Update as of June 2025

With the EU Battery Regulation coming into full force, more questions continue to  emerge In particular, around requirements such as mandatory carbon footprint declarations, the introduction of Battery Passports, and the data that must be reported by various supply chain actors, including automotive OEMs, battery cell and pack producers, raw material suppliers, and others. At Minespider, we’re launching a series of videos and blog posts to answer these questions and provide battery supply chain participants with the latest updates and insights.

Watch our first episode about the recent EU Battery Regulation developments with  Pavlina, Minespider’s Battery expert, and read the blog to learn more about how you can kickstart compliance.

Who’s Affected by the EU Battery Regulation?

Under the EU Battery Regulation, all actors in the battery supply chain are impacted…some more directly than others.

• Directly impacted are those placing batteries on the EU market: original equipment manufacturers (OEMs), energy storage producers, importers, and distributors. These entities bear the brunt of compliance obligations, including reporting through the upcoming battery passport.
• Indirectly impacted stakeholders include the entire upstream and midstream supply chain; cell suppliers, raw material processors, cathode and anode producers, and more. While they may not report directly to authorities, they play a crucial role in supplying the data that their downstream partners need to stay compliant.

Introducing the Battery Passport

The battery passport is at the core of the new regulation. It’s a digital record that follows a battery through its entire lifecycle — from raw material sourcing to end-of-life treatment. It includes:

• General product and technical data
• Sustainability information (carbon footprint, recycled content, etc.)
• Circularity information
• Due diligence details on responsible sourcing (nickel, lithium, conalt and natural graphite and their compounds)
• Dynamic data from the battery management system (BMS)

This regulation ensures greater transparency and enables safer, more circular product development. But achieving this level of traceability is no small task.

Key Milestones and Deadline of the EU Battery Regulation

The regulation officially came into force in August 2023, and compliance deadlines are approaching fast:

February 2025: Carbon Footprint Reporting Begins

Electric vehicle battery producers must report the carbon footprint of their products. This requires detailed input from across the supply chain and should already be underway.

August 2027: Due Diligence Obligations

Originally scheduled for 2025, this requirement was postponed to 2027. It applies to companies with annual net turnover above €150 million and focuses on responsible sourcing, traceability, risk management and human rights.

‍February 2027: Battery Passport Becomes Mandatory

From this date, every Electric Vehicle (EV), industrial battery (with capacity > 2kWh) and Light Means of Transport (LMT) battery placed on the EU market must be accompanied by a battery passport. It will combine static and dynamic data with both public and private access layers. Implementation details on data handling are still pending, but the clock is ticking.

How to Prioritize Your Efforts

For most companies, the main challenge is data coordination—internally and across complex, often opaque supply chains. Many are not vertically integrated, and essential data (like carbon footprint or material origin) may be scattered or missing.

A gap analysis is the best first step. It helps identify:

• Missing or siloed internal data
• Data needed from external suppliers
• System and team alignment gaps

While some companies may have in-house teams to handle this, many benefit from external support. At Minespider, we offer one of the most advanced Battery Passports on the market — including an AI Copilot that can pull data from your PDFs and structure it into Battery Passports - to help you get ahead of these deadlines and avoid costly delays.

Here’s a simple roadmap to get started:

1. Carbon Footprint Calculation
   
   • Urgent: required by February 2025
   • Requires full supply chain visibility
2. Due Diligence Preparation
   
   • Begin now if your company exceeds the €150 million turnover threshold
   • Involves risk mapping and supplier engagement
3. Battery Passport Implementation
   
   • Due by February 2027
   • Start collecting general information, performance, durability, and circularity data now
4. Internal Coordination
   
   • Align departments and data systems early
   • Establish clear ownership of data streams

While some compliance deadlines may seem distant, the groundwork must begin now. Data gaps, supply chain opacity, and internal misalignment can all lead to delays and ultimately, non-compliance. Whether you're an OEM, a battery manufacturer, importer, or battery materials supplier, the best time to act is today.

You can also learn more about the EU Battery Regulation and Minespider Battery Passport here.