10 reasons to use the GBA’s Battery Passport to prepare for compliance amid regulatory uncertainty in the European Union and beyond

November 21, 2025

Image: REUTERS/Claudia Morales

by Kaisa Toroskainen, Senior Programme Manager - Global Battery Alliance 

In a nutshell: With shifting legislative scope and timelines, visibility of supply chains, security of material supply, early detection of risks and capabilities to engage supply chains for data collection, help anticipate requirements and avoid material risks to business. The Battery Passport guides putting in place management systems for compliant supply chain due diligence and GHG calculation before the EU Batteries Regulation is enforced.

Since the passing of the EU Batteries Regulation (EUBR) in 2023, the “battery passport” has become a ubiquitous term among battery users, suppliers and stakeholders. This ground-breaking legislation leverages a digital product passport for traceability of battery products across their lifecycle from 2027 onward. Today, EU policymakers’ focus is on competitiveness, in support of the EU Green Deal and the Net-Zero Industry Act. Concrete tools include the designation of strategic projects under the Critical Raw Materials Act in and outside the EU, the Re Source Europe and Battery Booster initiatives, and Public Procurement rules under revision. Meanwhile, the European Bank for Reconstruction and Development and European Investment Bank are tasked to invest in EU and partner country projects, and to screen them for risks.

Yet, both uncertainty and urgency surrounds the implementation of the EU Batteries Regulation and the broader policy measures – as heard loud and clear this week throughout the EU Raw Materials Week in full swing in Brussels. A key area of uncertainty is the lack of coherent criteria for environmental, social and governance (ESG) risks, traceability and carbon footprint calculation. The EU Batteries Regulations’ supply chain due diligence requirements were postponed as part of the ‘Omnibus’ simplification package in earlier this year. Last week, the European Parliament voted to further scale back the Corporate Sustainability Due Diligence Directive, raising the possibility of a knock-on effect to the Batteries Regulation. EU member states have not agreed on the calculation methodology of the battery carbon footprint, let alone cross-sectoral harmonisation of greenhouse gas accounting rules. Rules for other data attributes on performance, durability and recycled content are still being defined. Financing for the competitiveness measures is still stratified across policies and instruments. This leaves economic operators[1] asking how to prepare to collect, manage, present and verify data on supply chain due diligence and battery carbon emissions, and suppliers in and outside the EU wondering how to respond to the data expectations, and how to qualify for EU-based funding.

In this first edition of the Global Battery Alliance Secretariat blog, we outline 10 reasons why the Global Battery Alliance’s Battery Passport – an emerging sustainability certification scheme for batteries built on a digital product passport infrastructure - helps industry prepare for upcoming requirements. As we embark on our most important milestone to date, the large-scale Operational Trialling of the Battery Passport, using a harmonised framework built in our precompetitive, public-private alliance to find and trial practical solutions is poised to accompany companies and stakeholders on the journey towards compliance, while hedging for uncertainty.

1. Gap assessment and capacity building toward regulatory readiness: The GBA’s two principal frameworks help identify gaps and guide supply chains toward bridging them:

• • The Battery Benchmarks is the first ever, globally harmonised set of criteria outlining due diligence and ESG performance benchmarks for battery value chains in line with the EU Batteries Regulation and its underlying international frameworks. It guides setting up a compliant supply chain due diligence policy, management system, reporting and verification, incorporating risk-based approach, continuous improvement and stakeholder engagement.
  • The GBA’s Greenhouse Gas rulebook is a consensus-based interpretation of product carbon footprint calculation, guiding companies in the use of two calculation methods in line with the options on the table for upcoming EU rules – a market-based and a physically modelled approach – to achieve comparability in anticipation of a methodology finally adopted in the EU and elsewhere.

Especially for new entrants to battery value chains – such as utilities, energy storage providers, cathode and anode producers and recyclers - the Battery Passport offers an entry point toward developing required capacities for compliance.

2. Efficient supply chain engagement: Exchanging data on carbon footprint and due diligence between suppliers and clients in a harmonised format reduces duplication of queries and eases audit burden. Data requests can be made through the GBA’s harmonised system of data exchange and digital credentials. The data model is built on the United Nations Transparency Protocol (UNTP), but is fully interoperable with other data sharing protocols such as Catena-X.

3. Efficiency and interoperability with facility-level standards: The Battery Benchmarks are built together with and in recognition of mining and refining standards; Aluminium Stewardship Initiative, CopperMark, ICMM Mining Principles, Initiative for Responsible Mining Assurance (IRMA), Responsible Mining Initiative, Toward Sustainable Mining, and a range of ISO standards. The cross-recognition is a unique offering for economic operators to start using existing schemes to support due diligence, ahead of the adoption of recognised schemes under the EU Batteries Regulation. Ultimately, the GBA Battery Passport seeks to become a recognised scheme via the cross-recognition of its standard setter partners. It significantly reduces the reporting burden for battery material suppliers who are already audited on-site against one of these standards. This helps make credible claims vis-à-vis increased asks for a standards-based market, as outlined in a recent G7 critical minerals action plan, or to meet the ESG criteria of the EU’s strategic projects.

