# Battery passport: build or buy? Effort, risks and the work after go-live > What your own battery passport solution involves: building blocks, operation until the battery is recycled, pending acts and our effort estimate. What your own battery passport solution involves: building blocks, operation until the battery is recycled, pending acts and our effort estimate. By [BatteryPass-Redaktion](https://kabin.sh/en/about#batterypass-team)Published: 25 October 2026Updated: 25 October 2026Facts checked: 25 October 202614 min read ## In short Building your own battery passport means more than coding a form and a QR code. It takes access tiers, review workflows, integrity protection, registration and an operation that keeps the passport available until the battery is recycled, even after your company is gone. Building pays off mainly with a permanent development team, many models and an existing data platform. ## Key facts - Availability Even if the responsible economic operator ceases to exist or stops its activity in the Union [Source](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_78) - End of the passport Only once the battery has been recycled; there is no fixed period [Source](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_77) - Content can change The Commission may amend Annex XIII by delegated act [Source](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_77) - Registration Identifier into the EU registry; verification for example by qualified electronic seal, valid for at most three years [Source](https://eur-lex.europa.eu/eli/reg_impl/2026/1778/oj/eng#art_4) - Passport obligation starts 18 February 2027 [Source](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_77) Building your own makes sense if you have a permanent development team, run many battery models, already hold your data in a structured way in PLM, MES or your own data platform, and are prepared to operate the solution until your batteries have been recycled. For manufacturers and importers with a few models and no development team of their own, the case usually favours buying. Most of the work is not the build but years of operation and the changes that are still to come. We sell such software ourselves, so read the estimates on this page with that in mind. How to compare providers is covered in [Choosing battery passport software](https://kabin.sh/en/choosing-battery-passport-software); what the passport requires in law is in the [battery passport guide](https://kabin.sh/en/battery-passport). ## What does a battery passport solution consist of? More than a form and a QR code. Articles 77 and 78 of the Battery Regulation, Annex XIII and Implementing Regulation (EU) 2026/1778 on the registry give rise to these tasks: - **Content by category.** Annex XIII applies “to the extent applicable to the category or sub-category” of the battery (Art. 77(2)). The Commission's non-binding guidance, version 2.0, sorts which data points are required at the start, which only in certain cases and which not yet. Our [data fields](https://kabin.sh/en/battery-passport/data-fields) show how many fields that means per category. - **Model and individual battery.** The passport holds information on the model and on the individual battery, including from its use (Art. 77(2)). You need a data model with model, technical revision and unit. - **Identifier and QR code.** The passport is reached through a QR code linked to a unique identifier under ISO/IEC 15459 or equivalent standards (Art. 77(3)). The code is printed or engraved visibly, legibly and indelibly on the battery (Art. 13(7)). - **Access tiers.** Public information, information for persons with a legitimate interest, and information only for notified bodies, market surveillance authorities and the Commission (Art. 77(2)); rights to modify restricted (Art. 78(f)). - **Integrity and security.** Authenticity, reliability and integrity of the data, a high level of security, fraud prevented (Art. 78(g) and (h)). - **Condition data.** State of health and usage data such as cycles, negative events, temperature and state of charge (Annex XIII, point 4; Art. 14). - **Second life.** A new passport for repurposed or remanufactured batteries, linked to the original (Art. 77(7)). - **Registration.** The unique identifier is uploaded to the digital product passport registry (Art. 77(10)), through the registry's user interface or its API (Article 8(6) of the Implementing Regulation). - **Open data.** Machine-readable, structured, searchable and transferable without vendor lock-in (Art. 77(5)). - **Availability.** The passport stays available even if the responsible economic operator ceases to exist (Art. 78(e)), and only ceases to exist once the battery has been recycled (Art. 77(8)). On top of that comes what the Regulation does not spell out but everyone needs: import from spreadsheets and the ERP, requests to suppliers (who under Article 39 must provide the necessary information free of charge), evidence, a review before publication, and a log of who changed what. ## How much effort goes into building your own? The table below is **our own estimate** in person-weeks (PW), not a measurement and not a study. It assumes one battery category, a team experienced in web applications and security, an existing hosting environment and a simple ERP connection. It excludes collecting the data itself, which you have to do just the same if you buy, and legal advice. | Building block | What you build | Build | What you operate | What changes later | | ------------------------------ | ----------------------------------------------------------------------------------- | ---------------------- | ------------------------------------------------------- | ------------------------------------------------------------------- | | Data