The EU’s Battery Regulation, which came into effect in February 2023, marks a notable shift in how the region governs the lifecycle of batteries, particularly for electric vehicles (EVs). It’s not just about recycling rates or carbon footprints anymore—though those matter too. The new framework sets out something arguably more ambitious: full traceability of critical raw materials, including cobalt, lithium, and nickel, across the battery supply chain. Automotive OEMs, especially those with large European market shares, now face the task of proving, with credible data, where these raw materials come from and how they’ve moved through each tier of production. That’s a tall order. And one that raises as many practical challenges as it does policy questions.
On paper, the idea is clear enough. By requiring traceability, regulators aim to reduce environmental harm, prevent human-rights abuses linked to mining, and create more circular, transparent supply chains. In practice, though, building this traceability—especially for materials sourced from regions where data transparency isn’t always guaranteed—calls for tools and systems that can stitch together information across borders, companies, and processes that were never designed to be interoperable. Blockchain technology is one of the solutions gaining traction. It’s not without limitations. But it offers a foundation for creating what’s now being called a battery passport—a digital record of a battery’s material inputs and manufacturing journey.
Constructing a blockchain-based battery passport system isn’t, it should be said, something that can be done overnight. Automotive OEMs will need to make a series of design decisions that balance technical feasibility, supplier participation, and compliance obligations. The first step, naturally, is defining what data points the passport will contain. Under the EU regulation, minimum requirements include the origin of critical raw materials, details of processing facilities, and environmental performance metrics. Some OEMs are going further, voluntarily including additional fields on working conditions or community impacts at mine sites, though that’s still the exception rather than the rule.
With data fields agreed upon, the next hurdle is onboarding suppliers—right down to mining operators. This isn’t always straightforward. Not all mining firms, particularly smaller concession holders in Africa or parts of South America, are ready (or willing) to integrate their data into blockchain systems. Here, OEMs may need to work through intermediaries—trading houses, refiners, or certifiers—who can help collect and validate information. Again, it’s not perfect. Data quality will vary. But it’s a step toward assembling a more complete picture.
Linking battery pack coordinates to mining concession open-data platforms forms another essential piece of the traceability puzzle. Fortunately, several jurisdictions now maintain public registries of mining licenses and concessions. The Democratic Republic of Congo, for example, has an open cadastre system listing authorized cobalt mining areas. Similarly, Australia and Chile offer portals mapping lithium and nickel extraction sites. By correlating supplier-provided mine-of-origin data with these public platforms, OEMs can start to verify that reported sources match legally sanctioned operations. This, of course, depends on the accuracy of both the supplier declarations and the government databases—a point that shouldn’t be overlooked.
Establishing this link between battery packs and mining sites typically involves assigning unique digital IDs to each pack, with embedded data that can be read (and updated) at various points in the supply chain. Some firms are exploring QR codes or NFC chips for this purpose, while others favor purely digital ledgers without a physical tag. Either way, the aim is to create a record that persists as the battery moves through cell assembly, module integration, and final pack installation in the vehicle. Whether that record is as watertight as the regulation envisions—well, that remains to be seen.
OEM compliance teams face practical choices around data governance too. Should they build proprietary blockchain systems or join shared industry consortia? The latter might lower costs and improve interoperability, but it also raises questions about data ownership and competitive sensitivity. There’s no universally accepted model yet. What’s emerging is a patchwork of pilots, partnerships, and, frankly, some trial and error as firms work out what delivers value beyond mere compliance.
It’s also worth noting that while blockchain gets much of the attention, it isn’t a magic bullet. Traceability still relies on the integrity of the data entered. If false information is uploaded, blockchain can’t correct it. This is where third-party verification and engagement with local NGOs or independent auditors come in. Some OEMs are beginning to embed these actors directly into their traceability frameworks—funding site visits, for instance, or contracting neutral observers to report on conditions at mining sites. Again, this adds complexity, and not every supplier relationship will accommodate such scrutiny.
As these systems mature, another challenge looms: harmonizing battery passport data with other reporting requirements—whether under corporate sustainability reporting rules, carbon accounting frameworks, or upcoming digital product passport initiatives in the EU. Some OEMs are already grappling with how to avoid duplicative reporting and reconcile differing data standards across regulatory regimes. There’s no neat solution just yet. It’s an area that will likely see further guidance (or at least clearer expectations) as the European Commission refines technical standards for the battery passport over the next few years.
While the EU Battery Regulation sets out a clear policy ambition—full traceability for critical raw materials—the path to implementation is far from simple. Automotive OEMs will need to invest in systems, partnerships, and, importantly, internal capacity to manage what’s shaping up to be one of the most ambitious supply-chain data initiatives to date. The journey is underway, but the road ahead is, in many respects, still being mapped out.