Battery passport data for a cell manufacturer under the EU Batteries Regulation

The question

New contracts with European carmakers depended on data the client’s systems could not produce. Regulation (EU) 2023/1542 requires carbon footprint declarations (Article 7), recycled-content documentation (Article 8) and, from 18 February 2027, a battery passport (Article 77) for electric-vehicle batteries. The existing ERP held none of this data at the level of detail the carmakers asked for.

What we did

• A gap assessment of the regulation against the client’s data, focused on the carbon footprint declaration and recycled-content documentation.
• Functional specifications for the passport data layer between the manufacturing execution system (MES) and the carmakers’ data exchange. The design follows Article 78 of the regulation, which sets requirements for interoperability, access rights and data storage without prescribing a technology.
• A chain-of-custody model mapping suppliers from mine to refinery for cobalt, lithium and nickel, in line with the OECD Due Diligence Guidance for minerals.
• Technical liaison between the client’s research and development headquarters and the carmakers’ procurement teams to validate the data-exchange protocols.

What changed

• Regulatory readiness demonstrated to European carmakers, supporting multi-billion-euro supply agreements.
• An auditable upstream data model for cobalt, lithium and nickel, which lowers exposure to conflict-minerals litigation.
• A position with carmakers as a passport-ready partner, ahead of regional competitors.

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