Beginning February 18, 2027, no electric vehicle, industrial or light means of transport (LMT) battery can go on the European Union market without a digital battery passport. The rule calls for data that runs several tiers up the supply chain, placing the responsibility for compliance squarely on procurement.
The hardest entries under the new requirement aren’t created in your own plant but at your cell suppliers, module makers and their upstream vendors. The carbon footprint, the share of recycled raw materials and origin of the critical materials can only be gathered if the chain plays along. Supplier management is where it’s decided whether the passport is ready by the deadline.
The legal basis is EU Battery Regulation 2023/1542; the catalogue of mandatory data sits in Annex XIII, detailed technically in DIN DKE SPEC 99100. It covers traction batteries from electric vehicles, industrial batteries above 2 kWh, and LMT batteries. Device batteries from a laptop or smartphone are not included.
The passport splits into two groups. One the company already knows itself, covering technical data and conformity. The other hangs off the supply chain: the carbon value of the cells, recycled-content share, and due-diligence data on cobalt, lithium, nickel and graphite. That second group is the real work.
What the Chain Has to Deliver Upstream
Three kinds of data make the difference. First is the carbon footprint, calculated by a prescribed method across the battery’s life phases and driven largely by cell production. Second is the share of recycled raw materials, which only the cell or material supplier can credibly document. Third is due diligence, meaning the origin and sourcing routes of the critical raw materials.
For all of this, the bottleneck is whether suppliers respond. A company that already knows which supplier can deliver which figure, and at what quality, has the passport under control. One that finds out just before the deadline joins the queue, because by then everyone is asking the same vendors at once.
For supply chain leaders, the real hurdle lies in the depth of the chain. A cell’s carbon value is created in cell manufacturing; the origin of the lithium or cobalt sits with the mine and the refinery, two or three tiers above your own procurement. Ask only your tier-one supplier and you get, at best, figures passed down the line, at worst a shrug.
In practice, the requirement has to be pushed contractually up the chain. The direct supplier binds its own upstream vendor, and so on to the source. None of this is fundamentally new; the EU due-diligence rules already demand a look into the upstream chain. The battery passport only makes visible how far that look has to reach, and it makes it auditable.
Three strategic misconceptions need to be avoided:
- “Compliance will handle it.” The core data lives in procurement and with the suppliers. Compliance can only assemble what sourcing brings in.
- “Our cell supplier will include it.” Maybe, but only if it’s contractually agreed and asked for early. Without a clear requirement, the figure doesn’t arrive on its own.
- “We’ll sort it out just before launch.” The carbon balance and recycled-content proof need lead time up the chain, often several months. Late means expensive, or not at all.
From Mandatory Field to Sourcing Advantage
The passport forces companies to know their suppliers better than many do today. That involves effort, but also leverage. A company that cleanly captures the origin and carbon data of its cells also sees the risks in its chain, from concentration at single sources to suppliers that can’t deliver on sustainability data. That transparency is exactly what procurement and risk leaders are after anyway.
In concrete terms, it becomes sourcing work with familiar tools. The passport data can feed the supplier scorecard, as a criterion alongside price, quality and on-time delivery. A clause in the framework agreement that makes the carbon balance and recycled-content proof binding costs little today and saves weeks later. And a buyer with several sources for the same cell quickly sees which of them can deliver and which cannot.
On top of that comes market pressure. Buyers in the EU need the passport data themselves in order to resell with legal certainty. A maker who supplies it early and in full becomes a preferred supplier, while others are still combing through their own chain. The passport becomes a criterion by which the EU buys.
You don’t need an IT platform of your own. The regulation describes the what and the how of access, not the technology behind it. In practice, it comes down to a classic make-or-buy decision, and for most makers the answer is buy: a service maps the fields of DIN DKE SPEC 99100, issues the identifier and QR code, and manages the tiered access rights. The cost sits in the time the sourcing team needs to collect the missing figures from suppliers and keep them current.
A Realistic Roadmap to Compliance
Four steps lead reliably to the goal, and two of them belong in 2026. It starts with the question of scope: above 2 kWh, EV or LMT, and which unit in the company places the battery on the market? Next comes a stock take of supplier data, matching Annex XIII against what procurement and quality assurance already have on file. The third step is the decisive and slowest one: pin the suppliers down, contractually and on a timeline, for the missing figures, from the carbon balance to recycled-content proof. Only at the end comes generating and linking the passport itself.
The battery passport often reads as a regulatory burden, just another rule from Brussels. In practice it’s something more useful — a data foundation across your own supply chain that you’ll have to assemble sooner or later anyway, the moment that customers, recyclers or market surveillance start asking. In addition to having their papers in order at the deadline, the companies that start now will know their chain better than the competitors that are still searching.
Niels van Veen is founder and chief executive officer of DPP Hero in Hanover, Germany.
