The measure is intended to give each battery a digital identity through which information on its composition, performance, sustainability and life cycle can be accessed. Although the visible element for users will be a QR code, behind it there will need to be an infrastructure capable of bringing together and updating data from numerous actors.
That is where the difficulty lies. Implementing the passport is not simply a matter of generating an identifier; it requires manufacturers, suppliers, integrators and operators to work with information that is compatible, reliable and available when needed. Europe has spent years preparing standards and data models, but with only a few months to go before the rules take effect, the question is no longer whether a sufficient regulatory framework exists, but whether industry will be able to translate it into real-world operations.
AN INDUSTRY MOVING AT DIFFERENT SPEEDS
One of the clearest snapshots available comes from the European Commission itself. In July 2026, DG GROW presented the results of a survey of 91 participants across the battery value chain. Large companies predominated, accounting for 63% of the sample.
The results show an industry in motion, although still far from completing the transition. Only 12% of organisations considered their level of readiness to be “very advanced”, while another 15% rated it as “advanced”. Overall, just 27% said they were at the highest levels of maturity, while 34% were at a moderate stage and the remaining 39% were still at an early stage or had not yet started.
This does not mean companies are standing still. Some 58% are already working on data collection and mapping, 54% have begun engaging their suppliers, and 49% are adapting IT systems. However, only 34% had started pilot projects or testing activities.
The difference matters because the real challenge emerges when systems have to communicate with one another. In fact, only 15% identified QR codes and unique identifiers among the technical areas that would require the greatest effort, whereas supplier data integration reached 51%.
The message is clear: the problem is not the QR code, but everything that needs to exist behind it.
The information required by the passport is distributed among raw-material producers, material and cell manufacturers, integrators, vehicle manufacturers and, later on, companies specialising in repair, second life or recycling. No single company necessarily controls all the data it will need to use.
That is why, when the Commission asked about the main implementation barriers, data availability and quality ranked first, cited by 63% of participants. This was followed by defining roles and responsibilities, at 59%; managing dynamic data throughout the life cycle, at 58%; and technical implementation and interoperability, at 53%.
The pressure increases when the calendar is taken into account. Only 35% said they were very or fairly confident that the necessary data would be available within their value chain by February 2027, while 41% had little or no confidence that they would be able to achieve this in time.
The picture, therefore, is not one of an unprepared industry, but nor is it a sector that has completed all its homework. Many companies have started the process, although moving from regulatory analysis to the real integration of information remains one of the major tasks still to be completed.
