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Export controls, tariffs and concentrated sourcing have made battery supply chains fragile. The companies that can see what they are exposed to are the ones that can react.

The energy transition built the largest, most complex supply chains the battery industry has ever run. Spread across many borders, they are exposed to shifting regulations and external risk, making them fragile. 

For years, the risk in those chains was treated as a reporting problem. Something for the sustainability team to tidy up. That framing is now out of date. War, export controls, tariffs and extreme geographic concentration have turned supply chain visibility into a question of resilience. Not compliance. 

The danger is not simply that a disruption might happen. Disruptions always happen. The danger is that when one does, most companies cannot answer a basic question quickly: which of our products, suppliers and shipments are actually exposed?  

This piece looks at why that question has become so hard, why batteries are especially exposed, and what it means for the companies that build and buy them. 

A battery looks like a single object. It is not. It is the end of a long chain that crosses many borders. Mining in one country. Refining in another. Cathode precursors, active materials, graphite anodes, cells. Each step sits in a different place. Each step is a potential chokepoint. 

That chain has become extraordinarily concentrated. China accounts for over 80% of global battery manufacturing capacity, according to the 

. The concentration runs deeper than the cells themselves. Production of LFP cathode materials and their precursors is still almost entirely concentrated in China, along with the associated manufacturing capacity and technical expertise. Even the plants being built in Europe and the United States rely on imported components, most of them Chinese.  

Concentration on its own is not a crisis. Concentration plus policy is. Protectionism is rising globally. The EU is tightening origin rules through the Battery Regulation, the United States has leaned on tariffs and export controls, and Chinese export controls on key minerals have roughly tripled since 2023. Concentrated supply chains are more exposed to the events in those places, rules on where material can come from, and go, are changing faster than most supply chains can follow. What used to be a theoretical vulnerability is now a live one. 

Two suppliers is not the same as resilience 

Most procurement teams know they should diversify. Many believe they already have. They hold contracts with two Tier-1 suppliers and call the job done. 

Look one layer down and the comfort often disappears. Two tier-1 suppliers are not diversification if both depend on the same upstream refiner or the same cathode processor. The redundancy is an illusion. It exists on the first page of the supply chain and nowhere after it. 

This is the trap batteries fall into. When you look only at the battery chemistries deployed outside China, the LFP portion relies almost exclusively on Chinese supply. A company can feel diversified at tier 1 and be completely single-threaded at tier 3. The only way to know the difference is to see below tier 1. Most cannot.  

 used the recent disruption around the Strait of Hormuz to make the point. When shipping through the Strait slows or stops, manufacturing inputs can be delayed within days. More than a quarter of the world's helium transits the waterway, and its price has already doubled since the conflict began. The IEA recorded the same event rippling wider; disrupted sulphur supplies pushed acid prices up so sharply that, in some cases, acid overtook energy as the largest single cost in mineral processing.  

One chokepoint affecting multiple industries; metals, chemicals and fertiliser, all at once. Batteries are no exception. Material from an affected route can sit inside cells already made and products already shipped, the real challenge is identifying which ones before it becomes a problem. 

 of stationary battery storage installations in 2025. LFP is also the chemistry whose upstream supply is the most concentrated. So the fastest-growing corner of the energy storage world, the one now being pulled hard by grids and data centres, sits on the narrowest and most exposed supply base there is. That is a strategic exposure, not a footnote. 

The clearest signal is what large manufacturers are doing with their own money. 

 signed a multi-year LFP cathode material deal with a Korean supplier, explicitly to strengthen its North American energy storage business and diversify its supply chain away from China. In August 2026, 

 signed a ten-year agreement for United States-produced lithium carbonate, pointing to fast-growing North American storage demand and the need for a stable, local supply of material. They are not alone. 

These are not sustainability announcements. They are resilience moves, made by companies that have looked hard at the concentration in their own chains and decided to act before they are forced to. 

frames the same decade ahead: the easy growth is over, and the advantage now goes to the companies that master their supply chains, not just their chemistry.  

