The EU battery passport promises greater transparency and traceability, but its success will depend on closing key gaps around legacy batteries, compliance costs and unfinished technical rules. Without practical support for smaller dismantlers, repairers and second-life operators, the system risks pushing viable batteries out of reuse and into premature recycling.
Hidde Huijssoon, Circular Economy Sourcing Lead at Swiss second-life battery storage company modual AG, examines the EU’s forthcoming battery passport requirements and the challenges they could create for dismantlers, repairers and second-life operators. He argues that while greater battery transparency is essential, gaps around legacy batteries, compliance costs and unfinished technical rules could undermine the passport’s circular economy ambitions.
From 18 February 2027, no battery above 2 kWh can be placed on the EU market without a digital battery passport. Each battery is expected to carry a QR code, printed or engraved, that links to a unique identifier and an electronic record of roughly eighty data points: chemistry, rated capacity, carbon footprint, supply-chain due diligence, performance and durability data, with multiple data points over time, showing the battery’s history. Some information is open to anyone who scans the code, where more sensitive data is reserved for regulators and for actors with a legitimate interest, such as repairers, second-life operators, and recyclers.
Responsibility sits with the economic operator placing the battery on the market, through the Extended Producer Responsibility (EPR). That party must create the passport, host the data behind it, and keep it accurate and up to date for as long as the obligation runs. The definition of “placing on the market” also includes the situation where a battery is repurposed or remanufactured. Whoever gives a pack its second life becomes the economic operator, with the full passport obligation attached.
The Compliance Challenge for Smaller Operators
That last point is where problems begin, because the regulation was written as if economic operators were large manufacturers. Often they are not. Used EV batteries surface first at garages and dismantlers, and the regulation offers these businesses no exemption and no lighter regime. Compliance costs are largely fixed: the same data systems, the same hosting obligation, whether a workshop handles ten packs a year or ten thousand. A large OEM absorbs that overhead without noticing. A five-person dismantler cannot. The likely result is not that small actors cannot comply, but that batteries drift into informal channels the passport was designed to eliminate. Transparency legislation that prices out the actors closest to the batteries produces less transparency, not more.
The Missing Passport for Today’s EV Batteries
The second gap is temporal. The passport applies only to batteries placed on the market from February 2027 onward. Nothing already on the road will ever have one. That would be a footnote if second-life markets ran on new batteries, but they run on old ones: the packs feeding reuse and repurposing over the next decade are precisely the pre-2027 generation the regulation leaves undocumented. Assessing those packs is possible today through per-pack testing, but that approach does not scale. When undocumented packs start arriving in the millions, the constraint will not be the difficulty of grading them. The problem will be that proving a good pack’s remaining value costs more than the pack is worth. Healthy batteries will be recycled early or lost entirely, which is the opposite of the regulation’s intent.
A third problem is not immediately noticeable but makes the other two worse: the rules themselves aren’t finished yet. The EU is still filling in the technical details through follow-up legislation, and more requirements are expected over time. This means companies building passport systems today are aiming at a moving target. The smaller the company, the harder it is to afford building things twice.
Making the Battery Passport Work
None of this argues against the passport. It argues for finishing it. Small actors need a realistic route in: shared passport infrastructure or accredited service providers that spread fixed costs across many operators, and a simplified compliance tier scaled to volume. The market’s current volumes need a bridge. For example, a retrofit passport for pre-2027 packs, plus standardized access to the state-of-health data OEMs already collect, so second-life value can be proven cheaply. The remaining technical requirements also need to be published early enough that businesses can build once rather than twice.
The battery passport is the right idea. Whether it works will depend on the actors and data transparency.
Further Reading on Auto Recycling World
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BMW’s Vision for a Circular Battery Future
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BLC Puts Battery Value Before Recycling
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IDEA Project: Data Sharing for Circular End-of-Life EV Batteries
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Embracing or Evading End-of-Life EVs
