The battery passport and how to solve it

If that’s you and you haven’t started, then you’re late. You’re very late. But you’re not alone. So, what do you need to know and how do you solve this?

What is a battery passport?

The passport itself is a digital page that shows the user a series of sustainability and safety-related information about that particular battery. This includes things like where the battery has come from, what raw materials are in it and its carbon footprint.

A QR-code should be on the battery that leads to the battery passport. The link should follow a standard such as GS1 Digital Link so that it’s easy to manage. This all stems from the EU Battery Regulation (Regulation EU 2023/1542) that came into force in August 2023 and fully replaced the previous Battery Directive 2006/66/EC.

So what exactly do I need to show in my passport?

The short version

1. A unique identifier
2. The carbon footprint of the battery
3. The raw materials used and where they come from
4. The amount of recycled materials used
5. Where the battery was manufactured
6. The existing state of health of the individual battery
7. Clear instructions on how to repair the battery
8. Where to recycle the battery at end of life

The explanation So, every passport needs a unique identifier. In other words, every passport will be unique to that particular battery. The information in every individual passport will need to be modified as the years go on to outline the changing health of the battery or what modifications have been done to it. This is a challenge in itself and differs from digital product passports for the clothing industry for example where item-level passports are not required but only optional.

The carbon footprint of the battery over its entire lifecycle from extracting the raw materials to manufacturing and transport and over its expected service life. Eventually, you’ll need to show that your battery doesn’t exceed certain carbon emissions limits but what those limits are hasn’t been set yet.

The raw materials used and the percentages of each raw material will also be needed. On top of that, you’ll need to show the amount of recycled raw materials. So, if your battery is 60% lead, then you will need that information but you will also need to show how much of that lead is from recycled materials (older batteries that have been recovered). You’ll also need to show what kind of hazardous substances are used in your battery. You or your suppliers will probably already have a REACH certificate outlining this. On top of that you’ll need to show where these raw materials have come from.

Every battery passport should also show where the battery was manufactured. In other words, the production plant itself should be in the passport. A specific requirement for battery passports that does not exist for other DPP’s is a ‘state of health’ indication as well as the expected lifetime of the battery. Updates will need to be made to individual batteries outlining how many times they have been recharged for example, how much time is left until the battery is no longer functional but even if there have been any abnormal events occurring to the battery. So, error logs should be provided. This is all well and good if your battery is already connected to the Internet but for purely analogue batteries, there are a lot of questions, as of yet unanswered, as to how to provide this information in a good way.

Each battery passport will then need to show how the battery can be repaired and then recycled. This could be as simple as directing them to the nearest authorised repair service, but it could also provide information on self-repair. When it comes to recycling, then the passport should show where a user can go to safely leave back their battery so that its raw materials can be re-used again.

How do I solve it? Is there a quick fix?

The short version

1. Talk to a compliance specialist and find out what you need to report to make sure you’re compliant
2. Find out what information you have and don’t have and start filling the gaps
3. Do a pilot on a flagship product. Talk to someone like us at Kolla and create the structures and design for a prototype passport
4. Work with the information you have and start there. Don’t wait to have everything in place to start.
5. Fill in the gaps as you get them and add to your existing passport

The explanation

So the quickest way to get this solved is to start talking to a compliance advisor who has already cut through the bureaucracy and can guide you in the right direction. Petra Färm runs https://georgiamolly.com/ and is a self-confessed compliance nerd, who has read all the relevant documents so you don’t have to. She insists though that you can’t let everything else wait until you have gathered all the relevant information. “You need to split the process into two strands. One is gathering the right content or data that is required by law. So, you need to understand what is required and then find that information. But you need to simultaneously start the actual process of creating passports; generating QR-codes, using the GS1 Digital Link structure, fetching information from databases to the passport and creating a final digital page that is attractive and easy to understand.

You won’t have all the information required from the start but you can’t afford to wait for it before getting the process for creating passports in place.”

At Kolla, we always recommend a pilot to start with as this will also help you see what you have and what you don’t have in terms of information required for the passport. But we also look at what other information could be in the passport that would add value to the user.

“Remember that a passport is a new communications touchpoint,” says Colm O’Callaghan, managing director of Kolla. “Even if it’s a battery, it still belongs to your brand and you should still provide a brand experience for anyone who scans it. You want to make life easy for your customer and you want to give them a good impression. This is a great opportunity to both inform but also inspire your audience.”

Get the key stakeholders in the room

Creating a good battery passport then means making sure the final product is aligned with the brand and creates a brand experience. In this way, the passport can be more than a compliance hurdle to overcome but also a way of building brand loyalty. This in itself highlights one of the challenges required for any digital product passport.

“The biggest challenge for companies creating passports is actually getting the right people in the room and on board with what’s going on,” says Petra Färm. “Battery passports are definitely a compliance question, but it’s also an IT issue. It’s also a question for the product team, for supply chain, sourcing, sustainability, marketing and branding. Regardless of a company’s size, getting everyone involved at the right time and having one clear owner of the passport project is a key success factor.”

Another challenge is that the goalposts keep changing. The rules required for the battery passport are evolving all the time. This causes a lot of concern amongst brands trying to do the right thing but this where it’s important to have a provider and specialist on your side, keeping track of the latest developments.

Don’t forget the upside

In all of this work, don’t forget that there’s a reason for doing this. For consumers, it gives them transparency and helps them extend the lifecycle of products as well helps them recycle every battery safely. For brands, there are two major benefits. The first one is that the work required for this passport will help you understand your supply chain in much more detail and learn more about where your stuff actually comes from. “I have worked with several companies that have mentioned that this process has given them very valuable insights and helped them make their products in a better and more efficient way. Gathering all this knowledge will help brands make better decisions,” says Petra Färm

The other benefit is on the branding and marketing side, as mentioned above. “Every time someone scans a passport, it means they are interested in your brand. Give them a reason to stay interested,” says Colm O’Callaghan.

What else should I read?

The ‘BatteryPass ready’ project provides a pretty structured and accessible analysis of the data required. There are also several pdf’s you can download from there to support you. https://thebatterypass.eu/battery-pass-ready/resources/

Read the EU’s official pages on the topic: https://environment.ec.europa.eu/topics/waste-and-recycling/batteries_en

Talk to us. If you need a starting point, just give us a call and we’ll either help you directly or point you in the right direction.