Global Supply Chain Evidence and the Battery Passport

Global supply chain evidence in a battery passport traces the materials in a battery, and the due diligence behind those materials, across several countries, several holders and several transformations, from extraction through processing to cell and battery manufacture. The trace must survive each border and each holder, because a break at any point leaves the later reader unable to connect the finished battery to its material origins. The Regulation addresses the trace through due diligence duties and through the supply chain information in Annex XIII, and the OECD due diligence guidance provides the internationally recognised framework that the Regulation recitals point to for responsible sourcing. The passport is the place where the trace becomes readable for a later holder, recycler or authority.

The scope is the supply chain and due diligence information in the Regulation, read with the OECD guidance in general terms, as checked on 28 October 2026. The guide does not state the due diligence position for any particular material, supplier or country.

What supply chain information does the passport carry?

The passport carries supply chain information at model level in Annex XIII, including information on materials, on the due diligence policy and on the origin of materials, subject to the access tiers and to the protection of commercially sensitive information. The information is model level because the supply chain for a model is the relevant unit for due diligence, while the individual battery carries the identifier that links it to the model. A reader should therefore read the model supply chain information together with the individual identifier, so that the trace attaches to a specific battery, rather than reading the model information as if it described a different battery. The tier structure means that some supply chain detail may sit in a tier that a general reader cannot see, and the reader should state the tier read.

What due diligence duties does the Regulation impose?

The Regulation imposes battery due diligence duties in its due diligence chapter, requiring economic operators to adopt and implement due diligence policies for the supply chains of specified raw materials, with the start date delayed from the original date by a later amendment, as the European Parliament amendment text records. The duties are described in the Regulation summaries as applying to lithium, cobalt, nickel and natural graphite, with the operator required to base the policy on internationally recognised standards, including the OECD guidance and the UN and ILO instruments named in the recitals. The precise start date, the turnover threshold and the verification arrangements need a reading of the current consolidated text, because the amendment changed the timing, and this guide does not state a due diligence start date as fixed.

How does the OECD guidance fit the Regulation?

The OECD guidance fits the Regulation as the internationally recognised framework for risk based due diligence in mineral supply chains, setting a five step framework covering management systems, risk identification, risk response, independent audit and reporting. The Regulation recitals point to the OECD guidance alongside the UN Guiding Principles, the UN Global Compact, the ILO declaration and the OECD Guidelines for Multinational Enterprises, as the basis for a due diligence policy. The OECD framework is therefore a method source, not a legal duty in itself, and an operator should read the Regulation for the duty and the OECD guidance for the method, keeping the two sources apart. A due diligence file that cites the OECD guidance without showing how it meets the Regulation duty is incomplete, and a file that cites the Regulation without a method is unworkable.

What does a supply chain trace table look like?

A supply chain trace table follows the material through the stages that the due diligence framework names, without claiming a trace for any particular battery. The table below uses general stages.

How is commercially sensitive information protected?

Commercially sensitive information is protected in the Regulation by the access tier structure and by the provision that information duties are without prejudice to obligations to preserve confidentiality of commercially sensitive information under Union and national law, as Article 73 states for its documentation and as the passport tier structure reflects more generally. The protection means that a passport reader should not expect to see supplier prices, contract terms or other sensitive commercial detail in the public tier, and an operator should not withhold supply chain information that the Regulation requires on the ground that it is sensitive, without checking the tier and confidentiality rules. The balance is struck by tier, not by withholding, and the operator file should record the tier decision for each sensitive field.

What breaks a supply chain trace?

A supply chain trace breaks when a holder does not record the chain of custody, when a material is mixed without a mass balance record, when a supplier changes without a new risk assessment, or when a document names a material without naming the battery model it serves. Each break has a different remedy, from a custody record, to a mass balance method, to a fresh risk assessment, to a model link, and the remedy should be recorded with the date. A trace with a stated, bounded break is more useful than a trace that claims completeness without evidence, because a later reader can see where the trace stops and what would be needed to extend it. The trace should be read as a chain with named links, not as a general assurance.

What limits apply to supply chain readings?

The limits are that due diligence duties, thresholds and dates need a current text reading, and this guide states them only in general terms. This guide gives general educational information only and is not individual legal advice. An operator with a specific supply chain should check the Regulation text and the OECD guidance as checked on 28 October 2026 before acting.