Question 1

What is Regulation (EU) 2023/1542?

Accepted Answer

It's the EU's comprehensive batteries regulation, adopted in July 2023 and in force since 17 August 2023. It replaces the 2006 Battery Directive and brings together — in a single binding instrument — requirements for sustainability, safety, performance, supply-chain due diligence, end-of-life management, and a new digital battery passport. Unlike a directive, a regulation is directly binding in all EU Member States without national transposition. That means one rulebook for the whole single market, not 27.

Question 2

When does the battery passport become mandatory?

Accepted Answer

18 February 2027. From that date, every EV battery, every LMT (light means of transport) battery, and every industrial battery above 2 kWh placed on the EU market must carry a digital passport accessible via a QR code on the battery itself. Other obligations bind earlier. Carbon footprint declaration for EV batteries was already required from 18 February 2025; for industrial batteries above 2 kWh and LMT batteries, from 18 February 2026. Supply-chain due-diligence obligations have been in force since 18 August 2025.

Question 3

Does the regulation apply to me if I'm not based in the EU?

Accepted Answer

If you place batteries on the EU market — directly or through an EU importer — yes. The regulation applies to every battery sold or put into service in the EU regardless of where it was manufactured. The practical implication: a Korean cell manufacturer selling to a German automaker is in scope, even though the manufacturer has no EU presence. Compliance obligations follow the product, not the company.

Question 4

What's the difference between Annex VI and Annex XIII?

Accepted Answer

Both relate to the battery passport, but they cover different things. Annex VI specifies the physical labelling and identifier requirements: what's printed on the battery itself, how the unique identifier is constructed, and the QR-code data carrier specification. Annex XIII specifies the digital passport's data content: the actual fields, their values, and how they're organised into the four points that map to the three access tiers (public, legitimate interest, authorities). Annex XIII is the data schema; Annex VI is the physical-world carrier that points to it.

Question 5

Who counts as a "person with legitimate interest" for tier 2 access?

Accepted Answer

Repairers, refurbishers, second-life operators, recyclers, and accredited researchers — anyone with a legitimate operational or scientific reason to access more than the consumer-facing public data, but who isn't a regulatory authority. In practice, tier 2 access is granted to verified industry actors who need detailed state-of-health, performance, and material-composition data to do their job.

Question 6

What are the penalties for non-compliance?

Accepted Answer

Penalties are set by individual Member States, not by the regulation itself. The regulation requires that penalties be "effective, proportionate, and dissuasive" — standard EU language that gives Member States latitude but requires meaningful consequences. In practice, this can include fines, market withdrawal of non-compliant batteries, mandatory corrective actions, and reputational damage from market-surveillance enforcement actions.

Question 7

How does Regulation 2023/1542 differ from the 2006 Battery Directive?

Accepted Answer

The 2006 directive was narrow — focused mainly on collection and recycling — and gave Member States wide discretion in implementation. The new regulation is far broader: it covers sustainability requirements (carbon footprint, recycled content, performance, durability), supply-chain due diligence, the digital passport, and tightened recycling targets, all in a single binding instrument. The other major shift: it's a regulation, not a directive. Member States don't transpose it into national law — it applies directly, identically, across the EU.

Question 8

Do I need a passport for SLI batteries (12 V starter batteries)?

Accepted Answer

No. The battery passport requirement (Article 77) applies to EV batteries, LMT batteries, and industrial batteries above 2 kWh. SLI batteries are not in scope for the passport. That said, SLI batteries do fall under other parts of the regulation — labelling, hazardous substance restrictions, recycled-content disclosure (cobalt/lithium/nickel/lead), and end-of-life management.

Question 9

How does Vertex Battery Passport work, end to end?

Accepted Answer

At placement on the market, the manufacturer creates a passport record for each battery — uploading the regulatory data fields specified in Annex XIII. The platform generates a globally-unique identifier and a QR code that's printed onto the physical battery per Annex VI. Scanning the QR code returns the passport data — what's returned depends on who's asking. Consumers see the public view; verified repairers and recyclers see the expanded view; notified bodies and authorities see everything. As the battery's life progresses, state-of-health updates flow in from the BMS, status changes are recorded, and the passport stays current.

Question 10

Does the platform generate the QR codes and unique identifiers?

Accepted Answer

Yes. The platform generates Annex VI-compliant unique identifiers and produces print-ready QR codes that resolve to the passport URL for that specific battery. For high-volume manufacturers, identifiers can be generated in bulk in advance, exported in the formats your label-printing systems expect, and provisioned at the production line.

Question 11

How is tier-based access actually enforced?

Accepted Answer

Server-side, at every endpoint. The passport URL is the same for every caller, but the response payload is built dynamically based on the caller's verified identity. Anonymous callers get the Annex XIII point-1 data — the public view. Authenticated callers with legitimate interest get the expanded view. Authenticated regulators and notified bodies get the full passport, including supply-chain and conformity data.

Question 12

Can I bulk-import data from my existing systems?

Accepted Answer

Yes. The platform supports CSV import, REST API integration, and direct connectors to common production systems (SAP, Siemens Opcenter, Rockwell, PTC Windchill, and others). For existing battery inventories, bulk import can backfill passports for batteries placed on the market before your platform go-live. For new production, the typical pattern is a real-time API or webhook from your MES.

Question 13

What happens when a battery enters second life or is recycled?

