Can the EU’s battery passport and China’s battery ID become interoperable?

Electric vehicle (EV) adoption is accelerating globally, with the International Energy Agency (IEA) predicting 23 million sales in 2026, accounting for 28 per cent of total car sales.

China remains the global dominant market for EVs, which are projected to account for almost 60 per cent of total car sales in 2026. Europe is expected to see electric cars reach roughly one in three cars sold in 2026.

This growth trend presents the strategic challenge of how to source the materials needed for EV batteries sustainably.  There is also a looming toxic waste issue: millions of batteries will need to be maintained, repaired, repurposed, transported, dismantled and recycled safely. China expects 1 million tonnes of end-of-life batteries by 2030, while globally, 20 million tonnes of end-of-life batteries will be generated by 2040. 

Managing end-of-life batteries safely and efficiently requires improving second-hand applications, reuse models and improved recyclability across their full life cycle. Traceability will become the key to knowing where a battery has been and deciding where it should go next.

However, the information needed to safely manage end-of-life batteries (battery chemistry, state of health, ownership history, safety incidents, repair history, material content and recycling instructions) is often fragmented across original equipment manufacturers (OEMs), battery producers, service providers and recyclers.

The EU’s battery passport and China’s battery ID – digital tools to enable traceability of batteries – are early signs of a broader shift towards EV batteries becoming digitally governed assets. This reflects the strategic importance of batteries not only for decarbonization, but also for industrial competitiveness, critical minerals security and circular industrial strategy.

While both systems aim to create digital traceability systems for EV batteries, they reflect different regulatory logics. The EU approach is framed around sustainability disclosure, market access and product-level transparency. China’s system is more directly linked to industrial supervision, producer responsibility and control of end-of-life battery flows. Together, they show that battery traceability is becoming a core pillar of circular industrial policy.

Traceability could either become a bridge for circular trade or a new source of regulatory fragmentation. The outcome will depend on whether the major EV markets of China and Europe coordinate data standards, definitions, access rights and recycling classifications.

There are also emerging political challenges. China’s new Regulations on Industrial and Supply Chain Security, which started in March 2026, could become a major issue for battery traceability, as well as for cells or critical minerals sourced from China or processed through Chinese supply chains. The key tension is this: the EU’s battery passport and wider EU Batteries Regulation require companies to collect, verify and disclose supply-chain information, including due-diligence reporting, carbon-footprint data, recycled content and material information. However, Chinese producers might be prohibited by Chinese law from providing this information. 
 

Under the EU Batteries Regulation, the battery passport becomes mandatory from 18 February 2027 for EV batteries, light means of transport (LMT) batteries and rechargeable industrial batteries above two kilowatt hours. It will be linked to a unique identifier and accessible through a data carrier, such as a QR code. 

The passport is designed to provide structured data on identity, chemistry, carbon footprint, due diligence, recycled content, performance, durability and end-of-life handling. It creates obligations not only for EU producers but for any company placing covered batteries on the EU market (including Chinese companies like CATL). 

This supports market transparency, as regulators, consumers, repairers, second-life operators and recyclers should be able to access different layers of information depending on commercial confidentiality and data-access rules. It also links circular economy objectives with climate and resource-security objectives, particularly through recycled-content requirements, carbon-footprint disclosure and supply-chain due diligence. The EU model aims to turn traceability into a market-access requirement. If a battery enters the EU market, it will increasingly need to carry verified digital information about its origin, composition, sustainability profile and end-of-life pathway.

China has had battery traceability rules since 2018. China’s interim provisions on power-battery recycling traceability established a framework covering the battery lifecycle from manufacture through to recycling, with responsibilities for vehicle manufacturers, battery producers and recyclers. 

China is now strengthening this system. New interim measures, issued by China’s Ministry of Industry and Information Technology and five other departments, took effect on 1 April 2026 and assign each EV battery a digital identity. The measures aim to establish a national EV power-battery traceability information platform and a full-channel, full-chain, full-lifecycle management framework to improve recovery and recycling. 

The Chinese battery system aims to track batteries through production, sales, installation, maintenance, replacement, dismantling, cascade use and recycling. It is also closely tied to extended producer responsibility: automakers and battery producers are expected to establish collection and recycling networks.

The Chinese model treats battery traceability as part of industrial governance and regulatory supervision. The objective is not only disclosure, but maintaining control over battery and material flows, recycling channels and safety risks.

Both systems recognize that circularity cannot work without reliable and detailed data. While Europe starts from product sustainability and market transparency, China starts from lifecycle control and industrial system management.