What this means for the companies building and buying batteries 

Strip it back and the lesson is simple. Transparency has changed jobs. It used to be about proving good behaviour after an issue. Now it is about knowing your own exposure before and answering fast when it lands. 

For a battery maker, an OEM or a storage developer, that means being able to trace a product down to its materials and their origin, across every tier, on demand. Not once a year for a report. Continuously, so that when a port closes or a regulation lands, the response is identification rather than guesswork. The companies that can do this will treat the next disruption as a known list of affected products. The companies that cannot will treat it as an emergency. 

There is a hard deadline running alongside all of this. From 18 February 2027, in-scope batteries placed on the EU market will need a compliant Digital Battery Passport. The due diligence associated with Battery Passports and mandatory from 18 August 2027 is the same visibility that makes a supply chain resilient. It is the same work. Better done once, and early.

This is the problem Circulor was built to solve. We have been mapping battery and raw material supply chains back to their origin since before the EU Battery Regulation existed, which is why we helped shape its technical standards. In June 2024 we delivered the world's first full-scale battery passport on a production vehicle, the Volvo EX90, two and a half years ahead of the compliance deadline. The point was never the report. The point was knowing exactly what sits inside a product and where it came from, so that resilience and compliance stop being two separate jobs. 

The disruptions of the last two years were not the exception. 

So the question is not whether the next one comes. It is whether, when it does, you will be reading a list of the products it touches, or starting to look for them. 

If that is a question you would rather answer in advance, it is worth a conversation: 

Why potential geopolitical disruption makes supply chain visibility a strategic necessity

Commentary

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The registry is live but passports cannot be 'registered' yet. A breakdown of what the registry is, how the process will work and what organisations should do now.

Please fill this form to read more and download the guide

Under Article 77 of the EU Battery Regulation, from 18 February 2027, every EV battery, each LMT battery, and each industrial battery (including stationary storage) above 2 kWh placed on the market or put into service in the EU; must have a unique Battery Passport accessible via a QR code normally on the battery itself that links to a unique DPP identifier. 

 with specified registration data in a central EU Digital Product Passport (DPP) Registry (ESPR, Regulation (EU) 2024/1781). 

In short: the EU DPP Registry is a central index that records Battery Passport registration and verifies technical and semantic conformity.​ The Registry is operated by the European Commission under Implementing Regulation (EU) 2026/1778. It was adopted on 16 July 2026, published on 17 July 2026, and entered into force on 6 August 2026.​ 

It does not centrally store the full Battery Passport dataset. Instead, it stores unique identifiers and specified registration data. The underlying passport data remains with the Economic Operator or an authorized DPP service provider (e.g. Circulor). On registration, the Registry checks required data, schema conformity and relevant consistency. After successful verification, it generates a unique and persistent registration identifier. A separate Commission-sealed proof of registration can be obtained as formal proof of registration.​

How the registration process will work​

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How Circulor enables this for it's customers

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Enrol your own organisation with the DPP Registry.​

Completing its own verified value-chain-actor enrolment and building the registration integration in preparation for appointment as your DPP service provider once the nomination process is published.​

The Registry is “live” but passport registration is not available yet​

The EU has confirmed that DPPs cannot yet be registered, because the semantic catalogue defining battery passport data content has not been finalised. Three items on the EU's side must be completed first:​

Expected mid Oct 2026 (Commission to confirm)​

Defines the battery passport's data content. Registration is not possible until this is published.​

No EU timeline yet (Circulor’s build is already scoped and scheduled)​

The MVP does not yet expose the API needed to connect a DPP solution nor is manual registration feasible. A generic API specification does currently exist in the JTC24 standard EN 18222:2026.​

How a provider is formally nominated to register on an operator's behalf is not yet defined. The published DPP Registry documentation currently focuses on the Economic Operator. ​

Registration over the battery’s lifecycle ​

 - Circulor can manage DPP registration on the customer's behalf, but the Economic Operator must first have verified Economic Operator status in the EU DPP Registry. The Economic Operator remains responsible for ensuring that the data in the Battery Passport is accurate and complete.​

If the battery is repurposed or remanufactured - 

it is treated as newly placed on the market. If within Battery Passport scope, it needs a new passport, linked to the original passport(s). Responsibility transfers to the Economic Operator placing the repurposed/remanufactured battery on the market or putting it into service. An authorized, verified DPP service provider may create and register the new passport on that operator’s behalf.​

its passport continues and its status is updated to “waste”. Responsibility for maintaining it transfers to the producer, appointed producer responsibility organisation (PRO), or relevant waste management operator (Article 77(7)). No new Battery Passport is required solely because the battery becomes waste. The Battery Passport ceases to exist after the battery has been recycled (Article 77(8)).​

, where we will also cover more frequently asked questions. 

