The EU Battery Passport is mandatory from 18 February 2027. The supplier data takes longest, so start there.
Regulation (EU) 2023/1542 requires a digital passport for every electric-vehicle, light-means-of-transport and industrial battery above 2 kWh placed on the EU market from 18 February 2027. If your packs or cells end up in Europe, a buyer's data questionnaire is already on its way. This page sets out who carries the obligation, what the passport must contain, where that data sits in a plant today, and what to request from cell suppliers this quarter.
ResponsibleOperator placing the battery on the EU market
AccessQR code on the battery
PredCo is an industrial AI company headquartered in New Delhi that prepares battery pack makers, cell suppliers and Tier-1s in India and the USA for the EU Battery Passport. It collects the passport data fields from PLM, ERP, MES and supplier records, attaches the evidence, and extends the same IMDS automation workflow.
In short
The EU battery passport is a structured, machine-readable record for each battery, reachable through a QR code on the battery itself. Under the EU Battery Regulation it is mandatory from 18 February 2027 for electric-vehicle batteries, light-means-of-transport (LMT) batteries and industrial batteries with a capacity above 2 kWh placed on the EU market. The economic operator placing the battery on the market is responsible for creating it and keeping it accurate. It carries the manufacturer's identity, the battery's carbon footprint, its materials and recycled content, supply-chain due-diligence information and performance and durability data. Most of that data already exists in a pack maker's PLM, ERP, MES and test systems, and in cell suppliers' records; the work is collecting it in one place with evidence attached.
01 / Who is responsible
Who carries the obligation: whoever places the battery on the EU market.
The regulation attaches the passport to the economic operator placing the battery on the market, not to whoever made the cells. In practice that is one of three positions.
01
You export finished packs to an EU customer
If you, or your EU subsidiary, place the pack on the market, the passport is yours to create. Your EU customer will ask for it as a condition of supply, usually with a data questionnaire first.
02
Your pack goes into a vehicle or machine assembled in the EU
The OEM or integrator placing the finished product on the market is responsible, and will push the passport data requirements down to you contractually. Expect the same field list, with your name as the supplier of record.
03
You supply cells or modules to a pack maker
You are not the responsible operator, but the pack maker cannot complete the passport without your composition, carbon-footprint, recycled-content and due-diligence data. The requests arrive from several customers at once, each in a different template.
02 / Where you operate
Where you are, and what the EU will ask of you.
US
For US pack makers and exporters
Regulation (EU) 2023/1542 applies to every EV, LMT and industrial battery above 2 kWh placed on the EU market, wherever it was made. For a US manufacturer the responsible economic operator is usually the EU importer or the EU OEM that fits the battery, and that operator will pass the passport data request down the supply chain to you, with a deadline before 18 February 2027.
The fields a US exporter will be asked for first are the ones only it can supply: carbon footprint per battery model and plant, recycled-content shares for cobalt, lead, lithium and nickel, and due-diligence evidence for cobalt, natural graphite, lithium and nickel. PredCo collects them from PLM, ERP, MES and supplier records; deployment can be cloud, hybrid or on-prem in the US.
IN
For Indian cell, module and pack makers
Indian suppliers to EU OEMs and to Indian OEMs that export to the EU are already receiving passport data questionnaires. The responsible operator sits in the EU, but the data it needs (materials, recycled content, carbon footprint, test and durability results) exists only in the supplier's own PLM, ERP, MES and test systems, and in its cell suppliers' records.
PredCo's IMDS automation already builds and checks material declarations for Indian automotive suppliers; the passport record uses the same engine and the same connectors, and can run on-prem so plant data stays in India.
03 / What the passport contains
What a passport must contain, and which plant system already holds it.
The regulation groups the data into a handful of categories. None of it is new information; it is information that has never been collected in one record per battery.
Battery and manufacturer identity
Manufacturer identity, battery model and identifier, manufacturing site and date, battery category, weight and chemistry.Where it lives todayERP material master · MES batch and serial records · PLM
Carbon footprint
A declaration of the battery's carbon footprint per model and manufacturing plant, by life-cycle stage, with the method and the supporting study.Where it lives todayEnergy meters and SCADA · purchased-electricity contracts · supplier product carbon footprints · ERP purchasing
Materials, substances and recycled content
Critical raw materials and hazardous substances present, and the share of recycled cobalt, lead, lithium and nickel recovered from waste.Where it lives todayPLM bill of materials · supplier material declarations (the same evidence base as IMDS) · recycler certificates
Supply-chain due diligence
The due-diligence policy and the third-party verification report on the sourcing of cobalt, natural graphite, lithium and nickel.Where it lives todayProcurement and ERP vendor records · audit reports and policy documents held by compliance
Performance and durability
Rated capacity, power, round-trip efficiency, expected lifetime and the parameters needed to determine state of health as the battery ages.Where it lives todayEnd-of-line test systems · QMS and LIMS records · battery management system data definitions
Circularity and safety
Dismantling and safety information, spare-part availability, and conformity documentation.Where it lives todayPLM service documentation · technical file and declarations of conformity
04 / Cell-supplier data request
What to ask every cell and module supplier for, this quarter.
