that the digital product passport is consumed by different roles. The first one who looks at the product passport or the battery passport is the consumer. And the European Commission wants them to make an informed choice about the product that they're buying. And this is where they see sustainability certifications from the supply chain, which they can decide on, and the carbon footprint, for example, that they can compare with other batteries. So that's true. And then, of course, the battery passport includes data that is relevant for the downstream supply chain until the end of life, and then, of course, also recycling. So if you look at the data that needs to be entered into a battery passport, which is, by the way, listed in a specification that came out from Dean Dicke, it's a German standardization activity, as the standard is 99/100. You find all the attributes that are potentially in the battery passport, and they have different categories. So first of all, there's general information such as battery identifier, battery category, battery weight, battery status. Then you have labels and certifications in the battery passport, the carbon footprint, of course, how the carbon footprint has been calculated, then important, the supply chain due diligence information and a report, then material composition that now becomes relevant for recyclers, people that want to reuse the battery at the end of life. It includes hazard of substances, battery chemistry, critical raw materials, and the materials used in the cathode, anode, and electrolytes, and then you have the circularity and resource efficiency information such as manuals for removal, disassembly, and dismantling. And finally, you have performance measures and durability indicators such as the capacity, energy, power, state of health, expected lifetime, and negative events. Those are the categories that you have in the battery passport, and those are consumed by different voids, by consumers, actors along the supply chain, and people at the end of life. Brilliant. That's very clear, and I really appreciate you taking us through that. A quick announcement and a note for your diaries. If you're interested in learning more about the battery passport and the implications for business, we're holding the EU Battery Passport Conference on 4 February, 2026 at the Grand Palais in Lille. It will all be part of the Battery Tech Expo France being held in Lille that week. We'll be covering compliance, technology, and opportunities. In fact, we're across all aspects of battery passport implementation in the company of the foremost experts in the field. It really will be a unique opportunity to network with regulators, expert service providers, and in fact the battery industry in general, as we prepare for the implementation of the battery passport. So if you want to get ahead with your planning and preparation for the battery passport, that will be the place to be. Please check the show notes where you'll find more details. One important thing to understand is who is responsible. There's a term, economic operator, which gets used in the context of this. It is the economic operator who has the responsibility for making sure that there is a battery passport accessed via a QR code on every single individual battery in any industrial use above two kilowatt hours. It is the economic operator whose responsibility is to make sure that happens. Can we, for the sake of our audience, explain what economic operator means and who that would be in the real world? Yeah, the economic operator is the term from the battery regulation and by the way also from the Equal Design for Sustainable Products regulation, which is kind of the same regulation but for other product segments, that the economic operator is the company that places the product on the market, on the European market. And in the case of a battery in a car, in an electric car, this would be then the car manufacturer or the person that sells the car. In the case of different batteries such as stationary batteries, it is the economic operator that puts the stationary battery on the market. So it can be either part of the system that's been placed on the market or it can be a separate battery that can be used standalone. So it's mandated. It's going to happen on the 17th of February, 2027. What would you say is the state of readiness? Obviously, we've got a huge, diverse set of companies who will be affected by this. Obviously, use some very sophisticated businesses, there are some who are maybe less sophisticated. What in your assessment, having had responsibility for developing this, is your take on how companies are set up, are prepared for what really is only around the corner? It is clear that every car manufacturer that places products on the European market is alerted and involved and informed about the battery passport. In my last two to three years, I haven't met a car manufacturer that was not aware about the battery passport and that it's coming. When prepared a little bit differently, some car manufacturers are driving activities on the market with regards to standardization, with regards to supplier involvement. So if you look at Cartena X, for example, this is strongly driven by a few car manufacturers and some are more observing the space or have been observing the space, but now also have to find their ways to issue a product passport and because you have to collect all the data from your supply chain, you have to do something now, otherwise you won't be ready in 2027. So everyone's aware, at least in the car manufacturing industry, I'm not so sure actually about stationary batteries in other areas, if they have the same form of readiness, but I don't get to talk too many of those. So in case we have a listener, there will be plenty, there will be plenty in that market. Feel free to reach out. Where would you say, for an economic operator, somebody who's got to create this data, where would you say the big volume workload is in making that happen? Is it the technical side of it in terms of, hey, what does one look like? How do we design one? How do we create one? Or is it actually extricating or extracting, I should say, all of the data, historical data often, from fairly legacy systems often, in order to actually have the information to populate the battery passport with. Where would you say is the big weight of work that will need to be done here? So I think if I'm not alone, I would actually say everyone in the industry would agree that getting the data ready is the biggest challenge for everyone. Getting the data ready from your own systems, out of your own ERP systems that you run, because you have to provide general information about the battery, its capacity, and so forth. But of course, the supply chain data, the material of the cathode, anode, your suppliers, your diligence information, that's the biggest challenge. And there is a great project out there that finalized