The EU Digital Product Passport (DPP) registry is live: what to do now

White Papers

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Ford Otosan, Poweroad, Lucid, Aston Martin and Vale are among the first manufacturers operating on Circulor’s new platform.

Global regulations are advancing, increasing pressure on complex supply chains. From 1 February 2027, every battery with a capacity greater than 2 kWh placed on the EU market must be accompanied by a Digital Product Passport. By August 2027, those passports must stand behind due diligence obligations; documented supply chain policies, independent verification, risk assessments and annual public reporting. The EU Forced Labour Regulation (EUFLR), coming into force 14 December 2027, further requires organisations to trace and evidence working conditions deep in their supply chains or face having products removed from the market. Different rules, the same underlying need: prove what is happening across a complex, multi-tiered supply chain, or face exclusion, import bans and lasting reputational damage. 

Many companies are still deciding. Others have already moved.

 run some of the most complex supply chains in their sectors. They are the first to go live on Circulor 2.0; built for supply chain compliance at industrial scale. They are ahead of the deadline. They are not scrambling to meet it.

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The companies already on Circulor 2.0 aren't waiting to see how the 2027 deadlines play out. What they've told us they want is to understand and monitor their supply chain, so they can identify the key compliance risks at any moment. That's what we've built.

The problem Circulor 2.0 was built to solve

Compliance teams are trying to do something specific: demonstrate full regulatory adherence across complex, multi-tiered supply chains without disrupting production, overwhelming internal resources, or leaving gaps for regulators to find.

The challenge is structural. Supply chains span multiple countries and obligations that keep shifting, and most organisations manage this across disconnected systems. That fragmentation creates blind spots and under audit or enforcement, blind spots become liabilities.

By February 2027, organisations need to issue passports at production volume, track supplier compliance in real time, respond to supply chain events with full visibility, and surface non-compliance before it becomes an enforcement issue. Manual coordination, siloed data and reactive workflows cannot deliver that at scale. Circulor 2.0 can.

The heart of Circulor 2.0 is one change with a lot of consequences: your supply chain is no longer a set of disconnected records to be assembled on demand, it's a single, connected picture you can move through, from an individual product to the full network of facilities behind it.

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Built on regulatory standards, by experts

CEN/CENELEC, through JTC24, has specified the interoperability rules DPPs must follow: unique product identifiers, standardised data formats that enable regulatory interoperability, identity and access rights management, and audit-grade data integrity. 

Critically, JTC24 standards specify that DPPs must be 

backed by an independent certified third-party provider. 

Circulor’s technical team is actively engaged in JTC24 and other regulatory working groups, so the platform is built to the standard as it is being written, not adapted to it after publication. As well as being ISO 27001 and ISO 9001 certified, ensuring that security, data integrity, and quality management meet international standards. 

Read more about the European Commission standards and how they could affect your business 

Circulor was the first provider to deploy Digital Battery Passports at full industrial scale with Volvo cars. More than 550,000 live passports are already in production across regulated industries, built on years of work in real manufacturing environments at production volume. Circulor 2.0 is built on that foundation, and is ISO 27001 and ISO 9001 certified for security, data integrity and quality management.

For organisations moving to Circulor 2.0, our implementation team brings years of hands-on experience deploying compliance infrastructure across some of the world’s most complex supply chains, experience embedded directly into onboarding, so the move is structured, supported and does not disrupt operations already under regulatory pressure. 

