The shift to electric vehicles demands unprecedented traceability across battery supply chains: the origin of cobalt, lithium, nickel and graphite; the carbon footprint of the complete lifecycle; the share of recycled content. This is no longer a CSR commitment — it is a regulatory obligation with a fixed deadline.
EU Regulation 2023/1542 of the European Parliament and of the Council, published in the Official Journal of the EU on 28 July 2023 (EUR-Lex), establishes the Battery Passport: a unique digital identifier holding all essential battery data, accessible via QR code or RFID. From 18 February 2027, the Battery Passport will be mandatory for electric vehicle batteries, LMT batteries (e-bikes and e-scooters) and industrial batteries above 2 kWh placed on the EU market.
Why does this concern your ERP — and not just your quality or sustainability team? Because the data the Battery Passport requires lives in your ERP: supplier origin certificates, bills of materials, serial-number-level production data, quality test results. Without an ERP structured to collect, link and expose this information, the passport cannot be reliably produced.
EU Regulation 2023/1542: Who Is Affected and When?
Scope of the Regulation
The regulation classifies batteries into five categories. Obligations and timelines vary by category:
- Portable batteries (laptops, smartphones, small electronics): durability, performance and recyclability rules apply, but no Battery Passport requirement.
- LMT batteries (Light Means of Transport: e-bikes, e-scooters, mopeds): Battery Passport mandatory from 18 February 2027.
- Industrial batteries above 2 kWh (stationary energy storage, forklifts, heavy equipment): Battery Passport mandatory from 18 February 2027.
- Electric vehicle (EV) batteries: Battery Passport mandatory from 18 February 2027.
- SLI batteries (starting, lighting and ignition): specific collection and recycling rules apply, but outside the Battery Passport scope.
If your organisation manufactures, imports or distributes any of the three in-scope types, you have fewer than 18 months to adapt your information systems.
Key Obligation Timeline
The regulation applies in progressive stages, allowing you to sequence your actions:
Already in force (since 18 February 2024): general durability, performance and basic labelling requirements apply to new products placed on the market.
1 July 2024: lifecycle carbon footprint declaration (Life Cycle Assessment, LCA) in gCO2e/kWh, mandatory for industrial batteries above 2 kWh and EV batteries. This already requires a documented LCA calculation by battery category.
1 January 2026: EV and industrial batteries must display a carbon performance class (A to E, modelled on the EU energy label). This class appears on the physical product label.
18 February 2027: the central date for CIOs. Operational Battery Passport mandatory for EV, LMT and industrial batteries above 2 kWh. Due diligence on critical raw materials (cobalt, lithium, nickel, graphite) also mandatory by this date (the original deadline of 18 August 2025 was moved to 18 August 2027 by EU Regulation 2025/1561).
1 July 2027: mandatory maximum carbon footprint thresholds. Batteries exceeding these thresholds will no longer be permitted on the EU market.
18 August 2031: minimum recycled content targets. Cobalt: 16%, lead: 85%, lithium: 6%, nickel: 6% (for industrial, EV and starting batteries containing these active materials).
This timeline is not a regulatory curiosity: each stage introduces new data requirements into your information systems.
Who Must Implement the Battery Passport?
Responsibility falls on economic operators placing products on the EU market: manufacturers established in the EU, importers of batteries produced outside the EU, and authorised representatives of non-European manufacturers. A distributor that resells batteries without modification is not directly responsible for creating the passport, but must be able to pass upstream traceability data along the chain.
In practice, the entire value chain is involved: raw material and component suppliers must provide verifiable data, and equipment manufacturers integrating batteries (electric vehicles, energy storage systems) must ensure their sub-contractors meet the same obligations.
What Data Must the Battery Passport Contain?
The Battery Passport is a structured digital record, accessible via QR code or RFID. The regulation provides for several access levels: public data (accessible to all), regulated data (accessible to market surveillance authorities) and confidential data (accessible to value chain actors under defined conditions).
The required data categories span six domains:
Identity and general characteristics: unique battery identifier (serial number or batch), model, category, date and place of manufacture, chemical composition (NMC, LFP, NCA…), weight.
