What Is a Battery Passport? The EU Battery Regulation Makes It Mandatory from 18 February 2027, Ushering In an Era of Tracing Suppliers Back to Raw Materials

Hello, this is Ryuta Hamamoto from TIMEWELL.

When you first hear that "a battery will need a passport," it may sound a little strange. But this is not a figure of speech. It is an actual regulatory scheme. From 18 February 2027, the EU is scheduled to require that batteries placed on its market carry a "battery passport." Companies that make batteries, companies that sell products containing batteries into the EU, and even companies that supply materials into batteries are all drawn into this system.

In this article, I want to walk you through the basics of what a battery passport is, why it forces you to trace suppliers all the way back to the origin of raw materials, and what Japanese companies would do well to prepare now. I will unpack the technical terms one at a time. This is written for people who work in export control and economic security, of course, but also for readers who are still at the stage of "I keep hearing about battery passports, but does this actually affect us?" I will take it slowly and carefully.

Summary of this article

Let me start with the conclusions.

• A battery passport is a digital record tied to an individual battery. You access it through a QR code or similar marking, and it lets you check that battery's identity, environmental information, and supply chain information.
• It was introduced by the EU Battery Regulation (Regulation (EU) 2023/1542), which entered into force in August 2023.
• The scope covers EV (electric vehicle) batteries, industrial batteries with a capacity above 2 kWh, and LMT (light means of transport) batteries.
• The scheduled date for the requirement to take effect is 18 February 2027. However, some of the detailed data items and technical specifications are being set through delegated acts and similar instruments, so the final details need to be confirmed against the EU's official information.
• The battery passport requires items such as the share of recycled (recovered) material and the responsible sourcing of raw materials. To substantiate these, you have to gather data back to the origin of raw materials such as cobalt. This is where the real work of "seriously tracing your suppliers" begins.
• The battery passport is the forerunner of the EU's Digital Product Passport (DPP) initiative. The same framework is expected to spread to other product groups in the future, and Japanese companies that sell batteries or battery-containing products into the EU can also be affected.

Let's look at each point in turn.

What is a battery passport?

A battery passport (Battery Passport) is, in a word, "a digital resume tied to an individual battery." Just as the passport a person carries abroad records their name, nationality, and issuing details, a battery passport records information about that battery: "who made it and where," "what materials it is made from," and "how much of an environmental burden it created."

The defining feature is that it is managed as digital data, not as a paper booklet. The design under discussion is that when you scan a QR code (that square pattern) printed on the product or packaging, you can access the record corresponding to that battery. Who can see which information is expected to depend on the viewer's role, whether they are an ordinary consumer, a regulatory authority, or a recycling operator.

Why is such a system considered necessary? The background is that while batteries have become indispensable to our daily lives and to industry, what is inside them has been hard to see. A battery is made by combining various metals and chemicals, and its materials come together from mines and factories all over the world. How much CO2 (carbon dioxide) was emitted during manufacturing, how it is recycled after use, and whether the materials were sourced appropriately: this information used to stay inside the maker and was almost impossible to verify from the outside. It is easiest to understand the battery passport as an effort to resolve that "invisibility" through a digital record.

Introduced by the EU Battery Regulation

The instrument that introduced the battery passport as a regulatory scheme is the EU Battery Regulation. Its formal designation is Regulation (EU) 2023/1542, and it entered into force in August 2023. A "Regulation" is a type of EU legislation. Its defining feature is that it applies directly across the entire EU with strong legal force, without each member state having to rewrite its own national law.

This EU Battery Regulation is a comprehensive set of rules covering the entire life cycle of a battery, from design and manufacturing through use and on to disposal and recycling. It builds in a range of requirements, including carbon footprint declarations (I will explain this term later), the use of recycled material, restrictions on hazardous substances, and collection and recycling targets. The battery passport serves, in effect, as the container that makes the content of those requirements digitally disclosable and traceable.

Which batteries fall within scope?

The battery passport does not attach uniformly to every battery. Under the EU Battery Regulation, batteries such as the following are said to fall within scope of the battery passport when placed on the EU market. "Placing on the market" means making a product available for the first time, that is, starting to sell or supply it.

• EV (electric vehicle) batteries ... the large traction batteries built into electric vehicles.
• Industrial batteries (with a capacity above 2 kWh) ... batteries used in factory equipment, large-scale energy storage systems, and the like. "kWh (kilowatt-hour)" is the unit that expresses the amount of energy a battery can store, and the reference threshold is a capacity above 2 kWh.
• LMT (light means of transport) batteries ... LMT stands for Light Means of Transport, referring to relatively light vehicles such as e-bikes and electric scooters. The batteries built into these are also in scope.