That foundation is why organisations like Ford Otosan, Poweroad, Lucid, Aston Martin and Vale are already working on Circulor 2.0. They're using it to do the same job: turn a fragmented supply chain into a single, connected view, so the data regulators and auditors ask for is something they can see rather than scramble to assemble, so they can meet compliance deadlines as leaders, not latecomers.

Launching Circulor 2.0: first customers already live

Press Releases

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The European Commission has opened the Forced Labour Single Portal and published its first implementation guidelines. Companies have a defined window to prepare before the ban takes effect on 14 December 2027. 

On 26 June 2026, the European Commission launched the Forced Labour Single Portal, a central hub supporting the EU Forced Labour Regulation (Regulation (EU) 2024/3015). Alongside the portal, the Commission released its official implementation guidelines and a preparedness package, including an anti-forced-labour checklist for SMEs. Together they mark the start of an 18-month countdown to enforcement and the clearest signal yet of what businesses will be expected to demonstrate. 

The message from Brussels is unambiguous: preparation starts now. With an estimated 27.6 million people in situations of forced labour worldwide, the Regulation draws a firm line; from 14 December 2027, no product made with forced labour may be placed or made available on the EU market, or exported from it. 

In this update, we break down exactly what the EU Forced Labour Regulation requires, when it applies, and how it will affect your business. You can find the official materials on the 

The Forced Labour Regulation prohibits products made wholly or in part with forced labour at any stage of extraction, harvesting, production or manufacturing, whether that stage takes place inside or outside the EU. It applies regardless of a product’s origin, type, sector or value, and covers manufactured goods, agricultural products and extracted raw materials alike. Products sold online to EU customers are equally in scope. 

Crucially, the Regulation imposes an “obligation of result”. It does not create a new, standalone due diligence duty, but it holds economic operators responsible for ensuring that the products they place on the market are free of forced labour. The prohibition is described by the Commission as “unconditional and absolute”. 

Strong due diligence does not exempt a product from the ban if forced labour is present in it. What it does is shape the risk assessment: authorities must take account of the measures an operator has taken to identify, prevent and remediate forced labour when deciding whether a concern is substantiated. Due diligence and traceability are not a legal defence, but they are what separates answering a query with evidence from facing a full investigation. 

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The Regulation applies to all economic operators placing products on, making them available on, or exporting them from the EU. It applies to companies of all sizes, with dedicated support available to SMEs. 

Enforcement follows a risk-based approach. The Commission and national authorities will prioritise cases by the scale and severity of the suspected forced labour, the volume of affected products on the market, and the significance of the affected component within the final product.  

Enforcement runs in two stages. In a preliminary phase, authorities assess the information available and may ask an operator to explain how it identifies and addresses forced labour risks in its supply chain. Only where a substantiated concern remains does a formal investigation follow. This matters for preparation: an operator that can evidence a clear view of its supply chain and the steps it takes to manage risk stands the best chance of resolving questions at the preliminary stage, before a full investigation begins. Where a violation is confirmed, authorities can order products to be withdrawn, disposed of, or refused at the border, with financial penalties for non-compliance with a ban decision. 

Ban decisions also reach beyond the company investigated. A decision applies to the named product wherever it is placed on the EU market, and every decision is published on the Single Portal. A ban arising from an investigation into one of your suppliers, or a competitor who shares that supplier, can therefore affect your own products directly. Monitoring published decisions becomes part of staying compliant. 

Although the Regulation does not mandate a specific due diligence method, the Commission is explicit that due diligence and supply chain traceability is the most effective way for a company to show its products are clean. Its guidelines point to the internationally recognised OECD six-step framework:  

In practice, three jobs sit at the heart of readiness, each depends on the same foundation of supply chain visibility: 

Know where your products really come from. You cannot evidence what you cannot see. Full visibility to the mine, farm or facility is the goal, but it does not have to arrive all at once. The Commission's approach is risk-based and proportionate, so the sensible path is to map what you can see now, prioritise the highest-risk materials and regions, and extend coverage over time. Platforms that trace material provenance end to end, such as Circulor's Prove, are built to make multi-tier supply chains visible rather than assumed. 

