Battery Passports Could Reward the Firms That Keep the Records Reliable

Europe's approaching battery-passport deadline could create work for companies that connect production records, manage access and keep information useful after a battery changes hands.

From 18 February 2027, the EU's existing Batteries Regulation requires passports for electric-vehicle batteries, light-transport batteries and industrial batteries above two kilowatt-hours placed on the market or put into service. This is an established legal requirement, not a new November law.

The European Commission updated its information guidance on 19 October. Its list distinguishes required fields from conditional information and information due later. Preparing a passport therefore involves more than filling every box or attaching a QR code. Businesses need to establish which records apply to their batteries and who is responsible for maintaining them.

We think the useful connection is between this compliance work and the problems that appear when batteries are repaired, sold or reused. A manufacturer holds production records. A repairer needs technical information. A potential second-life operator needs dependable evidence about condition. Their needs overlap, but their access rights differ.

The responsible operator can appoint another provider in writing to perform passport tasks. The operator's legal responsibility remains. Detailed access arrangements are still being developed, so providers should check the final rules before promising compliance. This draft does not rely on an unverified consultation closing date.

Opportunity one: Connect production records to passport systems. Manufacturers and importers may pay specialists to bring identifiers, test records and existing software together. A useful first project would cover one battery type, identify missing records and measure how much manual work the connection removes.

Opportunity two: Maintain records and manage permitted access. A provider could charge recurring fees for updates, user checks and access logs. The service must follow the final rules and its customer's written authority. A customer buying this service would be stronger evidence than a software demonstration.

Opportunity three: Test battery condition for a defined buyer. Dealers, repairers and second-life operators could use reliable tests to reduce uncertainty. This is a separate commercial hypothesis: the passport obligation does not prove they will pay for every proposed test. Start with a buyer's acceptance criteria and compare testing costs with the value of a better decision.

Opportunity four: Preserve records through reuse. Linked records can help operators understand what changed when a battery is repurposed or remanufactured. Potential fees must cover testing, administration and updates. A long battery life does not automatically produce a profitable service contract.

The market already has substantial participants. The Global Battery Alliance organised 17 trial partnerships in 2026 and presented results in September. Its programme uses developing methods and cautions against treating the results as company sustainability rankings. These trials demonstrate preparation, not verified profitable sales by a new entrant.

SAP (NYSE: SAP) and SGS (SIX: SGSN) are established companies to study for their software and testing capabilities. SAP reported third-quarter revenue of €10.27 billion and IFRS operating profit of €2.93 billion. SGS reported first-half sales of CHF3.683 billion and a 15.1% adjusted operating-income margin. These historical group results do not identify battery-passport earnings or show that either share is undervalued.

The practical opportunity is preparation before February, not a claim that the market has just been discovered. A small provider should seek a paid, narrowly defined project before building a large platform. Manufacturers may use their existing teams, and basic passport tools may become inexpensive.

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