model and field catalogue | Annex XIII fields per category, requirement status, validation rules | 4 to 8 PW | Keeping up with the guidance and new acts | Annex XIII by delegated act; data models in the semantic repository | | Model, version, unit | Master data, technical revisions, units with serial numbers | 4 to 8 PW | Upkeep when models change | Further categories | | Import and ERP connection | File import with a validation report, interface to the ERP or MES | 4 to 8 PW | Error handling, ERP updates | New fields, new ERP versions | | Supplier data | Requests to outsiders without an account, evidence | 3 to 5 PW | Access links, reminders | Carbon footprint and recycled content once the acts apply | | Provenance, review, audit log | Supersede instead of overwrite, approval, change log | 4 to 8 PW | Maintaining roles and rights | Requirements from the act under Art. 77(9) | | Identifier, resolver, QR code | Identifier under ISO/IEC 15459 (for example GS1 Digital Link), resolver, print data | 2 to 4 PW | Domain and resolver for as long as batteries are in use | Standards replaced by delegated act (Art. 77(3)) | | Access tiers | Filtering on the server, access for those entitled, a log of reads | 4 to 8 PW | Granting access, requests from those entitled | Implementing act under Art. 77(9) | | Versions and signatures | Published versions, signing, key management | 2 to 5 PW | Key rotation, protecting private keys | Possible requirements from standards | | Condition data | Interface for BMS or service data per unit | 2 to 5 PW | Data quality, gaps in delivery | Parameters and frequency | | Second life | New passport linked to the original | 1 to 3 PW | Requests from repurposers | Rules in the data model | | EU registry registration | Submitting identifiers, error handling, proof of registration | 3 to 6 PW, uncertain | Renewing verification at least every three years | Interface and semantic repository for batteries not yet complete | | Export | Full export in documented formats | 2 to 4 PW | Format upkeep | The Commission's data model | | Operation and security | Sign-in, roles, backups, monitoring, hardening | 4 to 8 PW | On-call, updates, restore tests | Harmonised standards for Art. 78 (none so far) | | **Total** | | **around 40 to 80 PW** | **around 10 to 25 PW a year** | | Building blocks of an in-house build: what you build, what you operate, what changes later (our estimate) The ranges are wide because the effort depends mostly on two things: how clean your data already is, and how much you connect to existing systems. The registration figure is the least certain, since the registry's interface for batteries was not yet complete at our check on 25 October 2026. ## What work comes after go-live? The build is a project; operation is permanent. Five areas need constant attention. **Following and implementing new acts.** Several acts that affect the content of or access to the passport are still missing: the implementing act on access rights (Art. 77(9), a draft open for feedback since October 2026), the methods for carbon footprint and recycled content (Articles 7 and 8), minimum values for industrial batteries (Art. 10(5)) and the label specifications (Art. 13(10)). The Commission can also amend Annex XIII by delegated act (Art. 77(2)). Each of these can change fields, validation rules or access rights. We track the current state on the [implementation status](https://kabin.sh/en/battery-passport/implementation-status) page. **Following the Commission's data model.** All data in a digital product passport is to be structured according to the data models and definitions in the registry's semantic repository, and those models are versioned (Article 11(3) and (4) of the Implementing Regulation). For batteries the repository is not yet complete (FAQ 11.1). When data points become required or optional, a new version of the model follows (FAQ 7.6). An in-house build has to keep up with every version. **Keeping registration working.** Legal persons prove their identity with a qualified electronic seal or a qualified electronic attestation of attributes. The status lasts until that means expires and at most three years; after that you can neither register new passports nor change data until verification is repeated (Article 4(4) of the Implementing Regulation). The registry automatically checks semantic conformity and granularity at every registration (Article 8(7)), so your software has to handle rejections. **Looking after keys and signatures.** The Regulation prescribes no particular technology, only authenticity, reliability and integrity (Art. 78(g); FAQ 11.3). If you sign passport versions, you must protect the private keys, be able to rotate them and keep the public keys published for as long as anyone may want to verify old versions. **Taking in condition data.** Condition data must be updated at least when the battery's status changes or a change is being considered, for example before repurposing, and more often where the purpose requires it and it is technically feasible and proportionate (FAQ 8.3). Your solution has to accept measurements from the BMS, monitoring or service for years, including when deliveries stop. ## How does a self-built passport stay available once you are gone? This question is easily left open in an in-house build. Article 78(e) requires the passport to remain available even if the responsible economic operator ceases to exist or stops its activity in the Union. The Battery Regulation does not say how. The Ecodesign for Sustainable Products Regulation answers the same question for its products with a back-up copy held by an independent digital product passport service provider (Article 10(4) of Regulation (EU) 2024/1781). That obligation does not apply to batteries, but it shows how the EU legislator addressed the same risk for other products. For an in-house build, in practice: 1. The QR address sits on a domain whose continued operation is arranged independently of day-to-day business. 