Battery Lifecycle Triage: Evidence, Authority, and Decision Risk

Abstract

The battery passport will make lifecycle information more visible, but visibility is not the same as decision-grade certainty. At the point where an electric vehicle, industrial, or light means of transport battery leaves its first use, the next actor must decide whether the battery is suitable for repair, direct reuse, repurposing, remanufacturing, recycling, or waste handling. That decision depends on evidence distributed across the original manufacturer, the battery management system, the owner or operator, repair records, insurers, transport documents, physical inspection, test reports, repurposers, recyclers, waste managers, and regulators.

This paper maps that evidence problem before proposing any system design. It distinguishes five required data levels: model, individual battery, shipment, test event, and status change. It then maps the authority of key actors, classifies evidence types, traces the decision paths available at handoff, and identifies recurrent failure modes. The central finding is that battery lifecycle triage is not a single data-access problem. It is an authority problem: the actor who needs to make the next decision rarely controls all evidence required to make that decision safely, legally, and economically.

Research Question And Scope

The working question is:

What evidence is required to move a battery from first use into its next lifecycle path, and whose authority makes that evidence reliable enough to act on?

The scope is intentionally narrower than a platform proposal, market analysis, or implementation architecture. It is a structured evidence map for lifecycle triage. The primary legal frame is Regulation (EU) 2023/1542 concerning batteries and waste batteries, because it defines the battery passport, state-of-health access, responsibility transfer, and used-versus-waste shipment evidence for batteries placed on the EU market.^{1European Parliament and Council. Regulation (EU) 2023/1542 concerning batteries and waste batteries. EUR-Lex, current consolidated EUR-Lex record accessed 2026-05-04. https://eur-lex.europa.eu/eli/reg/2023/1542/oj?locale=en} The technical frame is drawn from battery passport implementation guidance, UL 1974, national laboratory work on sparse-data second-use evaluation and recycling-system analysis, peer-reviewed disassembly and direct-recycling literature, and IEA market context.^{2Battery Pass Consortium / DIN / DKE. Battery Passport Content Guidance / DIN DKE SPEC 99100. acatech, content guidance published 2023-12-08; DIN DKE SPEC 99100 published Jan/Feb 2025. https://en.acatech.de/publication/battery-passport-content-guidance/3UL Standards & Engagement. UL 1974: Evaluation for Repurposing or Remanufacturing Batteries. Second edition, published 2023-11-10. https://www.shopulstandards.com/ProductDetail.aspx?productId=UL19742S20231110 ; ULSE overview, 2023-11-22. https://ulse.org/insight/ul-standards-engagement-un-sustain...4Smith, K. Battery Second-Use Reconditioning Based on Sparse Data and Models: Cooperative Research and Development Final Report, CRADA Number CRD-21-17528. NREL/TP-5700-93187, 2025. https://doi.org/10.2172/25834945National Renewable Energy Laboratory. Battery Recycling Supply Chain Analysis and LIBRA-related research pages; see also Weigl, D. and Young, D. "Impact of Automated Battery Sorting for Mineral Recovery from Lithium-Ion Battery Recycling in the United States." Resources, Conservation and Recyclin...6Kaarlela, T., Villagrossi, E., Rastegarpanah, A., San-Miguel-Tello, A., and Pitkaaho, T. "Robotised disassembly of electric vehicle batteries: A systematic literature review." Journal of Manufacturing Systems 74, 2024, 901-921. https://doi.org/10.1016/j.jmsy.2024.05.0137Gaines, L., Dai, Q., Vaughey, J., and Gillard, S. "Direct Recycling R&D at the ReCell Center." Recycling 6(2), 31, 2021. https://doi.org/10.3390/recycling60200318International Energy Agency. Global EV Outlook 2025: Electric vehicle batteries. 2025. https://www.iea.org/reports/global-ev-outlook-2025/electric-vehicle-batteries}

This is not legal advice and does not attempt to specify a compliance program. It is a research map of the evidence and authority structure that any credible future solution would need to respect.

The Problem At Handoff

There is an awkward point in a battery's life where every actor wants certainty and no single actor owns it.