Raw material composition: active and passive materials (lithium, cobalt, nickel, graphite, manganese…), hazardous substances present, percentage of recycled content for each critical material.
Carbon footprint: LCA value in gCO2e/kWh calculated according to the European Commission methodology, carbon performance class, information on the energy source used in manufacturing.
Performance and durability: nominal capacity, voltage, cycle life, expected degradation rate, State of Health (SoH) updated throughout the lifecycle.
End-of-life information: disassembly instructions, identification of materials to recover, data for recycling and second-life pathways.
Safety and compliance: results of safety tests (IEC 62133, UN 38.3 for transport), certifications, storage and handling information.
The critical point for CIOs: the regulation requires an LCA per unit (per serial number or batch), not merely an LCA per battery model. This granularity is rarely handled by current ERP systems, which typically calculate carbon footprints at the product or product family level.
ERP Impact: Where Does Each Data Point Live in Your Systems?
Supplier and Supply Chain Data
Your ERP’s procurement module must now capture information that was previously managed outside the system or in separate files:
- Certificate of origin for each critical raw material (cobalt from the DRC or Australia, lithium from Chile, Argentina or Australia). Geographic origin directly affects due diligence risk.
- OECD due diligence on minerals from conflict-affected or high-risk areas. The regulation builds on the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
- Percentage of recycled content declared by the supplier, with supporting documentation (accredited recycler certificates, third-party audits).
- Documented supplier approval: suppliers of critical materials must be qualified to a higher traceability standard than standard suppliers.
The challenge is linking this supplier data to the corresponding production batch numbers, so that for every battery manufactured you can prove which material came from which supplier.
Production Data and LCA Calculation
The production module must evolve on two fronts:
Batch or serial-number recording: most ERPs support batch-to-batch traceability, but few can associate with each manufactured unit its actual energy consumption, waste generated and the specific manufacturing parameters used. These data points are required for individualised LCA calculation.
Carbon footprint calculation: the LCA in gCO2e/kWh is derived from ERP data (material volumes consumed, energy used, transport, waste), but the calculation itself typically requires a specialised external tool (SimaPro, openLCA, or an ESG module within the ERP). The most advanced ERP platforms are beginning to integrate this calculation natively: SAP offers the Sustainability Footprint Management (SFM) module, Oracle Fusion includes a dedicated Sustainability module.
Quality and Test Data
The Battery Passport requires safety test results to be documented and linked to each battery. Your QM module must:
- Archive test results (IEC 62133, UN 38.3) by serial number or individually tracked batch
- Integrate data from the MES (Manufacturing Execution System) and BMS (Battery Management System): production charge cycles, electrical test parameters
- Maintain an immutable history (audit trail) for market surveillance audits
The Battery Passport API
The regulation requires passport data to be accessible via a standardised interface. Data must be hosted on infrastructure compliant with EU data sovereignty requirements. Two initiatives are structuring the technical ecosystem:
- Catena-X: data sharing standard for the automotive industry, built on Gaia-X. Automotive Tier 1 and Tier 2 suppliers are the first affected (catena-x.net). Catena-X certifies interoperable Battery Passport solutions across OEMs and suppliers.
- Battery Data Space: a broader initiative covering all sectors using industrial batteries, based on Gaia-X and IDSA (International Data Spaces Association) standards.
In practice, your ERP will need to expose Battery Passport data either via a REST API to one of these platforms, or through a certified connector that your ERP vendor will provide.
Five-Step ERP Action Plan to Be Ready by 2027
Step 1: Audit Your Existing Data
Before changing anything, map what your ERP already holds in terms of traceability. Key questions: are your production batches tracked by serial number? Do you hold origin certificates for critical material suppliers in the ERP or in an external document management system? Does your QM module archive test results per unit? This mapping identifies the gaps and prioritises the workstreams.
Step 2: Upgrade Your Procurement Module
Add the missing traceability fields to supplier and item master records: country of origin of the material, source certification (third-party audit, RMI certification…), declared recycled content percentage, due diligence status. Build a dedicated supplier approval workflow for critical material suppliers, with annual renewal of supporting documents.