Focus effort where the risk is. The Commission’s risk database will flag high-risk geographies and products; the task for businesses is to overlay that against their own supply base. Continuously scoring suppliers, materials and regions for forced labour risk, and surfacing anomalies automatically, turns a periodic audit into an early-warning system. 

Be ready to prove it. When an authority asks how you manage forced labour risk, the difference between a swift resolution and a costly investigation is the quality of your records. A durable, tamper-evident audit trail, cascading obligations and codes of conduct down the supply chain and tracking adherence, lets a company respond with evidence rather than assurances. 

The Commission is running a programme of sector-specific webinars through late 2026. Covering solar, textiles, electronics and semiconductors, agri-food, automotive and fisheries, a clear indication of where enforcement attention is likely to concentrate. Understanding your supply chain, the Commission notes, reduces legal, financial, operational and reputational risk, and protects businesses that already uphold high labour standards from being undercut. 

Circulor will continue to monitor developments across the Forced Labour Regulation and the wider EU regulatory landscape and to share practical guidance as implementation approaches.  

Circulor provides supply chain traceability and digital product passport solutions designed to support responsible sourcing, cross-border trade facilitation and regulatory compliance across complex industrial supply chains. 

The EU’s Forced Labour Regulation Enters Its Countdown: What this means for Your Supply Chain

News

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Bureau Veritas and Circulor announce a strategic collaboration to support battery manufacturers, automotive companies, and industrial organizations in meeting emerging global requirements related to battery traceability, digital battery passports, and responsible supply chain management.

The collaboration combines Bureau Veritas’ expertise in testing, inspection, certification, and verification services with Circulor’s Digital Traceability and Battery Passport platform capabilities. Together, the companies aim to help organizations improve transparency, strengthen supply chain due diligence, and prepare for compliance with regulations such as the EU Battery Regulation (EU) 2023/1542 and the Ecodesign for Sustainable Products Regulation (ESPR).

Regulatory expectations across the globe regarding material traceability, carbon footprint transparency, recycled content, and responsible sourcing are continuously increasing. Companies across the battery value chain face growing challenges related to data collection, supply chain visibility, and compliance verification across complex global supply chains.

Through this collaboration, Bureau Veritas and Circulor intend to jointly support customers with integrated solutions covering:

Battery regulations and digital product passport requirements are reshaping expectations for transparency and traceability across global supply chains. By combining Bureau Veritas’ verification and compliance expertise with Circulor’s digital traceability capabilities, we aim to help organizations build robust and credible battery passport and traceability programs.

The collaboration is designed to support stakeholders across the entire battery value chain, including raw material processors, component manufacturers, battery manufacturers, automotive OEMs, and energy storage system providers.

The collaboration will also explore future opportunities related to digital product passports, supply chain sustainability data management, and verification approaches to support evolving international regulatory frameworks.

By leveraging their respective technological and technical capabilities, Bureau Veritas and Circulor intend to support companies in accelerating compliance readiness while improving supply chain transparency and stakeholder confidence.

Digital traceability and trusted data are becoming essential for companies operating in regulated battery value chains. Our collaboration with Bureau Veritas will help organizations strengthen confidence in supply chain information while supporting practical implementation of battery passport and traceability requirements.

Bureau Veritas is a world leader in testing, inspection, and certification services. Bureau Veritas helps clients improve performance, manage risk, and meet challenges related to quality, health and safety, environmental protection, and sustainability.

Circulor provides supply chain traceability and digital product passport solutions designed to support responsible sourcing, cross-border trade facilitation and regulatory compliance across complex industrial supply chains.

Bureau Veritas and Circulor Partner to Support Battery Passport and Supply Chain Traceability Compliance

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Circulor, REPT Battero and TÜV Rheinland have announced the successful completion of a pilot project for the first Battery Energy Storage System (BESS) Battery Passport created based on independent third-party verified data.

The Battery Passport is created on Circulor's PROVE platform with TÜV Rheinland delivering training, data collection and compliance verification of the data, working closely with various REPT Battero departments.