The OEM may know the design basis, chemistry, software logic, safety assumptions, and original compliance evidence. The battery management system may contain state-of-health and operational data. The owner may know duty cycle, storage practice, charging behavior, and whether the asset was abused. The insurer may know whether the vehicle was flooded, burned, or written off. The repairer may know whether modules were replaced. The repurposer may perform fresh sorting and grading. The recycler may only see a heavy, high-voltage, potentially damaged object arriving in a container or on a pallet.

The receiving actor then has to answer a practical question: is this battery an asset, a repair candidate, a direct reuse item, a repurposing feedstock, a remanufacturing candidate, a recyclable material stream, or waste?

The wrong answer has consequences. A reusable battery may be destroyed prematurely. A damaged pack may be placed into second-life service. A shipment may be misdeclared as used goods when the evidence legally points to waste. A recycler may receive mixed chemistries that reduce recovery value or increase processing risk. A repairer may install a mismatched module. A repurposer may overestimate remaining life because the only available evidence is a stale BMS value.

The passport matters because it creates a structured record. The triage problem remains because the next decision depends on whether that record is current, physically matched to the battery, accessible to the actor making the decision, and supported by measured evidence where measurement is necessary.

Legal And Technical Baseline

Regulation (EU) 2023/1542 requires, from 18 February 2027, an electronic battery passport for each LMT battery, each industrial battery above 2 kWh, and each electric vehicle battery placed on the market or put into service in the EU.^{9Regulation (EU) 2023/1542, Articles 77 and 78 and Annex XIII. These provisions establish the covered battery categories, battery passport content, public and restricted access classes, unique identification, responsibility for accuracy and updates, responsibility transfer after reuse/repurposing/...} The passport contains both battery-model information and individual-battery information. Some data is public. Some is accessible only to notified bodies, market surveillance authorities, and the Commission. Some is accessible only to persons with a legitimate interest, such as actors needing data for dismantling, repair, remanufacturing, second-life activity, or recycling.^{9Regulation (EU) 2023/1542, Articles 77 and 78 and Annex XIII. These provisions establish the covered battery categories, battery passport content, public and restricted access classes, unique identification, responsibility for accuracy and updates, responsibility transfer after reuse/repurposing/...}

From 18 August 2024, up-to-date data for the parameters used to determine state of health and expected lifetime must be contained in the battery management system for stationary battery energy storage systems, LMT batteries, and electric vehicle batteries. Read-only access is required for legally entitled purchasers, independent operators, waste management operators, and third parties acting on their behalf for purposes including residual value, remaining lifetime, further use, reuse, repurposing, and remanufacturing.^{10Regulation (EU) 2023/1542, Article 14 and Annex VII, "Information on the state of health and expected lifetime of batteries." https://eur-lex.europa.eu/eli/reg/2023/1542/oj?locale=en}

The regulation also makes responsibility transfer explicit. The economic operator placing the battery on the market is responsible for passport accuracy, completeness, and keeping the data up to date. If a battery is prepared for reuse, prepared for repurposing, repurposed, or remanufactured, responsibility can transfer to the economic operator that places that changed battery on the market or puts it into service. That changed battery must have a new passport linked to the original passport or passports. If the battery becomes waste, responsibility transfers to the producer, a producer responsibility organisation where appointed, or a selected waste management operator. The passport ceases to exist after the battery has been recycled.^{9Regulation (EU) 2023/1542, Articles 77 and 78 and Annex XIII. These provisions establish the covered battery categories, battery passport content, public and restricted access classes, unique identification, responsibility for accuracy and updates, responsibility transfer after reuse/repurposing/...}

That legal structure does not eliminate operational judgment. It creates a chain of record responsibility, access categories, and required data. It still leaves an intake actor with the task of reconciling the record with the physical battery and with new evidence generated after first use.

