The EU Battery Regulation 2023/1542 provides clear requirements for sustainability and transparency in the battery industry. The core element is the mandatory Digital Product Passport (DPP), which provides detailed information along the entire value chain – from raw materials to recycling. Together with Lifecycle Assessment (LCA) data, the DPP enables precise evaluation of the CO₂ footprint and resource utilization.
For German companies, this offers opportunities to secure competitive advantages, achieve ESG goals, and develop new business models. The regulation requires phased implementation, clearly defined data fields, and secure IT integration to ensure transparency and traceability.
The key points:
Now is the right time to adapt processes, launch initial pilot projects, and benefit long-term from the new transparency.
The EU Battery Regulation (EU) 2023/1542 provides a clear legal framework for the Digital Product Passport. The goal is to ensure transparency and traceability along the entire battery supply chain – from production and import to all other actors in the supply chain.
The Digital Product Passport serves as a digital twin of a battery and contains, among other things, data from lifecycle assessment (LCA), which provides a more detailed look at the battery's environmental footprint. In the following, we'll examine the various battery categories, the phased data release, and the additional requirements.
The regulation differentiates between various battery types, with specific requirements for labeling and documentation applying to each category. For some batteries, a comprehensive Digital Product Passport is planned that also integrates LCA data.
This tiered access regulation ensures that transparency is guaranteed on one hand, while business-critical data remains protected on the other.
The introduction of the new regulations occurs gradually to give companies sufficient time to adapt their processes and IT systems. Additional environmental information such as the battery's CO₂ footprint is captured. Performance and wear data should also be regularly updated to precisely represent the battery's condition throughout its entire lifecycle.
This staggered approach makes it easier for companies to efficiently implement the new requirements while pursuing long-term sustainability goals.
Compliance with the regulation is ensured through CE marking. With this, manufacturers confirm that their products meet the requirements. Market surveillance authorities receive extended powers to specifically penalize violations. Notified bodies take over the examination of battery conformity.
Violations face significant fines, and in cases of repeat offenses, market exclusion could even occur. The quality of the provided data is particularly critical: incomplete or erroneous information could permanently damage trust between manufacturers, trading partners, and end consumers.
The regulation thus not only establishes requirements but also provides a clear structure to strengthen transparency and sustainability in the battery supply chain.
The data structure of the Digital Product Passport (DPP) defines which information is captured, organized, and stored – a central component of the EU Battery Regulation.
The DPP is based on a multi-layered electronic data architecture that considers both national and European requirements. The structure is oriented toward existing EU directives such as the Ecodesign Regulation and the Green Deal to enable seamless integration into existing digital systems.
The decentralized architecture allows manufacturers and importers to manage their data independently. Exchange occurs through standardized interfaces, allowing companies to continue using their existing IT systems. This approach reduces dependence on central databases.
A key aspect is interoperability. The DPP must be able to communicate with a variety of systems – from production facilities to logistics software to recycling processes. This technical flexibility creates transparency without disclosing sensitive business information.
The next section will describe the necessary data fields and technical implementation in more detail.
The EU Battery Regulation specifies which information must be contained in the DPP. These data blocks ensure both traceability and compliance with legal requirements.
After defining the data fields, consideration of the technical implementation follows, which enables secure and efficient access to this information.
Through QR code integration, the physical battery is linked to the digital data structure of the DPP. Each battery receives a QR code that enables access to the corresponding data fields. This code must remain permanently readable even under difficult conditions, such as moisture or mechanical stress.
The data architecture distinguishes between three access levels:
To ensure the security of this data, encryption technologies and digital signatures are employed. Each data record is protected by a cryptographic fingerprint that makes manipulation immediately detectable. Changes are logged in an audit trail that documents who edited which data when.
This structured data architecture not only lays the foundation for compliance with legal requirements but also offers German companies the opportunity to measurably implement ESG goals and benefit from them long-term.
Lifecycle Assessment (LCA) plays a key role in the development of the battery industry, particularly in connection with the Digital Product Passport (DPP). While the DPP provides the technical foundation, LCA enables structured evaluation of environmental impacts throughout the entire lifecycle of a product.
With the EU Battery Regulation, documentation of environmental impacts, particularly greenhouse gas emissions, becomes mandatory for industrial batteries. These reports are based on LCA data and form the basis for classifying batteries into emission and performance categories. In Germany, these calculations must be verified by independent third parties to ensure data reliability. Internationally recognized procedures are used that guarantee uniform and transparent methodology.