In other words, small household dry cells or the batteries in your smartphone are not themselves in scope. The application starts with relatively large batteries, namely those for vehicles, industrial use, and light means of transport. For the finer lines of scope and any exceptions, it is safest to check the EU's official information. What matters here is that "a company selling vehicles or battery-containing industrial products into the EU may well be affected, and should treat this as its own concern."

What is recorded in a battery passport?

So what specific information goes into a battery passport? Based on the content of the EU Battery Regulation, the main items are said to include the following. Because some of the details are being set through delegated acts and similar instruments, please read this on the understanding that these are "the main items that are said to be included."

• Manufacturer, model, and chemical composition ... who made it, which model it is, and what materials it is made from, that is, the basic identity of the battery.
• Carbon footprint ... an indicator expressing the amount of CO2 (greenhouse gases) emitted during the manufacturing process. As the word "footprint" suggests, it shows the size of the environmental mark that battery left behind.
• Share of recycled (recovered) material ... the proportion of material that was not newly mined but was recovered from used products and reused. It is said to be required for specific metals such as cobalt, lithium, nickel, and lead.
• Performance and durability ... information on how much performance the battery has and how long it can be used.
• State of health (SOH) ... SOH stands for State of Health, an indicator of how healthy the battery is now, that is, how much it has degraded compared with when it was new. It serves as a basis for judgment when reusing or recycling a used battery.
• Responsible sourcing of raw materials ... information showing whether materials were sourced appropriately, with regard for human rights and the environment. Internationally, the OECD (Organisation for Economic Co-operation and Development) due diligence guidance is the reference point. "Due diligence" means the care and verification you are expected to exercise in transactions and sourcing; here, understand it as "the responsibility to investigate whether there is any risk in where the materials come from."
• Recycling and disposal information ... information on how the battery should be collected, recycled, and disposed of after use.

Laying these out, you can see that what the battery passport asks for is not just "battery performance." If anything, environmental burden and information about where materials come from (the supply chain) account for a large share. And this "where the materials come from" is precisely what becomes the greatest practical challenge for many companies.

If the content of a battery passport still does not quite click, I would suggest starting by working out whether the products or parts your company handles could even be subject to EU regulation in the first place. The way of thinking behind an export-control classification (determining whether something is "in scope" or "out of scope" of a regulation) is a useful starting point for this kind of exercise. If you would like to check informally first, you can try it out from a free export-control classification check.

Why do you end up having to trace suppliers back to raw materials?

This is the point I most want to convey in this article.

As I noted earlier, the battery passport requires you to include the "share of recycled material" and the "responsible sourcing of raw materials." Now, think about this. Suppose your company is a battery maker. What would you need in order to prove that "this battery contains X percent cobalt, of which Y percent is recycled material, and that cobalt was sourced appropriately"?

The answer is "gathering data from the suppliers upstream of you." A company that makes batteries buys components such as cathode and anode materials from other companies; those component makers in turn buy metals and chemicals from still other companies; further along there are smelters (plants that melt and refine metal); and beyond those there are mines. This chain of "your supplier's supplier, and that supplier's supplier again" is what practitioners call sub-tier suppliers. Tier 1 is your direct supplier, tier 2 is that supplier's supplier, and so on up the count.

To substantiate recycled content or responsible sourcing, you have to trace this chain as far upstream as possible, all the way to close to the origin of the raw materials. Cobalt in particular is a mineral that has drawn global attention from a responsible-sourcing perspective. I explain the investigation of cobalt in detail in our sister article, What Are Conflict Minerals? How to Read 3TG and the CMRT / EMRT Templates. The EMRT (Extended Minerals Reporting Template) from the RMI (Responsible Minerals Initiative) that I touch on there is precisely the standard template for investigating cobalt and mica, and it connects directly with the information the battery passport requires.

In other words, the battery passport is a scheme that asks you to "attach to a finished battery a tag showing the provenance (where it came from) of its materials." To do that, you have to break parts and materials down one by one to the level of the BOM (Bill of Materials), query the upstream suppliers for each, collect their responses, and cross-check them. The more items a product has, the more enormous this task becomes. It is here that many companies step, for the first time, into the practical work of "seriously tracing their suppliers."

The battery passport is the forerunner of the Digital Product Passport (DPP)

There is one more idea worth knowing that will make the battery passport easier to see in context: the EU's Digital Product Passport initiative.

The Digital Product Passport (DPP) is a broader framework aimed at digitally recording and disclosing the environmental and supply chain information of a wide range of products, not just batteries. Its foundation is the EU's Ecodesign for Sustainable Products Regulation (ESPR). "Ecodesign" is the idea of building environmental considerations in from the design stage of a product, and the ESPR is the regulation for extending that idea across a wide range of product groups.