The implementation challenge is recognised in the battery passport ecosystem itself. Battery Pass and DIN DKE SPEC 99100 define and organise data attributes to implement Article 77 and Annex XIII, including mandatory data and voluntary circularity additions.^{2Battery Pass Consortium / DIN / DKE. Battery Passport Content Guidance / DIN DKE SPEC 99100. acatech, content guidance published 2023-12-08; DIN DKE SPEC 99100 published Jan/Feb 2025. https://en.acatech.de/publication/battery-passport-content-guidance/} Battery Pass technical guidance emphasises interoperability, trust, access control, and distributed data repositories, including public and restricted access in practice.^{11Battery Pass Consortium. Technical Guidance: Requirements for the Digital Product Passport. Press release and resource page, 2024-03-26. https://thebatterypass.eu/news/consortium-publishes-technical-guidance-and-software-demonstrator-for-eu-battery-passport/} CIRPASS similarly identifies the Digital Product Passport as a way to reduce information asymmetry while also noting barriers around cost, data availability, data privacy, administrative burden, reliable data, and incentives for actors to update data across the chain.^{12Wautelet, T. and Ayed, A-C. Exploring possible Digital Product Passport (DPP) use cases in battery, electronics and textile value chains. CIRPASS D2.2, Version 2.0, 2024. https://zenodo.org/records/10974901}

The policy logic is therefore clear: passports are necessary infrastructure. The evidence problem is what happens when a passport is asked to support a concrete downstream decision under uncertainty.

Analytical Thesis

Battery lifecycle triage is a structured conflict between five things:

1. Identity: whether the record, QR code, serial number, modules, and physical object refer to the same battery.
2. Condition: whether the battery's current physical, electrical, thermal, and chemical state is known.
3. Status: whether the battery is original, repaired, reused, repurposed, remanufactured, recyclable, or waste.
4. Authority: whether the actor making or updating a claim has standing, competence, and liability for that claim.
5. Access: whether the actor making the decision can see the evidence needed to make it.

A battery passport can help with all five, but it does not resolve them automatically. A passport field may be accurate at creation and stale at intake. A measured BMS value may be accessible but insufficient. A legally declared shipment may be well documented but technically unsuitable. A test report may be recent but tied to only part of the consignment. A recycler may have a legitimate need for composition data but still need physical sorting because the pack in front of them may not match the record.

The minimum analytical unit is therefore not "a battery passport." It is a decision dossier: a set of identity, condition, status, authority, access, and timestamped evidence sufficient for the lifecycle path under consideration.

Required Data By Level

The first mapping task is to separate evidence by level. Many errors in battery lifecycle thinking come from treating model data, pack data, shipment data, test data, and legal status data as if they were interchangeable. They are not. Each level answers a different question.

This table has two implications.

First, downstream decisions cannot be supported by model data alone. Knowing that a pack is nominally NMC, LFP, or NCA is useful, but not enough to determine safety, remaining life, damage, or legal status at handoff.

Second, downstream decisions cannot be supported by measured condition alone. A fresh capacity test may show residual performance, but it does not prove legal used-versus-waste status, original chemistry, accident history, or authority to place the battery into a new application.

The core unit of trust is the link between levels: model to individual battery, individual battery to shipment, shipment to test event, and test event to status change.

Actor Authority

The second mapping task is to identify which actors have authority over which evidence. Authority here means more than possession of data. It includes legal responsibility, competence to generate evidence, access rights, and the ability to make a claim that another actor can reasonably rely on.

This distribution creates an authority gap. The OEM may know the model but not the incident. The insurer may know the incident but not the chemistry. The repairer may know the repair but not the legal status. The recycler may need composition but not receive it. The regulator may have access to compliance evidence that cannot be disclosed to every commercial actor. The repurposer may create the most relevant current evidence, but only after intake risk has already been assumed.

The battery passport changes the shape of this gap by creating a shared record and access-right framework. It does not collapse all authority into one actor.

Evidence Types

The third mapping task is to distinguish evidence by evidentiary strength. Lifecycle decisions fail when claims of different quality are treated as equivalent.