Circulor PROVE platform generated the Battery Passport, in which all regulated data attributes were independently verified by TÜV Rheinland. As a trusted Testing, Inspection & Certification provider, TÜV Rheinland provides training in interpreting data requirements of the EU Battery Regulation, designing data collection schemes, and independently verifying data attributes.

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As the world's leading supply chain traceability and digital product passport solution provider, Circulor has delivered battery passports on a large scale to multiple leading global manufacturers. The platform supports the generation of battery passports in accordance with the latest requirements of the EU Battery Regulation, which is highly compatible with the coordinated standards being developed by CEN/CENELEC JTC 24. At the same time, it supports brand customisation, allowing each manufacturer's passport to be presented in line with its own branding.

As the requirement for Battery Passport under the EU Battery Regulation due to be enforced on 18 February 2027, all three parties plan to expand the collaboration to ensure REPT Battero meets the compliance .

The first Battery Passport for a BESS product is now live, showing the EU Battery Regulation can be met in full. Every storage manufacturer faces the same deadline. 

 with our team to discuss what it means for you. 

Book a call

The First Battery Energy Storage System (BESS) Battery Passport pilot complete

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From Legal Obligation to Technical Specification: The EU Digital Product Passport Standards Explained

The European Commision (DG GROW) has confirmed the publication schedule for the eight harmonised European standards that will define how Digital Product Passports (DPPs) become interoperable in the frame of the European DPP System Framework. The first six standards passed the voting process beginning of April and are set for publication at the end of May 2026, with the remaining two following in Q3 2026. For operators preparing for DPP obligations, this is a critical milestone.

Download our guide to the mandatory data requirements for Battery Passports under Regulation (EU) 2023/1542 

The Standards That Will Define DPP Compliance

The Digital Product Passport is the central instrument of the EU's Ecodesign for Sustainable Products Regulation (ESPR), which came into force in July 2024. Under ESPR, a wide range of products on the EU market will require a DPP. Mandatory requirements begin on 18 February 2027 for batteries demanded by the EU Battery Regulation that enforces interoperability with the EU DPP System Framework. Other product sectors  like iron and steel, packaging, and construction materials following in 2028, and ICT products, tyres, aluminium, and textiles in 2029.

ESPR creates the legal obligation to issue a DPP. JTC 24's standards define how DPPs become interoperable in the DPP System Framework,  not what data it must contain, which will be defined be corresponding delegated acts to come.  The EU DPP System Framework defines the technical architecture through which that data is structured, stored, accessed, and verified. These standards will be the baseline against which system design is assessed. The eight standards cover the full technical architecture of a compliant DPP system:

What's Coming Next: A Calendar of Confirmed Milestones

The publication of the CEN/CENELEC (JTC 24) standards is only one piece of a rapidly accelerating regulatory programme. Based on the latest guidance from DG GROW, the confirmed timeline now extends well into the end of the decade:

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Looking further ahead, a new technical committee, ISO/IEC JTC 5 Digital Product Passport, is scheduled to begin work in September 2026 that shall standardise cross sectoral and cross system interoperability of DPPs at the international level, a framework with potential to be a global benchmark.

The Battery Passport: No Extensions, No Exceptions

The first hard deadline remains 18 February 2027, when the Battery Passport becomes mandatory under the EU Battery Regulation. Some companies still assume a delay or grace period; the Commission has been explicit there will be none. Some technical points; battery carbon footprint, recycled content, and certain methodological elements, will need further clarification through additional standardisation and secondary legislation, but the core obligation is fixed.

A wider body of secondary legislation is also taking shape, with delegated and implementing acts in development covering service provider rules and certification, battery passport access rights, recognition of due diligence schemes, industrial battery carbon footprint methodology, EV battery carbon footprint label classes, and recycled content calculation and verification. For battery manufacturers and their supply chains, every one of these instruments will shape day-to-day compliance.

Who Needs to Pay Attention and Why Third- party backup matters

The scope is broad. Millions of European companies are expected to be required to issue Digital Product Passports in the coming years, spanning automotive and energy storage to fashion, consumer electronics, and construction. For manufacturers with supply chains across multiple tiers and geographies, the time required to gather, verify, and structure primary upstream data means preparation cannot wait.