Step 3: Upgrade Your Production and QM Modules
Configure recording of manufacturing parameters by serial number or individually tracked batch. Connect your MES to automatically push test cycle data into the ERP. Configure quality test result archiving with an immutable audit trail.
Step 4: Build or Connect LCA Calculation
Assess whether your ERP already includes a carbon footprint calculation module (SAP SFM, Oracle Fusion Sustainability, Dynamics 365 Sustainability). If not, identify a dedicated tool (openLCA, SimaPro, or a specialist SaaS solution) and plan its integration with your ERP data flows. The objective is automated LCA calculation per production batch, without manual re-entry.
Step 5: Implement the Battery Passport API
In collaboration with your ERP vendor, plan the deployment of a connector to the Battery Data Space or Catena-X platform relevant to your sector. This step requires validating the target data model (which data to expose, in which format, with which access rights) and testing interoperability with your value chain partners.
Which ERP Platforms Are Ready for the Battery Passport?
Readiness among major ERP vendors varies considerably:
SAP S/4HANA is the most mature. The SAP Sustainability Footprint Management (SFM) module enables product-level LCA with batch-level disaggregation. SAP is a founding member of Catena-X and offers a certified Battery Passport connector for the automotive sector. For battery manufacturers or automotive suppliers, SAP S/4HANA is the best-positioned solution.
Oracle Fusion covers scope 1, 2 and 3 carbon accounting and product LCA through Oracle Fusion Sustainability. Integration with Battery Data Space platforms is under development. Well-suited to large industrial battery manufacturers.
Microsoft Dynamics 365 includes a native Sustainability module managing scope 1/2/3 emissions at the company level, but does not yet offer LCA at the serial-number granularity required for the Battery Passport. Developments are expected through the partner ecosystem.
Odoo has no native Battery Passport module. A specific implementation is required, using the lot traceability module and an external LCA calculation tool. Suitable for SMEs with a limited scope, though the TCO of bespoke development can be significant.
Infor LN and CloudSuite Industrial have a strong presence in automotive and industrial manufacturing. Catena-X partnerships are being finalised. Evaluate with your local Infor partner.
Practical recommendation: before finalising your ERP roadmap, formally ask your vendor for its Battery Passport product roadmap for 2026-2027 and request a demonstration of batch-level LCA functionality. A vendor without a clear answer today is a warning signal.
Per-Unit LCA: The Shift Few ERPs Have Anticipated
Most current ERP platforms calculate carbon footprint at the product model (or item reference) level, using average values for energy consumption and materials. This is sufficient for aggregated CSRD scope 3 reporting, but insufficient for the Battery Passport.
The regulation requires an LCA calculated for each individual unit or batch, because a battery’s actual carbon footprint depends on the specific conditions of its manufacture: the energy source available that day (renewable or fossil electricity mix), the specific raw material batch used, the waste generated during that production run. Two batteries from the same model made on the same day can have slightly different carbon footprints.
This granularity requires redesigning the production data collection architecture: energy meters must be connected to the MES, material consumption must be recorded per batch, and LCA calculation must be triggered automatically at the close of each manufacturing order.
This is a minimum 12 to 18-month project for a company already running a modern ERP. For organisations with an ageing ERP or poorly configured production modules, the timeline can be longer.
The Battery Passport as a Data Maturity Accelerator
Beyond regulatory compliance, the Battery Passport is an opportunity to clean up data management processes that have accumulated technical debt over years. Companies that use this project to strengthen their supplier master, structure their batch traceability and automate their carbon footprint calculations will also be better positioned to meet the other regulatory requirements coming down the pipeline: CSRD, the ESPR digital product passport, supply chain reporting obligations.
The 2027 compliance deadline is the short-term constraint. The data platform built to meet it will deliver value far beyond that date.
For further reading, see our operational guide to the Digital Product Passport (DPP) and industrial ERP and our analysis of CSRD and sustainability reporting in ERP.