A central component of these processes is defining system boundaries and precise data requirements.
The regulation requires comprehensive analysis covering all phases of the product lifecycle – from raw material extraction through production to disposal. For processes directly controlled by the battery manufacturer, primary data should be used. However, for upstream processes, secondary data from recognized databases can be used, provided they are current and representative.
Particularly for critical raw materials, it's important to obtain specific data from actual suppliers to conduct well-founded evaluations. For processes where multiple raw materials are mined simultaneously, environmental burdens must be allocated based on market prices. This approach should be regularly reviewed to ensure its accuracy.
Once data requirements are clearly defined, the focus shifts to sustainable implementation along the entire supply chain.
Introducing an LCA system requires systematic data collection across the entire supply chain. Suppliers are obligated to provide relevant environmental data, which is verified through audits, on-site inspections, and the use of specialized LCA software tools. These measures ensure consistent data and enable integration into existing ERP systems. Standardized data preparation makes it easier to extend LCA processes to the entire product portfolio, significantly simplifying compliance with regulatory requirements.
The EU Battery Regulation requires a structured approach that combines organizational processes with technical support. The foundation for this is the already defined DPP data structures and lifecycle assessment (LCA) requirements.
For implementing the Digital Product Passport (DPP) and complying with LCA requirements, clear task distribution within the organization is crucial.
Product Stewards coordinate between different departments and ensure that data collection occurs correctly. They are the interface between development, production, and compliance teams.
Data Governance Leads are responsible for developing and monitoring data quality standards. They establish validation rules, implement audit trails, and ensure that data collection occurs consistently across all product lines. They also regularly review data integrity and initiate corrective measures if deviations occur.
Compliance Officers handle adherence to regulatory requirements and coordinate communication with authorities. They oversee reporting deadlines, organize external audits, and develop strategies to continuously improve compliance processes. They play a central role in preparing for inspections and documenting evidence.
Once roles are clearly defined, technical support through appropriate IT systems is ensured.
Technical infrastructure is the foundation for successful DPP implementation. Data contracts between different systems are essential to ensure seamless integration of ERP, PLM, and MES systems. These contracts regulate data formats, transmission frequencies, and validation requirements for each individual data point.
Standardized APIs and middleware play a key role as they enable consistent data collection and ensure bidirectional communication between enterprise systems and the DPP register. Particularly important is real-time synchronization of master data, production parameters, and supplier information.
ERP systems provide material master data, bills of materials, and production orders that are automatically transferred to the DPP system via connectors. PLM systems contribute design data, specifications, and change histories, while MES systems provide production parameters, quality data, and traceability information.
Companies must ensure that their IT systems not only meet required security standards but also guarantee high availability for regulatory queries.
After IT system integration, testing and gradual scaling follow.
Pre-compliance checks are an indispensable step for successful implementation. These include validation of data formats, verification of LCA report completeness, and simulation of regulatory queries. Automated tests help identify potential gaps early and make corresponding corrections.
A good approach is to start with pilot projects limited to selected product lines. These enable early identification of technical challenges, employee training, and development of best practices. Only then should the solution be extended to the entire product portfolio.
Scaling to the entire product portfolio requires a structured approach. Similar product categories can be grouped and gradually integrated. It's important to keep IT infrastructure capacities in view and adjust them as needed.
Continuous optimization of compliance processes is based on regular audits, stakeholder feedback, and analysis of system performance data. Key Performance Indicators (KPIs) such as data quality, compliance rate, and system availability can measure implementation effectiveness and enable targeted improvements.
DPP and LCA offer companies far more than just compliance fulfillment. This section shows how German companies can benefit both economically and sustainably through these approaches. Concrete advantages and a clear implementation roadmap are presented.
Transparency as competitive advantage: Detailed documentation of the battery supply chain creates trust among customers and investors. Companies can provide precise information about origin, environmental impacts, and recyclability of their products. This openness becomes increasingly important, particularly in public tenders and the B2B sector.
More efficient procurement: Through systematic collection of supplier data, supply chain risks can be identified early. Companies can identify alternative sources and prefer suppliers with better environmental standards. This reduces costs and increases supply security.