2. A current copy of the published passports is held by an independent third party allowed to serve it. 3. Identifiers and the export format are documented so that another operator can take over. 4. In the registry, registered passports can be transferred to another verified economic operator that takes over the obligations (Article 6a of the Implementing Regulation). If you buy, the same question arises twice: for your company and for the provider. [Choosing battery passport software](https://kabin.sh/en/choosing-battery-passport-software) lists the questions to ask. ## When does building make more sense, and when buying? No single row decides. Count which side most of your answers fall on. | Your situation | Points to building | Points to buying | | ------------------- | -------------------------------------------------------------------------------------- | ---------------------------------------------------------------- | | Development team | Your own permanent team, experienced in web applications and security | No team of your own, or only project capacity | | Models and volumes | Many models, high volumes, several categories | A few models, hundreds to a few thousand units a year | | Existing systems | PLM, MES and your own data platform already deliver structured data | Data spread across spreadsheets, ERP exports and PDF files | | Integration | The passport is to be embedded deeply in production, service and your own portals | A standard workflow is enough, connected through an interface | | Time | Enough lead time before 18 February 2027, with room for testing | The deadline is close | | Long-term operation | Operation for the life of your batteries is secured, including through reorganisations | Operation should not depend on individual people | | Legal changes | Your own specialists follow and implement new acts | You would rather have that bundled with a provider | | Data location | Strict rules against storing data externally | External hosting under a data processing agreement is acceptable | Decision aid: build or buy A middle way often makes sense: buy the passport platform and build the connection to the ERP, MES or BMS yourself. The data stays where it originates, and the provider keeps the software in line with new legal requirements. Our [integration patterns](https://kabin.sh/en/integrations) show what such connections look like. If a consultancy builds for you, make sure the contract gives you the rights to the code and settles who maintains it after the project. ## Which risks of building are underestimated? - **Access tiers in the browser instead of on the server.** If the public page loads all data and only displays part of it, the restricted information is public. - **Overwriting instead of versioning.** Without history you cannot show which value applied when, or who approved it. More in [Provenance and four-eyes review](https://kabin.sh/en/blog/provenance-and-four-eyes-review-battery-passport). - **A QR address on a project or test server.** Printed codes cannot be changed. - **Hard-coded fields.** When Annex XIII changes, a configuration change turns into a rebuild. - **Registration as “later”.** A qualified electronic seal and verification in the registry take time to arrange. - **Knowledge in one head.** A solution only one developer understands will not last as long as your batteries. ## What are the risks of buying? They are real too: lock-in if the export or the QR address is not under your control; the continuity of young providers; features that do not fit your processes; prices that change; and data held outside your company. A full export, a QR address you can move and clear contract terms deal with most of this. Article 78(d) in any case forbids a provider acting for you to sell your passport data or use it beyond the service. ## Where does BatteryPass stand? BatteryPass is a platform you buy, with an API through which you connect your ERP, MES and BMS yourself. No customer runs BatteryPass in production yet. Most building blocks in the table above, from import and review to access tiers, signed versions and the full export, are in testing in testing. Access to the restricted tiers is limited until the act under Article 77(9) limited; managed ERP connections and submission to the EU registry are planned planned. Responsibility for the data stays with you. More on the [product page](https://kabin.sh/en/product) and, for developers, on [Developers](https://kabin.sh/en/developers). Your data, a reviewed battery passport In 30 minutes we show you how your existing spreadsheets, supplier data and serial numbers become a maintained battery passport. [Request a demo](https://kabin.sh/en/contact)[See an example passport](https://kabin.sh/en/example-passport) ## Frequently asked questions ### How long does it take to build our own battery passport solution? By our estimate, around 40 to 80 person-weeks for one battery category, with an experienced team and existing hosting, plus roughly 10 to 25 person-weeks a year to run it. That is a judgement, not a measurement. Collecting the data is not included; you need to do that just as much if you buy. ### Are a spreadsheet and a static web page per battery enough? For the public information of a small fleet, that can be done technically. It does not solve the restricted tiers, updating condition data, registration or availability under Article 78(e). ### Do we have to store the passport data ourselves? You, or someone you authorise (Art. 