The EU has indicated a policy of expanding this DPP to various product categories in stages. And the first full-scale application is positioned as the battery passport. Put differently, the battery passport is "the leadoff batter of a large wave that is coming." Similar disclosure schemes are expected to spread in turn to other product groups, such as textiles and electronics.

What is important here for Japanese companies is that "you can be affected even if you do not make batteries yourself." Companies that export battery-containing products (EVs, industrial machinery, electric light mobility, and so on) into the EU will need to prepare battery-passport information for the batteries they install. And as the DPP expands, similar information disclosure will likely be required for products other than batteries. For any company selling something into the EU, this is not a fire on the far bank of the river.

The service we are developing, TRAFEED, aims to make this kind of supply chain visualization more efficient across the board using the power of AI. Below, I will explain why TRAFEED's approach is a good fit for the practical work of the battery passport.

The battery passport sits within the same current as several other regulations

Reading this far, you may have started to see that the battery passport is not "a special story that only concerns batteries." In fact, the idea the battery passport calls for, "tracing parts and raw materials back one by one," is connected at the root with several schemes that have been spreading in recent years.

Consider, for example, the following.

• Schemes concerning forced labor ... a representative example is the U.S. UFLPA (Uyghur Forced Labor Prevention Act). It was enacted in 2021 and took effect in June 2022. It creates a need for companies to trace their supply chains to confirm that products and materials are not connected to forced labor. In the EU as well, a framework to regulate the circulation of goods made with forced labor is being put in place. I explain how these schemes work in detail in our sister article, Supply Chain Due Diligence: The Practicalities of UFLPA and Responsible Supply Chains. The important point here is that schemes like the UFLPA should be treated matter-of-factly, as "how the scheme works and how the authorities enforce it," and are not meant for condemning particular countries or companies. If anything, it is more practical to view them as a means of preparation that lets a legitimately operating company trace its own supply chain and be able to explain that "there is no problem."
• Schemes concerning conflict minerals and cobalt ... the responsible sourcing of the 3TG (tin, tantalum, tungsten, gold) and cobalt I mentioned earlier. These connect directly with the recycled-content and responsible-sourcing items of the battery passport.
• Understanding chemical composition ... it is also essential to correctly grasp the chemicals contained in a battery. The basic document that conveys chemical information is the SDS (Safety Data Sheet). I explain how to read an SDS and its relationship to export control in our sister article, What Is an SDS (Safety Data Sheet)? The Practicalities of Export Control Starting from Chemical Composition. For export control in industries that handle many chemicals, please also see Export Control in the Chemical Industry.
• List-based export controls and verifying counterparties ... the practical work of confirming that a counterparty is not included in a regulated list. The way of thinking behind carefully verifying counterparties through due diligence is covered in detail in End-User Screening and Customer Due Diligence.
• Critical minerals and economic security ... the rare metals and rare earths used in batteries also attract attention in the context of economic security. I touch on related developments in Rare Earths and AI / Robots as well.

Laying these out, what they have in common is this: "to build a supply chain you can protect, a strong supply chain, you need to visualize parts and raw materials one by one, down to the level of the BOM and sub-tier suppliers." Forced-labor risk, the provenance of conflict minerals and cobalt, chemical composition, inclusion in an export-control list, and the recycled content and responsible sourcing the battery passport requires. These look like separate assignments, but in fact they are simply "investigating the same items in the same supply chain from different angles."

The TRAFEED perspective: cross-cutting the enormous investigation with AI, while people make the final call

Let me share how we think about this. Please read the parts about the future outlook and my proposals as the views of the author (Hamamoto).

Once the battery passport is in full swing, companies will find themselves repeating the task of "investigating a single item from multiple angles, tracing it upstream" across a large number of items. Tracing provenance for recycled content, collecting reporting templates for responsible sourcing, checking suppliers for forced-labor risk, and cross-referencing lists for export controls. If there are thousands or tens of thousands of items, it is not realistic to handle this by human labor alone. This is where I believe there is a great deal of room for AI to help.

TRAFEED, which we are developing, is an AI agent that supports export control, economic security, and supply chain due diligence. It aims to investigate across enormous volumes of information and to assist the person in charge in reaching a decision. To introduce it within what we can officially confirm: in a joint demonstration with Okayama University, TRAFEED achieved an AI classification accuracy of over 95 percent in export-control classification (based on our own research). It complies with the Ministry of Economy, Trade and Industry's criteria, supports multiple languages, and operates so that updates to each country's laws are reflected on the same day. Behind it lies a knowledge graph (a database that connects the relationships between pieces of information) with more than 200 million entries. We have also obtained a patent.

