regulation
We Just Assemble Packs — Isn't the Battery Passport Our Cell Supplier's Problem?
If you place the finished battery on the EU market, the Digital Product Passport obligation is yours — even when every cell comes from someone else. Here's why, and what to do about it.
The short answer
No — it's yours. Under Regulation (EU) 2023/1542, the Digital Product Passport obligation attaches to the economic operator placing the battery on the EU market. If your company sells the finished pack — even a pack built entirely from purchased cells — you are that operator from 18 February 2027 for EV, LMT, and industrial batteries above 2 kWh.
This surprises a lot of pack assemblers, because everything else in your quality world (cell datasheets, UN 38.3 test reports, cell-lot certs) arrives from the supplier. The passport inverts the flow: you're now the publisher of record for data you never generated.
Why the obligation lands downstream
The regulation is written around market access, not manufacturing. The passport is the condition for legally selling the battery in the EU, so it binds the seller. In practice that means:
- A pack assembler sourcing cells from a separate manufacturer owns the passport for the finished pack.
- An OEM integrating packs into a vehicle or machine owns the passport for batteries it places on the market under its own name.
- An importer bringing finished batteries into the EU owns it if no EU-established operator upstream does.
The cell maker's data — chemistry, critical raw material shares, due-diligence reports — is input to your passport. It never was, and never becomes, a substitute for it.
The gap this creates on your side
Most assemblers already hold good internal build data: cell-lot tracking, BMS firmware versions, end-of-line test records. What's typically missing is everything upstream of the cell — mine-to-cell provenance for cobalt, lithium, nickel, and natural graphite, plus the supplier's carbon footprint contribution. That data exists at your supplier (or their supplier), and getting it flowing is usually the longest-lead item in the whole compliance project — start there, not with the QR code.
What to do this quarter
- Confirm you're the economic operator for each product line — especially white-label and rebadged configurations, where it's easy to assume the other party has it.
- Add passport data delivery to supplier contracts now: cell chemistry by weight, origin countries, due-diligence report references, carbon footprint per the regulation's methodology.
- Inventory what you already produce internally — your existing cell-lot and test records cover more of the passport than most teams expect.
The obligation is non-transferable, but the work is mostly data assembly — and the data mostly already exists. The task is routing it to a publishable record before February 2027, not inventing it.