Accepted Answer

The passport supports status transitions that match the regulation's lifecycle states: in service, prepared for re-use, repurposed, remanufactured, waste battery. When a status change is recorded, the passport's responsible-operator field updates, and new labels can be generated as Article 13 requires. The historical chain of custody stays in the passport — what was true before remains visible alongside the new status.

Question 14

How are state-of-health updates ingested from the BMS?

Accepted Answer

From August 2024, Article 14 requires that up-to-date state-of-health and expected-lifetime parameters are maintained in the battery's management system for EV, industrial, and LMT batteries. The platform ingests these via a manufacturer-side gateway service or OEM telematics integration. Frequency and granularity are configurable.

Question 15

Does the platform store carbon footprint declarations under Annex II?

Accepted Answer

Yes. The platform stores the carbon footprint value (kg CO₂-equivalent per kWh), the carbon footprint performance class, the calculation methodology used, and the underlying study reference. When the Commission's delegated act updating the PEF methodology lands, the calculation rules in the platform are updated centrally.

Question 16

How long does a typical implementation take?

Accepted Answer

For a self-serve mid-market customer onboarding via the SaaS platform, basic implementation — creating an account, configuring battery types, generating identifiers, and producing passports for new production — can be done in days. For an enterprise customer with bespoke MES, ERP, and PLM integration, expect 8–16 weeks for a full integration depending on scope.

Question 17

Which production systems do you integrate with?

Accepted Answer

Pre-built connectors exist for SAP S/4HANA, Siemens Opcenter MES, Rockwell FactoryTalk ProductionCentre, Honeywell MES, PTC Windchill PLM, and Ignition SCADA. For any system not on that list, a REST + webhook API and an OPC-UA / MQTT bridge cover most other integration patterns.

Question 18

Can I get a demo or trial?

Accepted Answer

Yes. We run guided demos for prospects on request. For self-serve evaluation, a free trial tier is available — you can create test passports against the full Annex XIII schema and verify that the platform handles your battery data correctly before committing to a plan. For enterprise prospects, we typically run a proof-of-concept against a representative slice of your real production data.

Question 19

What data do I need to provide to get started?

Accepted Answer

To create a working passport, the minimum is: manufacturer details, battery category, chemistry and material composition, weight, manufacturing place and date, carbon footprint value and methodology (if Article 7 applies), recycled-content percentages where required, hazardous substance presence, and end-of-life handling instructions. Most of this data already exists somewhere in your existing systems — the integration work is usually about mapping fields rather than collecting new data.

Question 20

Can you co-develop a custom platform for our specific programme?

Accepted Answer

Yes. For OEMs setting up new manufacturing programmes — whether in the EU or elsewhere — we work alongside the customer team in a co-development model. The platform is integrated directly into the production system rather than bolted on at the end. This model includes on-the-ground engineers for plant-floor commissioning, follow-the-sun support cover, and direct involvement of our regulatory-affairs team.

Question 21

What does it cost?

Accepted Answer

Pricing is tiered by passport volume and integration scope. Self-serve plans are listed publicly on the Pricing page with monthly costs and clear included-volume limits. For enterprise customers — typically OEMs with custom MES integration needs, bespoke SLAs, or co-developed deployments — pricing is bespoke and depends on integration scope, volume, and support level.

Question 22

What's included in each plan?

Accepted Answer

Every plan includes the full Annex XIII passport schema, Annex VI labels and QR generation, the three-tier access model, state-of-health ingestion, and continuous regulatory updates. Differences across plans are around passport volume per month, retention period, support response times, integration features, and team seat counts.

Question 23

Is there a free tier or trial?

Accepted Answer

Yes. A free trial tier lets you create a limited number of test passports per month, with the full schema available. It's intended for evaluation — verifying that the platform handles your battery data correctly before committing to a paid plan.

Question 24

Where is passport data hosted?

Accepted Answer

Primary infrastructure is hosted in the EU (Frankfurt region) on managed cloud services with ISO 27001-certified providers. Object storage for QR codes, attachments, and supporting documentation uses Cloudflare R2 with EU residency. For customers with specific data-residency requirements, we support deployments in additional regions on enterprise plans.

Question 25

Are you GDPR compliant?

Accepted Answer

Yes. The platform is built to GDPR requirements: lawful basis documented for every data processing activity, data-processing agreements available for customers, right-to-erasure procedures, breach notification within 72 hours, and a documented data-protection impact assessment. Battery passport data is mostly product data rather than personal data, but where personal data is involved, GDPR safeguards apply in full.

Question 26

How do you protect supply-chain confidentiality?

Accepted Answer

Tier 3 data (supply-chain due-diligence reports, raw-material origin records, conformity documentation) is access-controlled at the row level. Only authenticated notified bodies and authorities with verified credentials can read it. For commercially sensitive supplier data, the platform supports redaction and aggregation: you can publish that you sourced from a verified mining operator in a region without naming the specific supplier in the public view, while still providing the full record to authorities when required.

Question 27

What support do customers get?

Accepted Answer

All paid plans include email support with documented response-time SLAs. Business and Enterprise plans add priority response, named technical contacts, and access to our regulatory-affairs team for compliance questions. Enterprise customers also get follow-the-sun coverage across UK, Pakistan, and KSA time zones.

Everything you'd ask before
booking a demo.

Regulation