Third-party data is the long pole. A request sent in October gets answered before the deadline; one sent in January competes with every other customer's request. One structured template per supplier, not an email thread.
Cell chemistry and full material composition, with the hazardous and critical raw materials declared by substance, in the same structured form you already require for IMDS.
Recycled-content shares for cobalt, lead, lithium and nickel, with the certificates or mass-balance evidence behind each figure.
A product carbon footprint per cell model and production site, stating the method, the system boundary and the electricity-mix assumption.
The supplier's due-diligence policy for cobalt, natural graphite, lithium and nickel, and the most recent third-party verification report.
Rated capacity, cycle-life and calendar-ageing test data for the cell model, with test conditions.
Manufacturing site, production date format and the identifier scheme printed on the cell or module, so each pack can be traced to its cells.
A named contact and an agreed update cadence, because the passport has to stay accurate for the life of the battery.
05 / Before 18 February 2027
Four months, in order.
1
Decide the operator for each export flow
List every route by which your batteries reach the EU market and name who places them on it. That decides whose passport it is and what your customers will ask of you.
2
Map the field list to your systems
For each passport category, record which system holds the value today, who owns it, and where there is no source at all. Gaps are usually carbon footprint and recycled content.
3
Send the supplier requests
One template, every cell and module supplier, with a return date. Track responses as structured data, not as attachments.
4
Assemble and validate per battery model
Build the record from the source systems, check completeness and unit consistency, and keep the lineage from each value back to its evidence.
5
Prepare for the technical format
The Commission's implementing acts on the passport's technical design and the data registry were still pending in October 2026. Keep the data model field-based so it can be exported in whichever format is finalised.
06 / How PredCo does it
The same engine that builds and checks IMDS declarations builds the passport record.
PredCo's compliance automation reads the bill of materials from PLM, the material master from ERP and the supplier declarations that arrive as PDFs and spreadsheets, validates them against the rulebook and keeps the evidence trail. The battery passport asks for the same material data plus carbon, due-diligence and performance fields, from the same systems and the same suppliers. It is an extension of the record, not a new project.
Reads PLM, ERP, MES and test-system data where it already sits; nothing is migrated.
Structures supplier declarations, carbon-footprint statements and audit reports into fields with the source page retained.
Validates completeness, units and mass balance per battery model before anything is sent to a customer or a registry.
Keeps every value linked to its evidence, so a customer or auditor can see how a figure was produced.
Exports per battery in whichever technical format the implementing acts settle on, and keeps the record current as suppliers update.
Runs on your own servers or air-gapped if your security review requires it. PredCo and Panscience Innovations hold SOC 2.
PredCo's IMDS automation runs with automotive Tier-1 suppliers in India under confidentiality agreements. Battery passport work is scoped as an extension of that record; we do not name customers.
Talk to our compliance team
Tell us what reaches the EU, and from which suppliers.
Which batteries or cells go to Europe, and whether you or your customer places them on the market.
A compliance engineer replies within one working day with the field list mapped to your systems.
We walk through a supplier data request on one of your actual cell models.
The economic operator placing the battery on the EU market. If you or your EU entity imports and sells the pack, that is you. If your pack is built into a vehicle or machine assembled in the EU, the OEM or integrator placing the finished product on the market is responsible, and will require the data from you by contract.
In most cases, yes. The regulation covers light-means-of-transport (LMT) batteries, which include batteries for electric two- and three-wheelers up to 25 kg, and electric-vehicle batteries, which include heavier traction batteries for type-approved L-category vehicles. If the battery reaches the EU market, check which category it falls in; both need a passport from 18 February 2027.
The 18 February 2027 date is the one in the regulation as adopted. As of October 2026 the Commission's implementing acts were behind schedule and parts of the industry were lobbying for a stop-the-clock, so a delay is possible. EU buyers are sending data questionnaires now, and supplier data takes months to collect either way.
With one structured request template per supplier, sent early, covering composition, recycled content, carbon footprint, due-diligence documents and performance test data, and tracked as fields rather than as attachments. PredCo reads the returned PDFs and spreadsheets into structured records, flags gaps, and keeps each value linked to the supplier document it came from.
Manufacturer and battery identity, carbon footprint, materials and hazardous substances, recycled content for cobalt, lead, lithium and nickel, supply-chain due-diligence information, performance and durability data, and dismantling and safety information. Some fields are public, others are restricted to persons with a legitimate interest, such as repairers, recyclers and authorities. It is accessed through a QR code on the battery.
Identity and batch data from ERP and MES, composition from the PLM bill of materials and supplier declarations, carbon footprint from energy meters, electricity contracts and supplier product carbon footprints, performance from end-of-line test systems and the quality system, and due-diligence documents from procurement and compliance. The passport is a join across those systems per battery model.
No. Your team keeps its IMDS account and its customer portals. PredCo reads your PLM, ERP and supplier data, prepares and validates the records, and keeps the evidence trail; it extends what you have rather than migrating it.
PredCo and Panscience Innovations hold SOC 2. The system can run on your own servers or air-gapped, access is role-based, and your source systems stay where they are. Our security page has the details.
A 30-minute working session with our engineering team. No slideware. Bring a real operational problem and leave with a concrete view of what a PredCo deployment looks like for your plant.