State of health illustrates why these distinctions matter. It can be measured, inferred, or legally required. The EU regulation requires up-to-date BMS data for state-of-health and expected-lifetime parameters in specified battery categories, but a BMS value is not automatically an independently verified second-life guarantee.^{10Regulation (EU) 2023/1542, Article 14 and Annex VII, "Information on the state of health and expected lifetime of batteries." https://eur-lex.europa.eu/eli/reg/2023/1542/oj?locale=en} NREL's second-use reconditioning work is built around rapid state-of-health characterization, lifetime modelling, and forecasting under sparse-data conditions.^{4Smith, K. Battery Second-Use Reconditioning Based on Sparse Data and Models: Cooperative Research and Development Final Report, CRADA Number CRD-21-17528. NREL/TP-5700-93187, 2025. https://doi.org/10.2172/2583494} Sparse data can support a decision, but it should be labelled as sparse-data inference, not treated as complete proof.

The same problem appears in used-versus-waste classification. A declaration that a shipment contains used batteries is legally meaningful only when it is supported by the required documentation, functionality proof, testing records, declaration, and transport protection. In the absence of proof and appropriate protection, the regulation treats the object as waste and presumes an illegal shipment.^{13Regulation (EU) 2023/1542, Annex XIV, "Minimum requirements for shipments of used batteries." https://eur-lex.europa.eu/eli/reg/2023/1542/oj?locale=en}

Evidence type therefore has to travel with the evidence itself. A future triage model that records "state of health: 78%" without recording source, date, method, access class, actor, and uncertainty would be too weak for the decision it invites.

Decision Path Map

The fourth mapping task is to connect evidence to the decision path. A battery is not simply "good" or "bad." It can be technically unsuitable for propulsion but suitable for stationary storage. It can be unsuitable for second life but valuable for recycling. It can have strong residual capacity but still be waste because shipment evidence is missing or damage risk is unacceptable.

The paths are not hierarchical in a simple sense. Repair and reuse may preserve the most product value, but they require credible identity, condition, and incident evidence. Repurposing can preserve value when automotive performance is no longer sufficient, but it requires application-specific testing and risk evaluation. Remanufacturing is evidence-heavy because it changes the technical basis of the battery while aiming for the same or similar use. Recycling is not merely a fallback; it can be the rational path where chemistry, damage, safety, or age make continued use unjustified. Waste handling is not a commercial failure; it is the lawful response when evidence or condition no longer supports continued product status.

UL 1974 is important because it frames repurposing and remanufacturing as sorting, grading, diagnosis, maintenance, and continued-viability work rather than a simple residual-capacity check.^{3UL Standards & Engagement. UL 1974: Evaluation for Repurposing or Remanufacturing Batteries. Second edition, published 2023-11-10. https://www.shopulstandards.com/ProductDetail.aspx?productId=UL19742S20231110 ; ULSE overview, 2023-11-22. https://ulse.org/insight/ul-standards-engagement-un-sustain...} The EU regulation's own definition of remanufacturing is similarly specific: it involves technical operations on a used battery, disassembly and evaluation of cells and modules, and restoration of capacity to at least 90 percent of original rated capacity with limited state-of-health divergence between cells.^{14Regulation (EU) 2023/1542, Article 3, including definitions of state of health, preparation for re-use, preparation for repurposing, repurposing, remanufacturing, treatment, waste battery, waste management operator, and recycler. https://eur-lex.europa.eu/eli/reg/2023/1542/oj?locale=en}

This is why "triage" is the right framing. Triage is not the destination. It is the evidence moment before the destination.

Failure Mode Map

The fifth mapping task is to identify common failure modes. These are not edge cases. They are the predictable ways a battery lifecycle record loses decision value.

These failure modes show why a simple score is premature. The quality of a battery lifecycle decision depends on which failure modes have been actively excluded. A pack with high measured capacity but a mismatched passport is not a high-confidence reuse candidate. A pack with complete model data but no current test is not a repurposing-ready asset. A shipment with a declaration but no functionality proof is not necessarily a legal used-battery shipment.

Used Versus Waste As The Cleanest Test Case

The used-versus-waste distinction exposes the evidence problem most clearly because it turns incomplete evidence into a legal status problem.