at the beginning of this year, which is the battery pass project, which was run by a systemic funded by the German government but targeted to support the European Commission and the battery solution. And they have come up with a number that 60% of your efforts is to collect the data to issue the product passport, the battery passport. I believe that in 2027 issuing the passport and leading it to a website, verify the website where you can see the product data is really the smallest problem. But to get that also into your processes is another challenge because the battery passport is touching so many different departments, I would say, in a company, you have to talk with the consumer interaction, with the marketing people, you are allowed to provide extra information on top of the required information from the regulation, and you have to change your organizational processes. But the biggest hurdle is definitely getting the data into the product passport. The other question that that suggests is, as an economic operator, you are to a large degree, reliant on your supply base to provide that information, that suggests a degree of compliance and cooperation by the supply base that they will provide that information. What happens if, and there can be a number of reasons for this, if the supply base is less than cooperative in supplying that information to you as an economic operator, and that might be because they feel that there's some commercial sensitivities about the information that they want to share, or they may be making public information that maybe they didn't want to make public for the very reason why we're having a battery passport, perhaps their procedures or their processes weren't as diligent as they might have suggested they were. How does an economic operator try to develop that level of cooperation with the supply base? Because it's going to be absolutely essential, I would imagine. Yeah, you're opening the box of the Pandora there. Of course, getting the information from the supply chain is essential for the battery passport. Now, there are different approaches to that. First of all, some companies do work with other companies, service providers, that have specialized in that area, actually. The only service they provide is to find out the supply chain of a battery supplier for them, to audit those suppliers, and to make sure that the supply chain due diligence has been made and can be made available to the battery passport. And while doing that, of course, you will now find out who is playing to the rules and who is not. And this, of course, will do a lot of things. First of all, it will motivate the supply chain to play against the rules. It also gives OEMs an instrument at hand to choose suppliers that have made their due diligence, and with that in the end provides more sustainable batteries to us. But of course, you're dependent on the cooperation of your suppliers, and that is not entirely solved. So you cannot force anyone to supply information, but of course, if you look at the upcoming benchmark of the Global Battery Alliance, which actually was released last week, the benchmark framework, then your batteries will soon be benchmarked against those criteria. And it will give transparency to the consumer and also to the car manufacturer. And with this, your battery will be rated according to those benchmarks, and you will get a score. So there is definitely a motivation or there's a reason to be motivated to work against the due diligence rules and to work against those benchmarks, because then you probably can sell your batteries better to the European market than not working against those benchmarks. That makes perfect sense. The world is moving in this direction. This trends this way in China, they're probably further ahead than us to be honest in this. There is in the United States and clearly now there is in Europe. So I don't think there's a single battery manufacturer in the world. It doesn't understand that they will be required to supply this information at some point in the future. So that makes sense. Two of the things just to talk about, it's easy sometimes to think of the battery passport as something which is created at the birth of a battery or at the introduction of a system into the market. But of course, it's an ongoing requirement. The information on these battery passports is not just about how they were made. It's about how they were used. And I just want to touch on that subject for a second. What will economic operators need to provide during the lifetime of other battery that will need to be on that passport? Yeah, on this question, I also recommend a look into the DKE spec 99100, where you find the data that needs to be provided. You will find a section that explains the state of health, which needs to be provided for a battery. And to figure out that state of health, it is recommended to collect information along the lifetime of a battery, such as loading cycles, negative events, usage of the battery in general. And that's the information that you would have to provide to also allow other parties to identify the state of health of a battery at the end of a lifetime, or when the car moves from one owner to the next, or the like. Obviously, it sounds like a big bureaucratic exercise, and to a degree, there is more bureaucracy involved. But it's bureaucracy for a reason, and the reason being we have far more transparency, we have far more visibility, or far better opportunity for second use in batteries. Do you see this as an opportunity for individual companies? If they manage this process in the right way, there are commercial advantages. Absolutely. Thank you for that question. I think it's very important. I think it would be a mistake to see the battery passport as a regulatory burden, because it actually isn't. It will give you a lot of benefits, and there I can also direct you to the battery pass project who have looked at the benefits and how to publish them. What you will experience is a general cost reduction because of the digitization of your information and the digitization efforts of the supply chain, the standardization of the way how you get information from the supply chain to your systems that you can then use in the battery passport. The battery passport, with also the right benchmarks, gives you better access to capital if you are a good performer in your supply chain due diligence. For consumers, it will increase the trustworthiness of your products and therefore your brand. What I like especially is that you will have better sovereignty over the data due to the decentralized nature of the digital product passport because the data stays with you as an economic operator. You don't have to provide it to a central platform anymore where you have no idea where the data ends up. Of course, we increase the circular economy. We have less gas emissions, and we meet or mitigate all the risks that I mentioned as at the