4. Trusted and assured data via two verification tiers: Via the cross-recognition of standards and an additional tier of independent document verification by GBA-approved verifiers, the Battery Passport will provide assurance that due diligence and carbon footprint calculation have been performed in line with rules and best practices. Economic operators can prepare for auditing of compliance with the EU Batteries Regulation and other requirements. The GBA verification also provides a first layer of assurance of self-reported responses against the Battery Benchmarks by suppliers with no existing audits, with built-in incentives via the scoring model to obtain facility standards in the future.

5. Transparency and comparability - from market access to asset: Harmonised reporting and comparable facility and product scores across battery supply chains provide an evidence base for demonstrating continuous improvement on due diligence and carbon footprint reduction. Comparable data is easier to analyse and use to track continuous improvement, supporting battery makers and OEMs meet investors expectations for traceability and assurance for products and projects they invest in, and responding to future public and private procurement demand. Ultimately, the Battery Passport converts due diligence efforts – too often seen only as a cost – into a market asset and possibly a premium through aggregated demand.

6. Supply-side solution jointly designed by the entire value chain: The GBA’s members have built the Battery Passport, bridging global, multistakeholder and pre-competitive needs. This has led to feasible, implementable interpretations and solutions to progressively meet regulatory requirements and stakeholder expectations. Perhaps most urgently, the digital architecture of the EUBR needs to balance concerns on access and auditability of data, with those on security and confidentiality, especially from jurisdictions which impose legal restrictions on data sharing. Through the GBA’s collective action platform we have worked and piloted solutions through anonymisation and aggregation of data – in line with the regulations’ definitions of user groups and persons of legitimate interest - backed with assurance and verification to meet the needs at both ends of the value chain. Following recent, dedicated engagement in China’s vast battery ecosystem, including with partners such as CCCMC, cooperative approaches yield more productive solutions than traditional cascading of supplier queries.

7. Technology agnostic tools for flexibility and lower barriers to entry for suppliers: The ‘GBA Gateway’, an open-access ecosystem under development with the International Trade Centre will allow supply chain actors to upload and share credentials with various supply chain partners, and exchanging data with in-house supplier assessment questionnaires or 3^rd party data solutions. Economic operators benefit from engaging with their suppliers in a single platform. They can also combine GBA Battery Passport’s harmonised supply chain and carbon footprint data with the full set of data attributes required by the EU Batteries Regulation on labelling, performance, durability, and recycled content, in line with the DIN SPEC 99100 standard developed by the Battery Pass consortium, reducing duplication of efforts. The GBA can leverage its global platform to find solutions on remaining open questions on these data attributes, too.

8. Hedging against regulatory uncertainty through global interoperability: Preparation for the EU Batteries Regulation is an immediate priority for companies looking to sell batteries in the EU, but the GBA Battery Passport is designed as a global tool. It offers a framework for building robust systems which can respond to multiple – and changing – compliance asks, rooted in international frameworks. Across the EU, companies need to meet the EU Forced Labour Ban, EU Conflict Minerals Regulation, and upcoming CSDDD and Corporate Sustainability Reporting Directive (CSRD). In the United States, policy incentives for battery and mineral production have pivoted toward proven provenance of critical minerals, requiring the establishment of chain of custody for battery components and their precursors, beyond the material scope of the EU Batteries Regulation. The China Battery ID and ESG rules also cover the full battery supply chain. The GBA Battery Passport chain of custody model establishes full value chain visibility, helping to meet these global requirements.

9. A tool for policymakers and stakeholders alike: The brunt of compliance is on companies subject to various legal requirements. But with the proliferation of policy measures with qualification criteria for financing, prioritised projects and ring-fencing supply chains, regulators too will benefit from coherent frameworks in designing, implementing and monitoring policies. The Battery Benchmarks offer a clear answer for EU policymakers to the calls for harmonisation. For battery mineral producing countries, benchmarking national standards against the Battery Benchmarks is an invaluable tool. Consumers and civil society can engage with battery value chain companies based on the transparency provided by the Battery Passport, enabling economic operators to meet the stakeholder engagement and public reporting requirements.

10. Piloting among peer first-movers to shape implementation: The GBA Operational Trials and reporting on the GBA Battery Benchmarks and the Greenhouse Gas Rulebook is an opportunity to gain concrete experience in preparing for the EU Batteries Regulation in a pre-competitive setting. Through the sharing of real-life lessons with EU policymakers, standard setters and other stakeholders, the Operational Trials are poised to help the adoption of realistic solutions and guidance for implementation, whilst ensuring robust assurance to build stakeholder confidence. Stay tuned for a technical briefing on EU Batteries Regulation, guiding companies participating in the Operational Trials.

Interested in joining the GBA and trialling the Battery Passport with us? Please contact the GBA Secretariat, join the GBA and shape the Battery Passport! secretariat@globalbattery.org

[1] Companies placing batteries into the EU market under the EU Batteries Regulation