The publication of the JTC 24 standards is the moment ambiguity ends. The technical specification is being fixed, and infrastructure that does not align with it will need to be rebuilt. It is not enough to collect sustainability data and attach it to a product identifier, that data must be structured, authenticated, stored with defined persistence, and accessible through compliant APIs. 

One requirement deserves particular attention. The standards make explicit that every DPP must be backed up through a certified, independent third-party provider. This is not an optional safeguard, it is a structural feature of the system, designed to ensure DPPs remain accessible for the full lifetime of a product, even if the original economic operator ceases to exist. For manufacturers, the practical implication is direct: in-house infrastructure alone will not satisfy the requirement. Choosing a proven, compliant DPP partner is now part of the regulation, not a commercial preference.

Circulor: Contributing to the Standards, Designed Around Them

At Circulor, our regulatory team has been closely following JTC 24's work since the committee's inception in December 2023 and contributing by reviewing during public consultations across the full stack of standards. As technical lead for the Battery Pass Consortium and a recognised contributor to the JTC 24 enquiry process, we have helped shape the regulatory framework now reflected in the engineering of our platform. The standards have not required Circulor to change course, because the course was set with these requirements in mind.

The Window for Getting This Right Is Narrowing

The JTC 24 publication schedule is a signal, not a starting pistol. The companies best positioned for compliance are those already building the supply chain relationships, data processes, and technical infrastructure a credible, standards-aligned DPP requires. Regulatory deadlines are fixed. The standards are imminent. The DPP Registry will go live in July. The question for every manufacturer in scope is no longer what will be required, but whether their current approach will meet it.

The EU's Digital Product Passport Standards Are Here: What They Mean.

LONDON, 12 February 2026 – Circulor, the global leader of enterprise Trust & Assurance and Digital Product Passport solution, has partnered with Tees Valley Lithium (TVL), one of the UK’s and Europe’s most strategically important lithium refining projects, to deliver a digital tracking platform that records material inputs and outputs across the refinery and enables the measurement of recycled content at a batch level. 

This capability allows TVL to evidence where feedstock is sourced from, how it is processed, and the recycled content contained in each batch of product. From 2027, EU Battery Regulations will require digital battery passports for batteries placed on the EU market, including verified information on material origin and recycled content.

“We are delighted that Tees Valley Lithium has chosen Circulor to support the implementation of its Digital Product Passport and to establish and prove the provenance of its lithium products. Knowing and proving where mined and recycled feedstock comes from and how it moves through the supply chain is now a regulatory and commercial expectation.”

From 2031, the EU Battery Regulation mandates a minimum recycled lithium content of 6% in batteries placed on the EU market. TVL is designing its operations to exceed this requirement from first production, targeting 20% recycled content, supported by on-site lithium recovery, access to recycled feedstock and batch-level digital tracking.

By embedding this capability early, TVL is positioned to meet future regulatory requirements and customer expectations without impacting refinery operations or project delivery.

The Partnership with Circulor enables digital tracking of the origin of feedstock at batch-level and recycled content, ensuring full compliance with the EU Battery Regulation requirements for batteries placed on the EU market.

“By partnering with Circulor to deliver full supply-chain traceability, we are embedding recycled content and transparency into our production from day one. These collaborations strengthen the resilience of the UK’s battery materials supply chain and position Tees Valley Lithium at the forefront of low-carbon, sustainable lithium refining in Europe.”

As battery manufacturers prepare for Digital Product Passports to become mandatory, this partnership demonstrates how transparency, recycled materials and regulatory compliance can be built into supply chains from the very beginning rather than retrofitted later. Circulor is proud to support Tees Valley Lithium as it develops Europe’s first independent lithium hydroxide refinery and helps set a new standard for responsible battery materials production.