beginning, but finally also there will be new business models arising from the new data that we have from the battery passport. Think of concepts such as battery as a service, for example, that then would motivate you to maybe put more quality into a battery. Expand the lifetime of a battery even more because you can get everything back. You can renew systems, parts of it that make it a really long-living battery and make a new business out of that. There's a lot of benefits that we will be seeing. If you have listened to some of the podcasts that I recorded with economic operators, you see that in a lot of different businesses, people are already using digital product passports like technology, orchestrate their logistics to improve all their processes and everything. So, do not see it as a burden. Do see it as a train to jump on for more digitization. Yeah, that makes a lot of sense. It's an opportunity, as all these big technological changes often can be, and it will be the more adventurous and more opportunistic, I guess, who really see the benefits of that. One final thing just to understand is, and it's coming back to a point you made right at the outset, this idea of decentralization because in other systems, REACH is a good example, it's a very centralized structure. This isn't. This is decentralized out to the economic operators. Does that mean that there can be various formats for the battery passport, depending on the economic operators preference? Or is it a standard, absolutely standard format for a battery passport? Or do economic operators have some freedom, they've got to have the same information, but the way it's displayed, can that be individual to an economic operator? So the content of the battery passport to meet the regulation needs to be the same. And that is defined in D&K in 1998-100, and that's what you have to provide. The commission allowed to have more information on the battery passport than just this information, which I think is a good thing because then you can transport more information in the battery passport, you can establish a connection to a consumer and convey more messages. So I believe that's right. I was not successful in convincing the European Commission that we have to have some kind of style sheets UI standard of how a battery passport needs to look like. So I fear that the battery passports that will come out in 2027 will all look differently. I think when this is seen, we will then start standardizing the user experience of a battery passport. That's one thing. So they should look the same because otherwise the consumer cannot compare the one passport to the other really nicely. The other thing that was also in your question was a little bit, can I use the battery passport for different things in different geographies? And here the interesting part is that the battery passport is now defined for the EU regulation, but the information that you need to have in there can help you to comply to different regulations in different jurisdictions. So the same data, for example, on the origin or the supply chain that you have for the European battery passport to show your supply chain due diligence and then to comply to the battery regulation can also help you, for example, for the US IRA, where you want to show that your supply chain contains manufacturing and mineral processing facilities within the US to get tax credits. So battery passport will start helping you standardizing the way you receive and share electronic information that makes you compliant to different regulations worldwide. And finally, obviously, 17th February, 2027, very big day, everyone will have battery passports about every single battery on the market above two kilowatt hours. Do you think the battery passport from that point will evolve? How do you think the battery passport project will move forward after its implementation? That's a very interesting question, and I'm pretty sure that it will develop. First of all, you have to comply to the regulation. And that's already still some steps to do to do this. But after we have the regulation in place and we see how the battery passport look like, we will also see things that have not been specified good enough, or maybe that do not meet the original tense. So I'm completely sure that we will see a revision of the battery passport, or the technology, or the details that have to deliver for the battery passport. After that, I think it will be a continuous improvement, especially to the calculation of the carbon footprint, the supply chain information that you have to provide. The UI that we talked about, how to make that better, to make it better comparable, I just also know that the revisions can take some time. So I think that these standards are revised every five years, at least the ones that we are now defining in JTC24. And what we have there in the first instance will stay there for a while. But that doesn't mean that the industry cannot further improve and work on it. And I'm pretty sure they will, because then they understand that they can use it for their own internal purposes. Suzanne, thank you. That has been an enormously enjoyable journey through the battery passport. It's a 2027 kind of feels a long way away, but it isn't. It sounds like there's an awful lot of work to do by an awful lot of companies to make sure there's the degree of readiness for the passport that it will be necessary. So Suzanne, I will make sure there's lots of links on the show notes to yourself and the great work you do. And maybe I can give some more hints to where the people can find more information about the battery passport. First of all, I would like to point you to the work of the global battery alliance, where the state of readiness gets better every year and every year. The global battery alliance has conducted pilots from 2023 onwards each year with their members, but also with external parties. So I can only recommend to look at it and to sign up for it. We will put in the show notes the link to the technical standards and the battery pass project that I mentioned. Also the surpass one project, which is funded by the European Commission to help the development of the digital product passport. I will also link to the UNC fact, United Nations transparency protocol, which can help you get standardized information from your upstream supply chain, the SAE standard that was mentioned. And of course, please visit my LinkedIn profile for weekly daily news on what's happening in the battery space. Absolutely thoroughly recommended that you do that. Suzanne, thanks for all your time on this. Thanks for your expertise. Thanks for your wisdom. That's been really enjoyable. Thank you very much for inviting me. The battery technology podcast is a copy-rided GSE media limited production. For more details and how to reach us, you'll find our contact details in the show notes or at our website, www.BatteryTechnologyPodcast.com. [Music]