Battery Recycling: Feeding Recovery Data Back into the Digital Product Passport

The loop only closes when the end of a product's life feeds back into its beginning. For batteries, the EU now mandates exactly that: the Battery Regulation (EU) 2023/1542, which entered into force in August 2023, doesn't just require a Digital Product Passport (DPP) at market launch — it explicitly requires that recycling information be written back into that passport throughout the entire product lifecycle. What this means in technical and organizational terms is still not fully clear to many manufacturers.

What the Regulation Actually Requires

Affected Battery Categories

The regulation does not apply equally to all batteries. The categories specifically covered are:

• Industrial batteries with a capacity of 2 kWh or more
• Traction batteries for electric vehicles (EV batteries)
• Batteries for light means of transport (e.g., e-bikes, e-scooters)

For these categories, a machine-readable data carrier — in practice a QR code conforming to the GS1 standard — is mandatory. It must point to a structured digital data record. That record is not a static document but a dynamic data point that must remain updatable across the entire product lifecycle.

Which Recycling Data Must Be Written Back

Annex XIII of the regulation lists the minimum data that must be maintained in the DPP. For the recycling phase, the relevant data points include:

• Recycled content of cobalt, lithium, nickel, and lead in the active material (as a percentage)
• Identity of the recycler and the recycling facility used
• Recovery rates for the materials listed above, based on the actual recycling process
• Evidence of compliance with the minimum recycling efficiency targets under Article 70

This data only exists after recycling has taken place — meaning months or years after the product was placed on the market. That is precisely what makes the DPP for batteries a living document: the passport must remain writable, and responsibility for keeping it up to date falls on recycling companies in coordination with manufacturers.

Technical Implementation: Writing Data Back into the Passport

The Resolver Principle and Why It Matters Here

A QR code printed on a battery contains no payload data directly — it points via GS1 Digital Link to a resolver endpoint. That endpoint returns different data views depending on context: consumers see safety information, authorities receive conformity documentation, and recyclers get material data.

This means the physical QR code on the battery never needs to change. What changes is the data it points to. For recyclers, this is a key advantage — they don't need to apply a new label; they simply update the existing data record.

A typical GS1 Digital Link for an EV battery looks like this:

https://id.example.com/01/04012345678901/21/BATCH-2024-XY7

Here, 01 is the GTIN application identifier and 21 is the serial number. The resolver uses HTTP Accept headers or query parameters to determine which data view to return.

Write Access for Recyclers: Who Can Update What?

The regulation does not specify a particular technical architecture for write access. In practice, two models are emerging:

1. Centralized repository with role-based access control: The manufacturer operates or commissions a DPP repository. Recyclers are granted write permissions on defined data fields — exclusively the recycling attributes, not the original product data — via API keys or OAuth2 tokens.

2. Decentralized model with data exchange via standardized API: Recyclers maintain data in their own system landscape and push it to the manufacturer's repository. Interoperability standards are critical here.

The BatteryPass-Ready consortium — developed largely by Fraunhofer IPK — launched a public test environment on June 24, 2026, allowing companies to validate exactly these interfaces against defined conformance checks. The test environment is freely accessible and covers the relevant EU standards ahead of the statutory obligation taking effect in February 2027.

Data Format and Interoperability

The European Commission identified interoperability as one of the most pressing unresolved issues at its July 7, 2026 webinar. Concretely: if a recycler in Poland enters data into their ERP system and a manufacturer in Germany uses a different DPP backend, both systems must speak the same semantic language.

CEN and CENELEC addressed this at a public webinar on June 25, 2026, explaining the adopted European standards. The most relevant standards for the battery passport are:

• EN 17623 (data model for the DPP)
• ETSI EN 319 401 (electronic signatures for trustworthiness)
• IEC 63110 (protocol for battery management systems)

A minimal example of a JSON payload that a recycler might submit to a DPP repository:

{
  "batteryId": "04012345678901-BATCH-2024-XY7",
  "recyclingEvent": {
    "date": "2026-06-15",
    "recyclerGLN": "4012345000009",
    "facility": "Recyclingwerk Norddeutschland GmbH, Hamburg",
    "recoveredMaterials": {
      "cobalt_pct": 92.4,
      "lithium_pct": 87.1,
      "nickel_pct": 95.0,
      "lead_pct": null
    },
    "recyclingEfficiency_pct": 80.5,
    "certificationReference": "TÜV-REZ-2026-4471"
  }
}

This payload would be sent via a PATCH request to the manufacturer's DPP endpoint and signed there with the recycler's qualified electronic signature to ensure tamper-proofing.

Organizational Challenges and Deadlines

Who Bears Responsibility?

The regulation assigns primary responsibility for the DPP to the party placing the product on the market — i.e., the manufacturer or importer. This means that even when a recycler supplies the data, the original manufacturer is liable for ensuring the DPP is complete and accurate. Contracts between manufacturers and recycling companies must explicitly address this data obligation — a point that is still missing from many existing waste management agreements.

Timeline to the Compliance Deadline

The time remaining before February 2027 is tight. If you don't yet have a DPP infrastructure in place, you should use the BatteryPass-Ready test environment now to identify gaps early.

Bulk Import of Recycling Data

In practice, large recycling facilities process hundreds of battery batches per month. Manual data entry is not scalable. Platforms that support structured bulk import of recycling records — for example via CSV upload with GTIN mapping or a batch API — will become an indispensable tool for recyclers.

One important consideration: every battery has its own serial number (serialization is mandatory), which means recycling data must be assigned at the individual unit level, not at the batch level. This significantly increases data throughput requirements.

Conclusion: The Passport Doesn't End at the Factory Gate

The Battery Regulation takes the product passport concept to its logical conclusion: a DPP that contains only production data is, by the regulation's own logic, incomplete. The passport only fulfills its regulatory function as a circular economy instrument once recycling data has been written back into it.

Technically, this is achievable — the resolver principle of the GS1 Digital Link makes the QR code a permanent anchor point without ever requiring the physical label to be replaced. Organizationally, it demands new contractual structures between manufacturers and recycling companies, as well as interoperable interfaces — work that CEN, CENELEC, and the BatteryPass consortium are actively advancing through their standardization efforts.

If you treat February 2027 as a deadline rather than a starting point, you still have enough time — but not much of it.