Battery producers, carmakers and recyclers operating globally may soon need to comply with both systems. This raises several practical questions:

• Could traceability systems become trade barriers, or could they help harmonize battery circularity across the global value chain?
• Can the EU battery passport and China’s battery ID become interoperable? Or will the different data standards fragment global battery markets? While the China Academy of Information and Communications Technology (CAICT) and China’s standards committee (SAC/TC 114) are working to bridge the gap with EU regulations, fundamental architectural differences in data governance and methodology make market fragmentation a highly probable outcome.
• How will commercially sensitive data be shared and protected while still enabling repair, second-life and recycling?

Key challenges to overcome include data interoperability and data integrity issues. 

Data interoperability: ‘Can you read me?’: Digital traceability systems can only function across different stages of value chains if they speak the same language. Without harmonized ontologies and aligned data requirements, information cannot be read across borders, instead requiring complex, costly secondary translation. Incompatible EU and Chinese systems could create duplication and compliance costs for EV and battery manufacturers, which will inflate the cost of bringing electric vehicles to market. Furthermore, traceability systems are only as robust as their boundaries. If batteries are exported, dismantled or recycled outside formal channels, the chain of custody breaks. This creates blind spots that will undermine a global circular economy.

Data integrity issue: ‘Is it true?’: battery passports and IDs are only useful if the information is accurate, updated and verified. There is a real risk of a ‘garbage in, garbage out’ dilemma. Without a verified chain of custody, companies risk feeding digital systems with unverified self-declarations. This is particularly fraught for high-stakes assets like batteries, where the EU now mandates third-party verification as a condition for market access. There is also a commercial confidentiality paradox, especially if Chinese firms may not be permitted to share detailed chemistry, design or performance data of batteries.

The solution is not to create more standards, but to bridge the existing ones through a unified quality infrastructure (QI) for batteries. This can be thought of as the invisible plumbing of global trade: the ecosystem of standards, testing and certification bodies that allows a buyer in Europe to inherently trust a data point generated in China. Establishing robust QI is historically slow, politically complex and capital-intensive, particularly for developing nations. However, the cost of inaction is no longer stasis, it is the compounding accumulation of systemic risk. To secure global supply chains and accelerate an inclusive circular economy, markets and policymakers must collaboratively shift to a dynamic, risk-based verification model with phased implementation.
 

1. Solve interoperability: the ‘language’

• Harmonize data standards through international frameworks such as ISO/IEC JTC 5 (Digital Product Passport) to ensure data is readable across borders.

• This lowers ‘compliance thicket’ costs and increases efficiency in data collection by ensuring interoperability across borders and value chains.

   

2. Solve integrity: the ‘truth’

• Data needs be verified through internationally accredited conformity assessment schemes. Backed by mutual recognition agreements, this strips out reporting bias and ensures market confidence in disclosed data.

• The Global Battery Alliance is currently developing targeted sampling methodologies that prioritize risk models to dictate the frequency of facility audits. This could be a pragmatic path towards guaranteeing data integrity without suffocating the industry with data assurance costs.

   

3. Targeted pilots: phased implementation

• The EV battery market is highly concentrated, dominated by global conglomerates and strictly controlled by major automakers. This consolidated structure makes it the optimal proving ground for initial cross-border traceability pilots.
• Digital traceability needs to encompass LMT and industrial batteries. However, because these markets are highly fragmented and heavily populated by SMEs with low digital readiness, this expansion requires targeted institutional support and a gradual phased rollout.

Europe and China are taking different routes: one through sustainability disclosure and market access, the other through lifecycle supervision and national traceability. Yet both arrive at the same conclusion: without readable and reliable battery data, there can be no circular battery economy.

For EU–China battery trade, this is particularly important: both sides have strong industrial interests, but also different regulatory systems and levels of data disclosure. A well-designed traceability system should be able to bridge these differences by providing verifiable information without unnecessarily exposing commercially sensitive data. Rather than undermining cooperation and trade, traceability should build trust and interoperability, support more predictable rules and create opportunities. 

Finally, improved traceability should address and reduce the vulnerabilities of emerging economies across the battery lifecycle. While digital tracking of battery materials may eventually initiate at the point of extraction, such as cobalt mines in Democratic Republic of Congo, a failure in circularity could mean end-of-life batteries terminate as hazardous e-waste in unregulated landfills like those in Nigeria, creating a toxic legacy. As stringent mandates close domestic loops in Europe and China, developing nations must not become dumping grounds for non-compliant, legacy batteries that fall outside regulated traceability systems.