From January 2027, the European Battery Regulation requires batteries placed on the market or put into service to have a battery passport that collates, stores, and displays product information, including carbon footprint, responsible sourcing, and recycled content. In the U.S., the Clean Vehicle Tax Credit, Section 30D of the Inflation Reduction Act, increasingly requires material traceability for batteries seeking to qualify for tax incentives. The Chinese government has responded by launching a Chinese battery passport, including transparency requirements, to facilitate trade.

To support organizations in preparing for these global regulations, Circulor works closely with customers across the battery value chain to implement battery passports, while also participating in a number of global battery passport initiatives.

What have we learned to date?

• Data interoperability is already happening, at scale – Open APIs, common standards and protocols are already being combined to enable data exchange and aggregation across the battery value chain, with blockchain providing a secure and decentralized platform to do this. We see a growing willingness by value chain participants to share data and therefore, going forward, the focus should be on finalizing the underlying methodologies and calculations for specific data requirements and driving international harmonization, for example the CO₂ footprint. ​
• Supply chain engagement is key – Establishing digital connections between supply chain participants is required to collate battery passport data but this takes time, so starting early provides a competitive advantage. By building strong relationships with suppliers who will comply with the regulations, manufacturers can also secure reliable and sustainable sources of materials, components, and resources.
• It’s more than just meeting regulations – Battery passports can create myriad value across business operations. Improved data availability will reduce costs for circular business models, create opportunities for organizations to focus on decarbonization, while managing the risks inherent in today’s global supply chains. For refurbishers and recyclers, it will improve safety of dismantling and streamline decisions on whether batteries are fit for second-life or ready to be recycled.
• Neutral, trusted data is critical – Battery passports will increase transparency and enable sustainable and circular value chains; however, only if the data is neutral and trusted. We see how shared knowledge from across the battery ecosystem is driving international best practices and this must increase further. The German BMWk Battery Pass consortium is a role-model here, setting a global precedent on how government, industry, research and technology organizations can work together to create a trusted standard.

The Battery Pass consortium recently published a comprehensive Battery Passport Content Guidance including a list of around 100 data points instructing industry participants on the information needed to comply with the EU Battery Passport requirements. This helps global companies to identify their specific data obligations in Europe and highlights opportunities for the industry to increase transparency and granularity, with ongoing engagement into the European Commission on recommendations for effective implementation and secondary legislation.

Building off the release of the content guidance, the consortium will apply technical standards, like unique identifiers and data carriers, and build a battery passport demonstrator that complies with the EU Battery Regulation. This demonstrator, for which Circulor is the project lead, will further assess technical feasibility of defined data points in the content guidance, verify applicability of selected standards, and be used to assess the additional business value of battery passports – crucial to accelerating data-driven circular business models.

To summarize

In response to global regulatory requirements, the battery ecosystem is increasingly collaborating and seeing both the regulatory and business benefits in doing so.

The need to harmonize and standardize international digital battery passport requirements is clear, and the good news is that the technologies exist today - like Circulor - that integrate with existing systems to facilitate the global implementation of battery passports and are accessible to various stakeholders in the value chain.

By getting started with the data requirements for product passports today, manufacturers can navigate the evolving regulatory landscape with confidence and use the information to benefit from circular business models that secure a more resilient and responsive future for their business.