Two EU regulations, one raw-materials dataset.

The Critical Raw Materials Act — Regulation (EU) 2024/1252 — and the battery passport requirement in Regulation (EU) 2023/1542 are separate legal instruments with different mechanisms. But they are pointed at the same materials: lithium, cobalt, nickel, graphite and rare earths. If you are already assembling material declarations, recycled content figures and due-diligence evidence for a battery passport, you are building most of the dataset that the EU's raw-materials agenda runs on.

Last updated: 25 July 2026

In one line: the CRMA does not impose battery passport obligations, but both instruments depend on the same raw-materials evidence — so collect chemistry, recycled content and due-diligence data once, structure it properly, and reuse it.

What the CRMA is, in context

Regulation (EU) 2024/1252 establishes a framework for securing the EU's supply of strategic and critical raw materials. Its concerns are supply resilience — reducing dependency on concentrated sources — alongside monitoring of supply chains and risks, and strengthening circularity so that materials already inside the EU economy are recovered and reused rather than lost.

Batteries sit at the centre of that picture because they concentrate exactly the materials the framework is about. An EV battery is, from a raw-materials perspective, a dense and traceable store of lithium, cobalt, nickel and graphite that will one day need to be recovered. That is why raw-materials policy and battery policy keep converging even though they arrive through different legal doors.

Where the data overlaps

The battery passport requires roughly 110 data points from 18 February 2027, and several of its families are raw-materials data by any other name:

Chemistry and materials composition. What the cells contain, and in what proportion — the base layer for any critical-raw-materials analysis.
Recycled content. How much of the material in the battery came from recovered sources rather than primary extraction.
Supply-chain due diligence. Evidence about where materials originated and how the risks in that chain were assessed and managed.
Circularity information. What happens at end of life, and what can be recovered.
Carbon footprint. Which depends in large part on the extraction and processing of those same materials.

Note the direction of the relationship carefully: the CRMA does not create battery passport obligations. Your passport duty comes from Regulation (EU) 2023/1542. What the two instruments share is an appetite for the same evidence, from the same suppliers, about the same materials.

Why one dataset should serve both

Most manufacturers discover raw-materials data the hard way: a customer sustainability questionnaire, then a battery passport project, then a procurement request about supply risk — each handled separately, each re-asking the same cell supplier the same questions in a slightly different format, each producing a spreadsheet that ages immediately.

The cost of that is not the paperwork. It is that three inconsistent answers now exist about the same battery, and you cannot tell which is right. A single structured material dataset — one authoritative record of composition, origin, recycled content and due-diligence evidence per battery model — is cheaper to maintain and defensible when someone checks. The battery passport gives you a good reason to build it, because that one is legally dated.

What to collect once and reuse

Material composition by cell and by pack, at the granularity your supplier can actually evidence, with the source document attached.
Recycled content figures with their basis of calculation and supporting documentation — not a headline percentage with no provenance.
Origin and due-diligence evidence for the materials in your chain, kept as records rather than assertions.
Supplier declarations, dated and versioned, so you can show what you knew and when.
A single owner and a refresh cycle, because material data changes when suppliers change.

PassPer builds this from documents you already have — spec sheets, certificates and supplier declarations — using AI extraction with human review, then publishes it as a registered, eIDAS-seal-ready battery passport. See how supplier data collection works, or run a free readiness check.

Frequently asked questions

Does the Critical Raw Materials Act require a battery passport?

No. The battery passport obligation comes from Regulation (EU) 2023/1542, which makes it mandatory from 18 February 2027 for EV batteries, LMT batteries and industrial batteries above 2 kWh. The CRMA, Regulation (EU) 2024/1252, is a separate instrument on raw-materials supply, monitoring and circularity — the two overlap in the data they rely on, not in their obligations.

Which materials sit in both conversations?

Principally lithium, cobalt, nickel, graphite and rare earths. These are central to battery chemistry and to the EU's strategic and critical raw-materials concerns, which is why composition, recycled content and due-diligence data serve both agendas.

Can we reuse battery passport data for customer sustainability questionnaires?

That is exactly the point of structuring it once. Composition, recycled content, due diligence and carbon footprint data assembled for a passport answers most raw-materials and sustainability questions — provided it is stored as structured, sourced records rather than one-off spreadsheets.

Our suppliers will not give us material composition data. Now what?

Start from documents they have already issued — spec sheets, certificates of analysis, declarations of conformity — which usually contain more than a direct request extracts. PassPer reads those documents and pulls the fields out, with human review, so the gap you have to chase is much smaller.

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