Supply chain
Battery passport supplier data
The battery passport obligation sits with whoever places the finished battery on the EU market — but most of the data it needs originates several tiers upstream. Carbon footprint per life-cycle stage, recycled-content chain of custody and due-diligence evidence cannot be produced from your own records at any level of effort. This is the collection problem, obligation by obligation, with the tier each one actually reaches.
Article 39: the provision that makes this enforceable
Most supply-chain data programmes run on contractual leverage. This one has a statutory hook, and it is short enough to quote in full.
Regulation (EU) 2023/1542, Article 39 — Obligations of suppliers of battery cells and battery modules:
"Suppliers of battery cells and battery modules shall provide the information and documentation necessary to comply with the requirements of this Regulation when supplying battery cells or modules to a manufacturer. That information and documentation shall be provided free of charge."
Two features make it unusually useful.
It binds the supplier directly. This is not a contractual term you have to negotiate into a master agreement. It is an obligation the supplier carries under EU law.
"Free of charge." Suppliers cannot price compliance data as a service. A quote for a "sustainability data package" is not a commercial position you have to accept.
And one limit worth being honest about. Article 39 names suppliers of cells and modules — tier one. It does not by its own terms reach the cathode active material producer, the foil supplier, the refiner or the mine. Reach beyond tier one does not come from Article 39. It comes from the substantive obligations below, which simply cannot be satisfied without upstream data.
How far up each obligation actually reaches
This is the table worth taking into a supplier conversation, because it answers "why are you asking us for this" with a specific article.
| Obligation | Minimum tier that must supply | Evidence type |
|---|---|---|
| Identification and composition Annex VI A, Annex XIII |
Tier 1 — cell and module suppliers | Bill of materials; cathode, anode and electrolyte materials |
| Critical raw materials above 0.1% w/w data point 15 |
Tier 2–3 — CAM, foils, additives | Substance-level declarations |
| Carbon footprint per life-cycle stage Art. 7(1)(e) |
Tier 3+ — mining and refining | Plant-specific LCA data and a publishable supporting study |
| Recycled content share Art. 8 |
Tier 2–3 — refiners, CAM producers | Chain of custody or mass balance |
| Due diligence, four raw materials Art. 48–53 |
To the mine or smelter | Policy and risk management, verified by a notified body |
The bottom two rows are where programmes fail. They are not document requests. They are assurance chains.
Carbon footprint: why corporate averages will not do
Article 7(1) requires a carbon footprint declaration "for each battery model per manufacturing plant", containing among other things:
- "information about the geographic location of the battery manufacturing plant"
- "the carbon footprint of the battery, calculated as kg of carbon dioxide equivalent per one kWh of the total energy provided by the battery over its expected service life"
- "the carbon footprint of the battery differentiated according to life cycle stage as described in point 4 of Annex II"
- "a web link giving access to a public version of the study supporting the carbon footprint values"
Three consequences follow, and each one rules out a shortcut.
Per model per plant rules out corporate averages. A group figure will not satisfy an obligation expressed at plant granularity.
Life-cycle-stage differentiation reaches raw material acquisition. You cannot split a footprint across stages without data from the stages you do not operate.
A publishable supporting study rules out unattributed proxies. Generic database averages are convenient until the study has to be public and defensible.
The methodology is not settled yet
The Commission's Joint Research Centre has published calculation rules work for EV and industrial batteries and draft work for LMT, but the implementing acts setting the official rules had not been adopted at the time of the research behind this page. The Commission's own passport guidance says the declaration format is "still to be specified in the upcoming implementing act".
That is a reason to start collecting inputs now rather than waiting — the supplier engagement takes longer than the calculation.
Recycled content: a chain-of-custody question, not a percentage
Article 8 requires documentation of the percentage share of cobalt, lithium or nickel in active materials "recovered from battery manufacturing waste or post-consumer waste", and of lead recovered from waste, for each battery model per year and per manufacturing plant, from 18 August 2028 or 24 months after the relevant delegated act, whichever is later.
The distinction between "battery manufacturing waste" and "post-consumer waste" is the whole problem. It is not a property of your cell. It is a property of the material's history at the refiner and the CAM producer, which means mass-balance or segregated-flow evidence from tier two and three.
