Less than four months remain before the European Union's Battery and Waste Battery Regulation (EU 2023/1542) makes the digital battery passport mandatory on February 18, 2027.
In four months, it will leap from regulatory text to customs windows.
By then, every EV battery, light-transport battery, and industrial battery exceeding 2 kWh entering the EU market must carry a "digital passport" — verified at customs through a unique identifier.
It sounds as simple as slapping on a QR code.
But companies actually preparing for it will tell you otherwise:
This could be the most complex compliance exam China's battery industry has faced in a decade. It isn't testing whether a battery can run; it's testing where it came from, how much carbon it emitted, and whether its data can be continuously verified.
Compliance, Redefined
Why is the EU going to such lengths for a battery passport?
The drive stems from its Green Deal and circular economy strategy. The EU views batteries as critical to the energy transition, aiming for three goals through digital passports: first, cutting lifecycle carbon emissions to support the 2050 net-zero target; second, boosting recycled material shares to curb reliance on imported minerals; third, extending battery lifespan to promote second-life use and a circular economy. The battery passport is just the beginning — the broader Digital Product Passport (DPP) system will eventually cover more categories.
The EU's DPP registry is set to go live in July 2026. In October, the Global Battery Alliance (GBA) released its latest pilot results: 17 supply-chain consortia entered operational trials, accounting for 80% of global cell production capacity.
Many companies initially treated the battery passport as an IT project: buy a system, generate a QR code, fill in 90 data points, and call it done.
Image source: FinDreams Battery
But EU regulations demand far more.
A compliant passport contains three layers of data:
The static layer: product model, manufacturer details, material composition, compliance certifications, hazardous substance management, and unique cell identifiers.
The semi-dynamic layer: lifecycle carbon footprint (gCO₂eq/kWh), recycled content ratios for cobalt, lithium, nickel, and lead, supply-chain due diligence reports, and performance and durability parameters.
The dynamic layer: post-delivery data including state of health (SoH), state of charge (SoC), cycle counts, repair records, second-life history, and even end-of-life routing and recycler information.
This means battery makers are delivering not just a product, but a continuously updated data chain. If a battery runs in Europe for three years, degrades to a certain capacity, gets repaired somewhere, and ends up at a specific recycler — all of it must be traceable.
Even more critical is data "credibility." Companies can't just fill in numbers. Carbon footprints must be calculated using EU-designated methodologies and verified by a third-party Notified Body. Supply-chain due diligence must prove you know where your minerals originated, which traders handled them, and whether environmental or social risks exist. Dynamic data must be captured in real time via IoT or the vehicle's BMS interface — no manual fabrication allowed.
A compliance executive at a top-tier battery maker put it this way: exporting to the EU used to be like getting a driver's license — memorize the rules, pass the test, hit the road. Now, it's like an annual inspection where you must disclose every repair record, fuel consumption figure, and even parts sourcing from factory to scrap — to regulators and customers alike.
The hardest part is that launching the system isn't the finish line. Generating the passport is just the start; the real workload lies in sustained operation over the following years — updating data, managing access permissions, handling anomalies, and adapting to regulatory shifts.
Sunwoda Mobility told Gasgoo: "The battery passport isn't a simple software development project. It's a systemic engineering effort that must integrate R&D, manufacturing, procurement, quality, sustainability, and IT."
Many companies spent two years realizing this isn't a software project at all — it's a management mechanism embedded across the product's entire lifecycle.
Dynamic data is particularly thorny. Once a battery is delivered to an automaker, metrics like SoH and cycle counts live in the vehicle's BMS — and battery makers may not have access. Whether carmakers will open data interfaces, how often they'll sync, and who owns the data are still points of contention. The industry's current workaround runs on dual tracks: where vehicle interfaces exist, data syncs in real time via trusted data spaces like Catena-X; where they don't, OBD terminals are added for offline collection. Either way, it demands coordination among automakers, battery makers, and data platforms.
This marks a leap from "product compliance" to "data governance."
Three Fault Lines in Industry Readiness
Survey China's major battery makers, and readiness gaps are already stark.
Leading the pack are those who started preparing when the regulation first dropped in 2023.
CATL has participated in all three GBA pilot rounds — the only battery maker globally to publish a passport in every cycle. In 2024, its Shenxing and CTP batteries each received independent passports, with pilot carbon footprints around 49 kgCO₂eq/kWh. In February 2026, CATL signed a memo with BMW Group in Beijing to collaborate on cross-border passport data pilots and supply-chain carbon footprint alignment, leveraging Catena-X — the trusted data space used by the German auto industry.
Another group is taking the "self-developed platform plus ecosystem partnership" route.
Sunwoda Mobility, for instance, set up a dedicated battery passport team in November 2023 and partnered with industrial software giant Siemens to co-develop a platform, completing the system build in two years.
Image source: Sunwoda
In 2024, Sunwoda Mobility's LFP battery projects with Dianlian Tech and SAIC Maxus, and another with Li Auto, both made the GBA's top-10 pilots. In 2026, it formed consortia with Li Auto and VOYAH to enter the GBA's operational trial phase. By mid-2026, its passport platform had completed integration with the EU DPP registry's test environment, passing full-process tests for identity authentication, data submission, and registration verification.
