5 mins Read 
27/03/2026 The EU Battery Passport becomes mandatory from February 2027 for industrial batteries and larger systems within scope of the regulation. That date is close enough now that it is starting to influence how battery programmes are discussed and assessed. Mark Rutherford, CEO of Alexander Battery Technologies, sets out what is changing for manufacturers supplying into Europe.
The principle behind the Passport is not especially complex. Batteries placed on the EU market will need a digital record covering origin, carbon footprint, recycled content and key technical characteristics. What is changing is the expectation around how reliably that information can be produced. If the data cannot be traced back with confidence, the battery does not meet the requirement.
For UK manufacturers exporting into Europe, this is already showing up in day-to-day interactions. Supplier questionnaires are becoming more detailed. Audits are spending more time on how records are generated and maintained, rather than just whether they exist. Commercial conversations are starting to reflect that shift as well.
At Alexander Battery Technologies, where we design and manufacture battery packs for OEMs across a range of sectors, the response has been to look closely at whether production systems can stand up to that level of scrutiny without additional workarounds.
Traceability becomes part of the process
This is where the change becomes more practical. Data capture cannot sit off to the side of manufacturing anymore. It needs to happen as part of it.
Each battery pack needs a record that can be retrieved easily – ideally in a few mouse clicks. Bills of materials, approved suppliers, serial numbers, firmware versions, test results and process parameters all form part of that picture. It is just as important that those records stay consistent as the programme moves forward.
Without a clear structure for managing the inevitable changes we see during programmes (component changes, design updates, process refinement etc.), it becomes difficult to keep documentation and physical product aligned. Under a Battery Passport framework, that gap is far more visible than it used to be.
For mid-market manufacturers, the battery pack producer often ends up joining the dots. Even where the OEM holds the responsibility for placing the product on the market, the pack manufacturer is usually handling data from multiple upstream sources. That can include cell chemistry, material origin and lifecycle information.
It does not always arrive in a usable format, either. In some cases, it is incomplete; in others, it is inconsistent across suppliers. It needs to be checked, organised and sometimes challenged before it can be relied upon. Over time, this tends to lead to tighter serialisation, clearer engineering change control and production records that are connected rather than scattered across systems.
Pressure points in the supply chain
Some of the difficulty lies in how battery supply chains are structured.
Cells, electronics and mechanical components are often sourced from different regions. Firmware sits alongside that and needs its own level of control and verification. The further upstream you go, the less standardised the data tends to be.
Raw material information and carbon reporting are still developing areas. Different suppliers may present similar data in different ways, which makes it harder to build a single, consistent product record further down the line.
Therefore, manufacturers need to be able to take that variation and make sense of it before it is attached to a battery record.
Software adds another dimension. Battery management systems and firmware directly affect performance and safety, as well as warranty exposure. Version control and verification are now expected to be handled with the same level of discipline as physical manufacturing data.
In practice, customers and insurers are looking at both together. Firmware history sits with weld data, torque settings and electrical test results, particularly in regulated or safety-critical applications.
Bringing functions together
There is also a more internal shift happening. Engineering, procurement and quality have always had different priorities. Engineering focuses on performance and validation. Procurement is concerned with cost and supply continuity. Quality looks after documentation, traceability and compliance.
Those distinctions do not disappear, but they are becoming harder to manage in isolation. Information needs to move cleanly between those functions, otherwise gaps start to appear.
In some businesses, that still relies on spreadsheets or local systems that work during early development but become difficult to maintain once production scales. Moving away from that tends to involve linking design control, supplier approval, materials management and manufacturing execution more closely.
Greater integration between design control, supplier approval, materials management and manufacturing execution is not about adding complexity for its own sake. When done properly, it usually removes duplication. Changes are reviewed once and reflected consistently, rather than being interpreted differently in different parts of the business.
It also tends to reduce the amount of time spent pulling information together after the fact. Questions can be answered earlier, and in more detail, because the data is already where it needs to be.
A shift already under way
Although February 2027 is the formal deadline, customer expectations are already changing.
Manufacturers are being asked to show how products have been designed, sourced and built, not just confirm that they meet specification. That expectation is starting to feed into supplier selection and ongoing relationships.
For companies supplying into Europe, this is becoming part of normal operating conditions rather than something to prepare for later. The businesses that are adjusting most effectively are the ones treating it as a change in how work is done, rather than an additional layer of compliance.
Mark Rutherford is Chief Executive Officer at Alexander Battery Technologies
Alexander Battery Technologies is a UK based contract battery pack manufacturer offering custom-designed and build-to-print battery pack solutions for OEMs across regulated and industrial sectors.
