The battery passport is mostly discussed as a data exercise: chemistry, carbon footprint, performance. But one block of it reaches deep into your supply chain. The Batteries Regulation requires larger operators to run a due-diligence policy covering the risks around cobalt, lithium, nickel and natural graphite — based on OECD guidance and verified by a third party — and the passport is where evidence of that work becomes visible. Here is what that involves in practice.
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The due-diligence obligations centre on the raw materials with the highest documented social and environmental risks in battery supply chains: cobalt, lithium, nickel and natural graphite. These are the materials where extraction and processing are concentrated in regions with known risks — child labour, unsafe artisanal mining, community displacement, water stress, pollution — and where a European buyer several tiers downstream has historically had little visibility.
The regulation’s answer is not to ban sources but to require operators to know their chain: identify where these materials come from, assess the risks, and act on what they find. The approach is deliberately built on the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals, so companies already running conflict-minerals programmes will recognise the structure.
This is a management system, not a document. In outline, an OECD-guidance-based policy means:
The obligation targets larger economic operators placing batteries on the EU market; the regulation carves out smaller companies below turnover-based thresholds, so the smallest importers and producers are not expected to run a full verified programme. Where exactly your company falls depends on your size and structure — check the thresholds against your own figures rather than assuming either way.
Two practical caveats. First, even operators below the thresholds will feel the obligation indirectly: larger customers must map their chains, and will push questionnaires and contract clauses down to you. Second, being out of scope for due diligence does not exempt a battery from the passport itself — from 18 February 2027, EV batteries, LMT batteries and industrial batteries above 2 kWh need a passport regardless.
The battery passport’s roughly 110+ data points include a due-diligence block: information about the responsible-sourcing policy and reporting for the battery’s supply chain sits alongside chemistry, carbon footprint and performance data. That makes due diligence visible — to authorities, customers and anyone scanning the QR code.
The hard part is evidence collection: policies, audit summaries, smelter lists and supplier declarations live in dozens of documents across your chain, mostly held by suppliers. This is where PassPer earns its keep — its AI extraction reads the documents your suppliers already produce (declarations, certificates, audit reports) and maps them to the passport’s data points, with human review before anything is published and eIDAS qualified sealing (QTSP onboarding in its final stage) on the result. Start requesting supplier documentation now; it is reliably the slowest step.
Count down to 18 February 2027 and work backwards to when each step has to start for your SKU count.
Take the 2-minute readiness check, watch the 10-minute interactive walkthrough, or download the full 2026 compliance guide. No account needed.