That said, I want to emphasize this: AI is, in the end, a tool for speeding up investigation and organization. The final classification decision, and the final judgments about the supply chain, must always be made by your company's export-control officer or the person in charge. This is a premise we do not compromise on. Regulations change year by year, and every case has its own individual circumstances. People take responsibility for the decision based on the material AI has gathered and organized. This division of roles is, I believe, indispensable in compliance practice.

The battery passport is exactly the kind of domain where AI-driven cross-cutting investigation can shine: "investigating a large number of items, upstream, from multiple angles." What TRAFEED aims to do is lower the burden of all this investigation so that the person in charge can spend their time on the "judgment" they should really be concentrating on.

What Japanese companies would do well to prepare now

Finally, from a practical standpoint, let me list what I think is worth starting on now. This too includes the author's views. Because the details of the scheme will firm up through delegated acts and similar instruments going forward, please read this as a sense of direction, on the premise that confirmed information should be checked against the EU's official sources.

1. Work out whether your products could fall within scope ... take stock of whether you sell battery-containing products such as EVs, industrial machinery, or electric light mobility into the EU, or plan to. Note that you can be affected even if you do not make the battery itself, as long as you install one.
2. Get your BOM into a state where it can be broken down to raw materials ... understanding, at the bill-of-materials level, which parts make up which product and from which materials, is the foundation of every kind of supply chain investigation.
3. Build data-exchange relationships with upstream suppliers ... recycled-content and responsible-sourcing information cannot be filled in unless you gather it from upstream. Prepare to make use of standard templates such as the RMI's CMRT and EMRT, deciding who to ask, what to ask, and in which format. That makes it easier to clear several assignments at once.
4. Do not treat the multiple schemes as "separate assignments" ... forced labor, conflict minerals, chemical composition, export controls, and the battery passport. If you run these individually, you end up asking the same supplier similar questions over and over, exhausting both your own organization and your counterparties. A design that bundles investigations of the same item and the same supplier and runs them together, as far as possible, is the realistic one.
5. Build a structure that uses AI to make investigation efficient while people bear the judgment ... the more items a company has, the harder it becomes to run cross-cutting investigation by human labor alone. Make the investigation efficient with AI, and have people make the final call. Building this structure will, I believe, be the key to supply chain response from here on.

The battery passport is certainly a scheme that brings new burdens. But seen another way, it is also an opportunity to show the market that you are "a company that can properly explain its own supply chain." Tracing things back as a stakeholder and being able to explain them: that, I think, is the preparation that will keep you being chosen in an era of expanding regulation.

If you would like to discuss how to proceed in concrete terms, or to work out where to start in your own case, please reach out to the TRAFEED team. We will think through a realistic path together, tailored to your products and organization.

Summary

Let me organize the key points of this article.

• A battery passport is a digital record tied to an individual battery. Through a QR code or similar marking, it lets you check that battery's identity, environmental information, and supply chain information.
• It was introduced by the EU Battery Regulation (Regulation (EU) 2023/1542, in force since August 2023), and the scheduled date for the requirement to take effect is 18 February 2027. However, some of the detailed data items and technical specifications are being set through delegated acts and similar instruments, so the details need to be confirmed against the EU's official information.
• The scope covers EV batteries, industrial batteries with a capacity above 2 kWh, and LMT (light means of transport) batteries.
• The main recorded items are said to include manufacturer, model, and chemical composition, carbon footprint, share of recycled material, performance and durability, state of health (SOH), responsible sourcing, and recycling and disposal information.
• To substantiate recycled content and responsible sourcing, you have to trace sub-tier suppliers back to the origin of raw materials such as cobalt, and this is where the practical work of "seriously tracing your suppliers" begins.
• The battery passport is the forerunner of the EU's Digital Product Passport (DPP) initiative and is expected to spread to other product groups. Japanese companies that sell battery-containing products into the EU can also be affected.
• It shares the same root as schemes such as forced labor (UFLPA), conflict minerals and cobalt, chemical composition (SDS), and export-control lists: the common foundation is "visualizing parts and raw materials one by one at the BOM level." Cross-cutting the enormous investigation efficiently with AI while people make the final call is the approach we take at TRAFEED.

The battery passport is a scheme that, at last, asks a great many companies to make their supply chains visible down to the raw-material level. It may feel daunting, but the essence of what you have to do comes down to "being able to explain what your products are made of and where those materials came from." I would be glad if this article becomes a chance for you to take that first step.

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