Implementing circular economy: With captured system data, optimized battery recycling becomes possible. Companies can develop take-back programs while relying on precise material data to make the recycling process more efficient.
Sustainable product development: LCA data provides development teams with valuable insights that lead to more environmentally friendly designs. Research and development projects can be specifically targeted at areas that have the greatest positive impact on the environment.
Implementing DPP and LCA helps companies fulfill their CSRD reporting obligations. Systematically collected data flows directly into required sustainability reports, significantly reducing the effort for data collection.
EU Taxonomy conformity: With detailed environmental data from LCA, companies can demonstrate that their battery products meet EU Taxonomy requirements. This is particularly important for financing projects and classifying investments as sustainable.
Improved GHG accounting: LCA data makes Scope 3 emissions, which are often difficult to measure, more tangible. Companies can set their climate targets on a scientifically sound basis and precisely track progress.
Stronger investor relations: ESG-oriented investors benefit from improved data availability. Transparent sustainability performance metrics reduce investment risks and can lead to more favorable financing conditions. This creates a solid foundation for strategic growth.
Phase 1 (until December 2025): First, companies should analyze their existing data structures and identify gaps. Integration with existing ERP and PLM systems is essential. At the same time, organizational structures must be created that support compliance implementation.
Phase 2 (January to June 2026): This phase involves technical implementation of DPP interfaces. In parallel, employees are trained and pilot projects with selected product lines begin. It's worth paying special attention to the specific requirements of international supply chains.
Phase 3 (July 2026 to February 2027): Now follows scaling to the entire product portfolio. Automated data validation and quality assurance are introduced. At the same time, integration of data into ESG reporting and strategic planning begins.
Phase 4 (from February 2027): With the DPP obligation for industrial batteries taking effect, all systems must be fully operational. The focus is on continuous optimization and using data for new business opportunities. Companies can use their pioneering role to open new markets and strengthen their position as technology leaders.
The ongoing development of systems will be shaped by practical experience and new regulatory requirements. German companies benefit from a strong industrial environment and proven quality standards. This foundation offers them the opportunity to remain competitive long-term while pursuing sustainable goals.
The introduction of the Digital Product Passport (DPP) and Lifecycle Assessment (LCA) represents an important turning point for the European battery industry. For German companies, this means not only the challenge of meeting new requirements but also the opportunity to take a leading role in sustainable battery technology.
Through the systematic collection of environmental data, a new level of transparency emerges along the entire value chain. Companies that view these requirements not just as regulatory obligations but as strategic opportunities can benefit long-term. This transparency is the foundation for future-ready business models.
Success depends heavily on early and well-structured implementation of the EU Battery Regulation requirements. Phased implementation gives companies sufficient time to adapt their internal systems and qualify employees accordingly.
DPP and LCA also significantly facilitate ESG criteria integration. Companies can more efficiently fulfill their CSRD obligations while scoring points with sustainable investors. The collected data creates trust, minimizes investment risks, and can positively impact financing conditions.
Now is the ideal time to take action: companies should review their existing data structures, initiate first pilot projects, and create the necessary organizational foundations. Those who approach this transformation decisively will not only meet regulatory requirements but also pave the way for sustainable growth within the circular economy.
The Digital Product Passport (DPP) offers German companies the opportunity to stand out in competition. It creates transparency along the entire supply chain and facilitates compliance with the EU Battery Regulation. The result? More trust from consumers and investors – and a strengthened market position.
Additionally, the DPP supports companies in achieving their ESG goals. Through precise documentation of the entire product lifecycle, sustainable practices can be proven, resources used more efficiently, and a contribution to the circular economy made. This not only increases environmental friendliness but also makes companies more attractive to partners and customers.
The compatibility of the Digital Product Passport (DPP) with existing IT systems is ensured through the use of open standards such as ISO/IEC 15459:2015 and prEN 18223. These standards enable seamless integration of the DPP into existing identification and data management systems.
Furthermore, the DPP is designed to work flexibly with other technologies and platforms. This not only ensures more transparency along the supply chain but also facilitates compliance with EU Battery Regulation requirements as well as other regulatory requirements.
To meet EU Battery Regulation requirements by 2027, there are several key steps that companies should address now:
Those who plan and implement these measures in time can not only meet legal requirements but also advance their sustainability goals and gain competitive advantages.