Since the EU’s new Battery Regulation took effect in February 2023, battery manufacturers across the bloc have been navigating a complex landscape of compliance demands, technical challenges, and evolving market expectations. The regulation, ambitious in scope, aims to impose strict sustainability and transparency standards on the entire lifecycle of batteries, from raw material extraction through to end-of-life recycling. It is, in many ways, a bold attempt to set a global benchmark. Yet, the reality on the ground is, predictably, a little messier. Preliminary industry adoption in 2023 shows that while some firms have made swift progress, integrating compliance requirements into their supply chain and reporting systems, others appear to be lagging—struggling, perhaps, to reconcile the regulation’s intent with operational realities. This unevenness has generated no small amount of debate among industry watchers and policymakers alike.
One of the more challenging aspects manufacturers have faced involves the regulation’s demand for life-cycle assessment data, particularly as it relates to substances of concern. The expectation, on paper, is relatively clear. Battery producers are to ensure that detailed supplier-level LCA data links seamlessly with submissions to the European Chemicals Agency’s SCIP database. In practice, though, this linkage is proving more cumbersome than many had anticipated. Some manufacturers, often the larger or more globally integrated ones, have been able to pull from open datasets or consortia resources—industry LCA libraries, for example, or academic environmental impact studies. These resources help fill gaps where proprietary supplier data remains elusive. But even here, questions arise about data comparability, consistency, and whether reliance on generic benchmarks dilutes the intended rigor of the regulation. There is no easy answer, it seems.
Interestingly, where companies have succeeded in this data integration task, it is often because they began by mapping out their supplier ecosystems well in advance of the regulation’s formal start. Those that had invested in digital compliance tools or early supplier engagement found themselves better equipped to automate SCIP notifications and link environmental metrics directly into their internal reporting systems. Yet, even among these early movers, there’s a degree of caution. Some admit, quietly, that their first round of submissions may fall short of the standard they ultimately want to meet. Others note discrepancies between what suppliers report and what can be verified through open data sources, like the Joint Research Centre’s environmental footprint references or pilot data from the Global Battery Alliance’s Battery Passport initiative. It’s a work in progress, one that reflects both the scale of the regulatory ambition and the limitations of current data infrastructure.
Then there’s the matter of the battery passport, which has attracted significant attention both within the industry and among external observers. The passport—essentially a digital record detailing a battery’s composition, performance, and sustainability credentials—was heralded as a breakthrough tool for enabling circular economy principles and ensuring supply chain accountability. The European Battery Alliance’s portal has emerged as the key platform for managing these records. Some manufacturers have started uploading passport data using self-developed templates that include information such as battery identifiers, material content down to the component level, and origin data for critical raw materials. But here, too, execution varies. Some templates are remarkably detailed, with comprehensive LCA indicators and recycling guidance; others feel piecemeal, constrained either by data availability or internal capacity.
Suppliers further upstream are feeling the pressure as well. For those providing cathode, anode, or electrolyte materials, requests for granular environmental and origin data have increased sharply. In some cases, this has led to tensions. Smaller suppliers may lack the technical capacity to provide the requested data at the level of precision now demanded, creating bottlenecks that ripple through the reporting chain. Some manufacturers have responded by revising their procurement contracts, embedding battery passport data requirements at the contract negotiation stage. Others have opted for a more informal approach, relying on supplier goodwill or informal assurances—at least for now.
The early experience with the Battery Regulation also raises a few under-explored questions about the intersection of compliance and market positioning. Several manufacturers have expressed the view, sometimes publicly but often in quieter conversations, that the new transparency obligations could serve as a differentiator, offering a means to demonstrate environmental leadership to increasingly discerning customers. The automotive sector, in particular, has shown interest in sourcing batteries that can provide verifiable environmental credentials, not simply for regulatory reasons but as part of broader ESG commitments. Yet the practicalities of turning data transparency into market advantage are still being worked out. How much weight do customers place on battery passports today, and how does that translate into procurement decisions or pricing power? There’s no consensus.
What seems clear, however, is that the regulation is prompting new conversations about data infrastructure, supply chain governance, and the future shape of the European battery industry. Some manufacturers have begun to experiment with direct data feeds between their internal compliance systems and external reporting portals, hoping to reduce manual inputs and the risk of error. Others are focusing on supplier training, recognizing that without upstream cooperation, even the best-designed internal systems will falter. There are also signs of emerging collaboration across companies, particularly in sharing best practices or pooling resources for supplier audits. But these efforts are still nascent, shaped as much by competitive concerns as by shared regulatory challenges.
It would be premature to draw firm conclusions about the success or failure of the Battery Regulation’s first year of implementation. The picture that emerges is one of genuine progress, tempered by operational friction and a degree of uncertainty about how best to meet the regulation’s complex demands. As manufacturers, regulators, and other stakeholders continue to navigate this terrain, the lessons from 2023 are likely to inform not only future compliance strategies but also broader discussions about sustainability and accountability in Europe’s industrial policy.