The digital battery passport becomes mandatory on 18 February 2027 for EV batteries, LMT batteries and industrial batteries over 2 kWh. The passport contains more than 90 data points on the battery's identity, materials, carbon footprint, performance, due diligence and end of life, and the data must be available digitally via a QR code on the battery.

For most companies, the challenge is not understanding the requirement, but getting started. This article gives a step-by-step preparation plan.

Step 1: Clarify which products are covered

Not all batteries require a battery passport. Start by mapping your product portfolio against the regulation's five categories and identify exactly which products are covered.

The battery passport applies to:

  • EV batteries (all)
  • LMT batteries (all, regardless of capacity)
  • Industrial batteries over 2 kWh

Portable batteries and SLI batteries are not covered by the passport requirement, but have other labelling obligations.

Note that any battery over 5 kg that cannot be classified as LMT, EV or SLI is automatically regarded as an industrial battery. Many special batteries for niche machinery will therefore require a passport if they exceed 2 kWh.

Responsibility for creating the battery passport lies with the economic operator placing the battery on the EU market, typically the manufacturer for EU-based products or the importer for products from third countries.

Step 2: Do a gap analysis of your data

The battery passport requires more than 90 data points structured according to the DIN DKE SPEC 99100 standard. The data points are divided into seven clusters:

Most companies have some of this data spread across systems. Typically:

  • Product identification and batch data sit in the ERP system
  • Carbon footprint calculations sit in separate LCA studies
  • Supplier-specific material data sits in PDFs and emails
  • Test results sit in quality systems
  • Due diligence reports sit with the compliance department

The biggest data gaps are typically:

  • Supplier-specific CO₂ data (company-specific rather than industry averages)
  • Material composition at component level (cathode, anode, electrolyte)
  • Documentation of recycled content
  • Dynamic data such as State of Health from the battery management system (BMS)

Mapping and collecting the necessary data typically takes 12-18 months, especially because supplier data often has to be obtained from several tiers of the supply chain.

Step 3: Establish internal governance

The battery passport is not an IT project. It is a cross-functional task involving compliance, sustainability, IT, purchasing and product development. Companies that let one department run it alone typically end up with solutions that cannot scale.

Five roles should be defined early:

  • Data Steward maintains data quality, defines standards and manages access rights.
  • Sustainability Manager collects LCA data for the carbon footprint and monitors due diligence.
  • IT/Systems Architect integrates the battery passport with ERP, PLM and BMS.
  • Compliance Officer monitors regulatory changes and ensures timely third-party verification.
  • Data Owner (management) is the strategic decision-maker responsible for budget and risk exposure.

Management involvement is crucial. The battery passport must be treated as a strategic prerequisite for continued market access, not as an administrative task for the sustainability department.

Step 4: Start the supplier dialogue

Most of the data in a battery passport comes from suppliers: cell manufacturers, chemical suppliers and ultimately mining companies. The supplier dialogue is the most time-consuming part of the preparation.

Start by mapping the supply chain from raw material extraction (Tier 4) to component manufacturing (Tier 1). Identify which suppliers already have ESG data, and where capacity is lacking.

The typical barriers are:

  • Suppliers' unwillingness or inability to share detailed data
  • Concerns about intellectual property
  • Geographical or cultural distance that makes the dialogue harder

Three approaches are recommended:

  • Update supplier agreements with specific data sharing clauses that oblige the supplier to provide verified data
  • Set up cloud-based supplier portals where suppliers can upload certificates and emissions data directly
  • Take part in industry initiatives such as Catena-X, the Battery Pass consortium or the Global Battery Alliance to share knowledge and standardise data exchange

The battery passport's three-tier access model (public, professional, authorities) protects trade secrets: this can be an important argument in the dialogue with suppliers who fear exposing IP.

Step 5: Choose the technical infrastructure

The battery passport sets three technical requirements:

  • Interoperability based on open standards
  • A decentralised data architecture (the manufacturer hosts the data, the EU keeps a central register of identifiers)
  • Unique identification via a QR code with GS1 Digital Link and ISO/IEC 15459

The technical platform must be able to handle both static data (material composition, carbon footprint) and dynamic data (State of Health, cycle history) from the battery's BMS. For EV and large industrial batteries, an active data connection to the battery passport is typically required.

The platform must integrate with the company's existing systems: ERP for product data and batch numbers, PLM for design specifications and LCA software for the carbon footprint. Data must be exchangeable in JSON-LD format, which is the recommended format for machine-readable data exchange.

Companies should choose a DPP-as-a-Service solution or build in-house, but in both cases the system must support role-based access control, encryption and backup for at least 10 years.

Step 6: Run a pilot project

Before full rollout, the company should create a complete battery passport for one product line. The pilot reveals data gaps, process gaps and technical bottlenecks before they become critical.

Invite a notified body to review the pilot data. Verification of carbon footprint, due diligence and recycled content are mandatory elements, and early contact with a notified body ensures that the documentation meets audit standards. Intertek is among the first to be accredited as a notified body under the Battery Regulation.

Recommended timeline: 18 months

  • Months 1-3: Discovery and strategy. Secure management backing, set up a cross-functional team, clarify the scope and carry out a gap analysis of existing data.

  • Months 4-8: Infrastructure and supplier onboarding. Choose a battery passport platform, start collecting data from the most important suppliers and test extraction of dynamic data from the BMS.

  • Months 9-12: Pilot project and validation. Create a complete battery passport for one product line, have a notified body review the documentation and adjust processes based on the experience.

  • Months 13-18: Scaling and go-live. Implement the battery passport on all covered models, automate the data flow from ERP and supplier portals and make sure every product leaving the factory after 18 February 2027 has a valid QR code and an active battery passport.

This means that companies that had not started by mid-2025 are already behind. Starting in 2026 leaves less than 12 months to the deadline, too short to obtain supplier data and run a meaningful pilot.

The five most common pitfalls

  • Manual data management. Trying to handle 90+ data points for thousands of batteries in spreadsheets leads to errors, inconsistency and audit problems. The battery passport requires a digital platform.

  • Silo thinking. Letting the compliance department run the project without close involvement of IT and product development results in solutions that cannot scale.

  • Underestimating data quality. Assuming that all supplier data is correct without validation. Master data in ERP systems is often incomplete or outdated.

  • Waiting for the final acts. The basic requirements are known. Companies that wait for the last implementing acts to be adopted lose preparation time they cannot make up.

  • Late supplier engagement. Onboarding suppliers and establishing reliable LCA calculations takes longer than expected, especially in global supply chains with several tiers.

Summary

Preparing for the battery passport is an 18-month effort that requires cross-functional organisation, a structured supplier dialogue and a digital platform to host and share data.

Most companies already have some of the necessary data: the challenge is to collect it, validate it and make it available in the format the regulation requires.

Start by clarifying the scope, doing a gap analysis and starting the supplier dialogue. These are the three activities that take the longest and provide the most value early in the process.

Syntakk is built to structure and maintain the battery passport's data points: from template to finished passport, with an automatic QR code and a compliance overview.