Minimum shares arrive later, and are worth planning against now:
| From | Cobalt | Lead | Lithium | Nickel |
|---|---|---|---|---|
| 18 August 2031 | 16% | 85% | 6% | 6% |
| 18 August 2036 | 26% | 85% | 12% | 15% |
These are demonstrated through the technical documentation in Annex VIII — the conformity assessment file — not through a self-declaration.
Due diligence: four materials, and a notified body
The due-diligence obligations cover "the sourcing, processing and trading of cobalt, natural graphite, lithium and nickel used for battery manufacturing", and bind economic operators placing batteries on the market.
The feature that distinguishes this from most supply-chain reporting:
"one of the battery due diligence obligations is that economic operators' battery due diligence policies are verified by a notified body."
A verified policy is a different artefact from a completed questionnaire. It needs a documented risk-management system, and evidence that reaches toward the mine or smelter.
The date moved, and by exactly two years
Regulation (EU) 2025/1561 of 18 July 2025 — the "stop-the-clock" instrument — made precisely two changes to the Batteries Regulation, both in Article 48: the date "18 August 2025" became "18 August 2027", and "18 February 2025" became "26 July 2026".
The Council's stated reason was to give producers "more time to prepare", and the recitals cite that notification of conformity assessment bodies "is taking longer than expected".
A correction worth making, because it circulates widely: Regulation (EU) 2025/1561 did not narrow the scope of the due-diligence obligations, did not change any turnover threshold, and did not change the exempt-operator definition. It changed two dates. Commentary headlined "reduced scope" is referring to a separate proposal about extending the exemption to small mid-caps, whose status we could not confirm.
What a workable collection programme looks like
Ordered by lead time rather than by deadline, because the two are different.
Start with the assurance chains, not the documents. Due diligence and recycled-content custody need supplier relationships that do not exist yet at tier two and three. Those take quarters. Composition data you can chase in weeks.
Ask per plant, not per supplier. Both the carbon footprint and recycled-content obligations are expressed per manufacturing plant. A request addressed to a corporate entity will come back at corporate granularity and be unusable.
Cite the article in the request. Article 39's "free of charge" language changes the conversation materially, and most tier-one suppliers have not read it.
Track non-response as a finding. The suppliers who do not answer are the risk, and a programme that only records what came back cannot see them.
Keep the evidence, not just the answer. A percentage in a spreadsheet is not documentation. The obligations route through technical documentation and, for due diligence, notified-body verification — both of which need the underlying artefact and its provenance.
Common questions about battery passport supplier data
Can we require this data in supplier contracts instead?
You can, and you should — contracts give you remedies the Regulation does not. But for cells and modules you do not need to: Article 39 already obliges the supplier to provide it free of charge. Contractual terms matter most beyond tier one, where Article 39 does not reach.
What if a tier-3 supplier simply refuses?
Then you have a sourcing decision rather than a data problem, which is uncomfortable but clearer. The obligations are on you as the operator placing the battery on the market; they are not waived because an upstream party is unwilling. This is why the assurance chains need starting early enough that switching remains an option.
Do we need this data before 18 February 2027?
Not for the passport itself — carbon footprint, responsible sourcing and recycled content are all marked "not to be filled/displayed as of February 2027" in the Commission's guidance. You need it for the underlying obligations, which run from August 2027 for due diligence and August 2028 for recycled-content documentation. Collection lead times are longer than that gap.
Is a supplier questionnaire enough?
For composition and critical raw materials, often yes. For recycled content it is not — that needs chain-of-custody or mass-balance evidence from the refiner. For due diligence it is not — the policy itself requires notified-body verification.
Does this apply if we only assemble packs from imported cells?
If you place the finished battery on the EU market, the passport obligation is yours. Article 39 obliges your cell supplier to give you what you need, free of charge. If instead you import finished batteries, you are the importer and the obligation attaches to you directly.
Non-response is the finding
Most supplier evidence programmes record what came back. The expensive gap is the set of suppliers who did not answer, two tiers up, on an obligation with a fixed date.
Qeluntra handles the request-and-chase side of this: structured evidence requests, what is outstanding, and the audit trail behind each response. It does not calculate carbon footprints or verify due-diligence policies — those need an LCA practitioner and a notified body respectively.
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This reference is published by Qeluntra, which sells procurement and supplier management software. It is not legal advice, and Qeluntra is not a compliance certifier.