Explaining the early push, Sunwoda Mobility said: "We want to turn external regulatory demands into an internally sustained management mechanism, giving customers more transparent, credible, and traceable product information."
EVE Energy is pursuing the certification route. In late 2024, it secured the world's first EU 2023/1542 Mark certificate for traction batteries from TÜV SUD. At the 2025 Munich auto show, it launched passports covering consumer, power, and energy storage batteries, integrated with the Catena-X data space. In April 2026, its Mr.Big energy storage battery passed SGS's deep D1-mode audit.
Companies in this tier share a common trait: they don't treat the battery passport as a compliance cost to appease the EU, but as a component of product competitiveness. Their passport platforms aren't just for European eyes — they feed back into internal carbon management, supply-chain tracing, and customer service.
Others are either playing catch-up or haven't truly started. The former are hiring consultants, seeking certifications, and building systems — yet internal data pipelines remain disconnected, upstream supply-chain data collection hasn't begun systematically, and carbon footprint methodologies are still being learned. The latter, focused on domestic or non-EU markets, barely grasp the concept beyond "knowing it exists."
A consultant working with multiple battery makers revealed that mid-tier firms' biggest confusion isn't whether to act, but where to start. EU regulatory details are still being released in dribs and drabs, with supporting standards landing in batches. Just as companies untangle one requirement, the next document lands — leaving teams scrambling.
A realistic assessment: the remaining four months are enough for top-tier players to close the last mile, but not enough for laggards to catch up.
The hardest part of the battery passport is never the coding — it's the supply-chain data architecture. Building it takes years; overtime won't solve it. Which means that after February 18, 2027, the roster of Chinese battery exporters to Europe will naturally slim down.
The Real Black Hole Is Upstream
At this point, one issue deserves to be singled out: a battery maker's own data is actually the easy part.
As long as internal digitalization is mature enough to connect MES, ERP, PLM, and QMS systems, product details, production parameters, and quality records can largely be aggregated automatically.
Image source: CATL
Take Sunwoda Mobility: its passport platform integrates industrial IoT with business systems, achieving over 70% automated internal data capture. The rest relies on supplier co-reporting and manual entry.
The real black hole lies upstream.
Sunwoda Mobility admits: "The further you extend up the supply chain, the harder data acquisition becomes."
A battery passport must trace back to raw material origins: where the cathode material came from, who made the precursor, which mine produced the lithium, and how many traders handled the cobalt. EU regulations impose clear due diligence requirements on critical minerals: companies must build supply-chain management systems, identify and assess risks, implement mitigation measures, undergo third-party audits, and publish due diligence report summaries to the public.
Reality check: the further upstream you go, the weaker corporate digital capabilities become.
Cathode and anode material makers are at least scaled enterprises with basic IT systems, capable of outputting product data on demand. Move further up, though, and lithium salt plants, cobalt smelters, and nickel smelters are largely small and mid-sized firms. Many lack complete product data ledgers, let alone standardized interfaces to connect with downstream battery makers.
A technical lead for a passport platform revealed that among their clients, battery makers' biggest headache isn't building their own systems — it's getting upstream suppliers to hand over data. Many material suppliers can't fathom why they should disclose customer lists, purchase volumes, and process parameters when they're already delivering to spec.
Trade secret concerns loom large. A cathode maker's formulations, yields, and client lists are core competitive advantages. When downstream battery makers demand supply-chain data, suppliers fear this information could leak to rivals through the passport platform.
The tech sector is hunting for solutions. Blockchain could provide data attestation: suppliers hash data on-chain without exposing raw content, while downstream battery makers and auditors verify it hasn't been tampered with. Zero-knowledge proofs could let suppliers prove "my lithium source meets compliance" without revealing the specific mine or volume. Tiered authorization could restrict the public to basic product details, give regulators full access, and limit commercial partners to authorized slices.
Yet these tools remain in early pilots, far from scaled deployment. And technology can't fix the root problem: if the source data is fabricated, the chain merely preserves a lie.
The industry's common workaround today: battery makers set up supplier portals, issue standard questionnaires, and have upstream firms manually fill them out and upload credentials for human review. It works, barely — but data quality is uneven. Some suppliers submit estimates, dates don't align, and key details stay vague. When EU third-party auditors come knocking, such data won't survive scrutiny.
Cost pass-throughs pose an even thornier problem.
Downstream automakers demand passport data from battery makers, who press material suppliers, who squeeze miners. Every tier must add staff to fill data, conduct reviews, and keep records for audits. These costs don't vanish — they cascade down the supply chain, ultimately landing in the battery price quote.
This is why some argue the battery passport may look like a test for battery makers, but it's actually a test for the entire Chinese lithium-ion supply chain. Even the strongest digital capabilities at the top can't withstand the data black holes of hundreds of upstream suppliers.
Conclusion:
Before February 2027, top-tier players are sprinting, mid-tier firms are cramming, and the tail end is watching. Yet all face the same hurdle: illuminating the data black box between the mine and the battery plant. Until that's solved, the passport remains an unfillable form.
In the next piece, we'll discuss two starkly different choices companies are making to cope with the passport: building dual data ledgers, or simply moving factories to Europe. Behind these choices lies a rewrite of the global landscape for China's battery industry.