Under Annex XIV of Regulation (EU) 2023/1542, a holder claiming that a shipment contains used batteries rather than waste batteries must be able to provide evidence including a sale or transfer document for direct reuse, proof of evaluation or testing, a declaration that the material is not waste, and protection against damage during transport. The testing record must include battery identity where applicable, year of production if available, the responsible testing company, test types, test results, and test date.^{13Regulation (EU) 2023/1542, Annex XIV, "Minimum requirements for shipments of used batteries." https://eur-lex.europa.eu/eli/reg/2023/1542/oj?locale=en}

If that proof and protection are absent, the object is considered waste and the load is presumed to be an illegal shipment.^{13Regulation (EU) 2023/1542, Annex XIV, "Minimum requirements for shipments of used batteries." https://eur-lex.europa.eu/eli/reg/2023/1542/oj?locale=en}

This is not simply an administrative rule. It demonstrates the difference between product identity and legal status. A battery may be technically capable of reuse and still fail the shipment evidence requirement. Conversely, a well-documented shipment may still require intake testing because legal used status does not prove hidden damage, chemistry, or second-life suitability.

In research terms, used-versus-waste status is a boundary condition. It shows that lifecycle triage must combine documentary evidence, measured evidence, actor responsibility, and physical protection.

State Of Health As Necessary But Insufficient Evidence

State of health is central because it is one of the few lifecycle indicators explicitly recognised in law and directly relevant to residual value. The regulation requires BMS-contained state-of-health and expected-lifetime data for specified battery categories and links access to purposes such as residual value, remaining lifetime, further use, reuse, repurposing, and remanufacturing.^{10Regulation (EU) 2023/1542, Article 14 and Annex VII, "Information on the state of health and expected lifetime of batteries." https://eur-lex.europa.eu/eli/reg/2023/1542/oj?locale=en}

But state of health is not the decision.

It does not, by itself, prove:

• that the battery was not damaged in a collision or flood
• that the pack has not been opened, altered, or reconfigured
• that modules have not been replaced with mismatched parts
• that the chemistry is correct for the intended recycling route
• that the enclosure, connectors, isolation, and thermal system are safe
• that BMS software or counters have not been reset
• that the battery is suitable for a specific stationary-storage duty cycle
• that a shipment is legally used rather than waste

State of health is also method-dependent. A BMS-derived value may be based on proprietary algorithms and operating assumptions. A laboratory capacity test may be more transparent but slower and more expensive. A sparse-data model may be useful at scale but should disclose uncertainty. NREL's sparse-data second-use work is relevant precisely because it treats state-of-health characterisation and lifetime forecasting as modelling problems under limited evidence, not as a single field lookup.^{4Smith, K. Battery Second-Use Reconditioning Based on Sparse Data and Models: Cooperative Research and Development Final Report, CRADA Number CRD-21-17528. NREL/TP-5700-93187, 2025. https://doi.org/10.2172/2583494}

The correct analytical role of state of health is therefore as a necessary input to triage, not as the whole triage decision.

Chemistry, Sorting, And Recovery Value

Chemistry changes the downstream answer.

IEA's 2025 battery analysis reports that battery demand for the energy sector reached about 1 TWh in 2024 and that recycling feedstock remains limited in the short term, restricting the immediate impact of recycling on mineral demand.^{8International Energy Agency. Global EV Outlook 2025: Electric vehicle batteries. 2025. https://www.iea.org/reports/global-ev-outlook-2025/electric-vehicle-batteries} At the same time, battery chemistries are shifting, including the growth of lower-cobalt chemistries such as LFP. That shift affects recycler economics because processes historically benefited from the value of recovered cobalt and nickel.

National laboratory and peer-reviewed recycling work reaches the same operational point from a different direction. LIBRA-based analysis identifies chemistry and sorting as important variables in recycling-system outcomes, with automated sorting helping recyclers selectively process material based on chemistry and material makeup.^{5National Renewable Energy Laboratory. Battery Recycling Supply Chain Analysis and LIBRA-related research pages; see also Weigl, D. and Young, D. "Impact of Automated Battery Sorting for Mineral Recovery from Lithium-Ion Battery Recycling in the United States." Resources, Conservation and Recyclin...} ReCell direct-recycling work emphasises that preserving cathode structure can retain more value than breaking materials down into elemental streams, especially as cobalt content declines.^{7Gaines, L., Dai, Q., Vaughey, J., and Gillard, S. "Direct Recycling R&D at the ReCell Center." Recycling 6(2), 31, 2021. https://doi.org/10.3390/recycling6020031} But direct recycling makes chemistry verification more important, not less, because the value of the output depends on recovering and upgrading a known, relatively pure material stream.