78(c)). The EU registry does not hold the passport; it mainly records registration and metadata (Commission FAQ, question 6.5). ### Do we need a qualified electronic seal for the EU registry? Legal persons prove their identity and establishment with a qualified electronic seal or a qualified electronic attestation of attributes (Article 4(2) of Implementing Regulation (EU) 2026/1778). The verified status lasts at most three years and must then be renewed. ### Does the Regulation require signatures on the battery passport? Not as such. Article 78(g) requires the authenticity, reliability and integrity of the data to be ensured; it names no particular technique. Signed versions are one way to make that verifiable, but they demand careful key management. ### What happens to a self-built passport if our company goes out of business? The passport must still remain available (Art. 78(e)). If you build your own, you need an arrangement that does not depend on your company, such as a copy held by an independent third party and a QR address that can be handed over. ### Can we switch from an in-house build to a bought solution later, or the other way round? Yes, if identifiers and the QR address are in your hands and all data can be exported with its history. Article 77(5) requires transferability without vendor lock-in anyway; plan for it from the start. ## Sources 1. [Regulation (EU) 2023/1542, Article 77: Battery passport](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_77) · Publications Office of the European Union (EUR-Lex) · accessed 25 October 2026 2. [Regulation (EU) 2023/1542, Article 78: Technical design and operation of the battery passport](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_78) · Publications Office of the European Union (EUR-Lex) · accessed 25 October 2026 3. [Regulation (EU) 2023/1542, Article 13: Labelling, marking and the QR code](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_13) · Publications Office of the European Union (EUR-Lex) · accessed 25 October 2026 4. [Regulation (EU) 2023/1542, Article 14: Information on state of health and expected lifetime](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_14) · Publications Office of the European Union (EUR-Lex) · accessed 25 October 2026 5. [Regulation (EU) 2023/1542, Article 39: Obligations of suppliers of battery cells and battery modules](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_39) · Publications Office of the European Union (EUR-Lex) · accessed 25 October 2026 6. [Regulation (EU) 2023/1542, Annex XIII: Information to be included in the battery passport](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#anx_XIII) · Publications Office of the European Union (EUR-Lex) · accessed 25 October 2026 7. [Regulation (EU) 2023/1542, consolidated text with Article 77(10) (uploading the identifier to the registry)](http://data.europa.eu/eli/reg/2023/1542/2026-08-13#art_77) · Publications Office of the European Union (EUR-Lex) · accessed 25 October 2026 8. [Implementing Regulation (EU) 2026/1778 on the digital product passport registry, Article 4: Verification requirements for economic operators](https://eur-lex.europa.eu/eli/reg_impl/2026/1778/oj/eng#art_4) · Publications Office of the European Union (EUR-Lex) · accessed 25 October 2026 9. [Implementing Regulation (EU) 2026/1778, Article 8: Registration of a digital product passport](https://eur-lex.europa.eu/eli/reg_impl/2026/1778/oj/eng#art_8) · Publications Office of the European Union (EUR-Lex) · accessed 25 October 2026 10. [Implementing Regulation (EU) 2026/1778, Articles 11 and 12: Data models and semantic repository](https://eur-lex.europa.eu/eli/reg_impl/2026/1778/oj/eng#art_11) · Publications Office of the European Union (EUR-Lex) · accessed 25 October 2026 11. [Regulation (EU) 2024/1781 (Ecodesign for Sustainable Products Regulation), Article 10: Requirements for the digital product passport (back-up copy, paragraph 4)](https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng#art_10) · Publications Office of the European Union (EUR-Lex) · accessed 25 October 2026 12. [Implementing Decision (EU) 2026/1736 on harmonised standards for digital product passports](https://eur-lex.europa.eu/eli/dec_impl/2026/1736/oj/eng) · Publications Office of the European Union (EUR-Lex) · accessed 25 October 2026 13. [EU Digital Product Passport FAQ for Batteries (questions 5.1, 6.5, 7.6, 8.3, 11.1, 11.3)](https://single-market-economy.ec.europa.eu/single-market/digital-product-passport/eu-digital-product-passport-faq-batteries_en) · European Commission, DG GROW · accessed 25 October 2026 14. [Digital Batteries Passport: data points by category, version 2.0 (non-binding guidance)](https://single-market-economy.ec.europa.eu/document/download/cd1e5e6c-4a4a-4b99-995a-49eb6916187e_en?filename=Digital+Batteries+Passport+-+data+point+by+category.pdf) · European Commission, DG GROW · accessed 25 October 2026 15. [Have your say: Access rights to certain parts of the battery passport (draft, initiative 16473)](https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/16473-Batteries-access-rights-to-certain-parts-of-the-battery-passport_en) · European Commission · accessed 25 October 2026 16. [GS1 Digital Link Standard](https://www.gs1.org/standards/gs1-digital-link) · GS1 · accessed 25 October 2026 This page reflects the law as we checked it against the linked primary sources on 25 October 2026. It is not legal advice; the text published in the Official Journal of the EU prevails. Your data, a reviewed battery passport In 30 minutes we show you how your existing spreadsheets, supplier data and serial numbers become a maintained battery passport. [Request a demo](https://kabin.sh/en/contact)[See an example passport](https://kabin.sh/en/example-passport)