Circulor partners with Tees Valley Lithium to deliver traceable recycled lithium for their battery supply chain

The BatteryPassReady project which started at April this year officially kicked off its comprehensive stakeholder engagement with their supporting partners last Tuesday. This marks the next chapter in Europe's journey toward mandatory digital battery passports. Building on the success of the original Battery Pass Consortium, this second-phase initiative brings together over 80 supporting partners, including manufacturers, technology providers, standards bodies, and research organizations, to turn regulatory requirements into industry-wide reality.

 is designed to prepare the entire battery value chain for compliance with the EU Battery Regulation. While the first Battery Pass project laid the conceptual and technical groundwork, this new phase tackles the practical challenges of full-scale implementation. The focus is on developing robust data verification processes, establishing clear communication protocols with the central EU Digital Product Passport (DPP) registry, and ensuring interoperability across the industry.

This is where theory meets practice. As the EU Battery Regulation comes into force, manufacturers, suppliers, and technology providers need proven frameworks they can deploy at scale. BatteryPassReady aims to deliver exactly that; bridging the gap between regulatory compliance and operational reality.

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Circulor served as technical lead for the original Battery Pass Consortium and has already demonstrated what's possible by launching the world's first production vehicles with digital battery passports through our work with Volvo Cars in June 2024. We've officially applied to join BatteryPassReady as a supporting partner and look forward to contributing our real-world deployment experience to this critical next phase.

Want to learn more about our Battery Passport solution? 

BatteryPassReady launches stakeholder engagement to prepare industry for EU Battery Passport implementation

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This month, China's expanding their export controls on critical materials potentially reshaping global supply chains, their emerging 15th Five-Year Plan will define the next wave of industrial competition, and there is growing resistance to the European’s 2035 combustion engine phase-out. 

With enforcement deadlines tightening and geopolitical tensions rising, the question is no longer whether regulations will impact your business, but how prepared you are to navigate them. From supply chain traceability to battery passports, we're breaking down what's happening now, and what you need to do next.

China tightens grip on critical materials

China’s Ministry of Commerce has announced 

, related technologies and equipment, effective Nov 8, just before the 90-day US trade truce expires. Even if framework deals with the US stops export controls, China could still weaponise its dominance on critical minerals. Companies must obtain a licence to export products containing trace amounts of Chinese REEs and those derived using Chinese technology, regardless of where production occurs.

China’s new rules target lithium-ion cells/ packs at ≥300 Wh/kg and key production equipment. With most EV batteries below that, the squeeze lands on next-gen chemistries (silicon-dominant, lithium-metal, solid-state) and by broader licensing to Chinese-origin materials, magnets, and overseas tech, they also affect LREEs.

China begins mapping out its 15th five-year plan

The 14th plan reshaped global competition, using industrial policy and subsidies to propel EVs, lithium-ion batteries and solar, disrupting industries in Europe and the US, stoking trade tensions. Now China’s Central Committee has begun drafting the 

, set for March 2026, emphasising high-quality, innovation-driven growth, technological self-reliance and a greener, more secure energy system. Pushing to “accelerate the development of industrial clusters” in new energy, new materials, aviation/aerospace and the low-altitude economy. It also aims to lift domestic demand, build a unified national market, and bolster advanced manufacturing, semiconductors, new energy and digital technologies.

Germany joins Italy in calling for changes to the 2035 zero emission mandate

, in coming months. Germany and Italy have joined together to push for changes to ban new petrol and diesel cars from 2035. They argue that the current law unfairly penalises carmakers and should recognise other low-emission technologies, not just electric vehicles. Demanding that cars running on renewable fuels, such as biofuels or synthetic e-fuels, should still be allowed after the deadline.

Circulor Founder Named to the 2025 TIME100 Climate List

TIME has recognized our founder, Douglas Johnson-Poensgen, in the Innovator category of its 2025 TIME100 Climate list, highlighting Circulor’s impact on building sustainability into the supply chain through traceability and battery passports. 

Volvo has already achieved its 2025 CO₂ targets for new cars, driven in part by proactive traceability strategies and the introduction of the world’s first battery passport in the EX90. 

Navigating the EU Battery Regulation with PROVE

Circulor’s PROVE platform enables businesses to meet the EU Battery Regulation's stringent requirements by tracing and evidencing supply chain activities in real-time. 

November 2025 Newsletter: Regulations Tighten and Shift to Implementation. What You Need to Know for 2026

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