This means the same state-of-health result can lead to different decisions depending on chemistry and process context. An LFP pack with good residual capacity may be attractive for stationary reuse but less attractive for conventional metal-value recovery. A high-nickel pack may carry different recovery economics and risk. A mixed or misidentified stream can undermine both safety and value.

Chemistry is therefore not a background attribute. It is a decision variable.

Physical Disassembly As Evidence

Digital traceability eventually meets the physical pack.

A 2024 systematic review of robotised EV battery disassembly identifies non-standardised pack design, handling risks, human-robot collaboration, AI-assisted automation, and design-for-disassembly as active challenges in end-of-life battery processing.^{6Kaarlela, T., Villagrossi, E., Rastegarpanah, A., San-Miguel-Tello, A., and Pitkaaho, T. "Robotised disassembly of electric vehicle batteries: A systematic literature review." Journal of Manufacturing Systems 74, 2024, 901-921. https://doi.org/10.1016/j.jmsy.2024.05.013} The point is not that robotics will remove the evidence problem. The point is that dismantling itself is evidence-generating work. Fasteners, adhesives, module layout, swelling, corrosion, thermal damage, tampering, and connector condition can confirm or contradict the record.

This is especially important for remanufacturing, repurposing, and direct recycling. Remanufacturing may require cell and module evaluation. Repurposing may require safe reconfiguration or enclosure redesign. Direct recycling benefits from known and separable material streams. In each case, a passport can reduce uncertainty before the pack is opened, but it cannot remove the need to inspect the pack that actually arrived.

The physical battery remains the final reference object.

Evidence Conflict Logic

Because evidence is distributed, conflicts should be expected. The following logic is not a software design; it is a research-derived discipline for interpreting evidence.

This conflict logic is where many future product ideas will be tempted to oversimplify. A triage score may be commercially useful, but it would only be defensible if it preserved the chain from evidence type to actor authority to decision path.

What The Map Shows

The completed map can be summarised in five findings.

First, required data exists at multiple levels. Model, individual-battery, shipment, test-event, and status-change data answer different questions and cannot substitute for each other.

Second, actor authority is fragmented by design. The OEM, owner, repairer, insurer, repurposer, recycler, waste manager, economic operator, and regulator each control evidence that can be decisive for at least one lifecycle path.

Third, evidence quality varies. Claimed, measured, inferred, legally declared, access-controlled, and independently verified evidence should not be collapsed into a single undifferentiated data field.

Fourth, each decision path requires a different evidence bundle. Repair, reuse, repurposing, remanufacturing, recycling, and waste handling are not points on one linear ladder. They are distinct decisions with distinct legal, technical, and economic requirements.

Fifth, common failure modes are predictable. Stale records, inaccessible records, mismatched packs, missing tests, hidden damage, wrong chemistry, and undocumented incidents are not implementation annoyances. They are the central risks that lifecycle triage must detect.

The working thesis can now be sharpened:

The battery passport will make lifecycle data more available, but battery lifecycle decisions become trustworthy only when evidence is mapped to level, actor authority, evidence type, timestamp, access right, and decision path.

Research Boundary Before A Solution

This research deliberately stops before proposing a system. That boundary matters.

A solution proposal would need to decide how to capture evidence, who can write which fields, how to integrate BMS readout, how to manage access rights, how to record tests, how to handle uncertainty, how to interface with passport infrastructure, how to support shipment documentation, how to resolve conflicts, and how liability is assigned when a downstream decision fails.

Those are architecture and governance questions. They should come after the evidence map, not before it.

The disciplined next step is not to ask "what platform should exist?" It is to ask:

• Which minimum evidence bundle is required for each decision path?
• Which evidence must be measured at intake rather than inherited from a record?
• Which actor has authority to update status after repair, repurposing, remanufacturing, or waste classification?
• Which restricted data must be accessible for repairers, repurposers, recyclers, and waste managers to operate safely?
• Which conflicts require quarantine, retesting, regulator escalation, or waste handling?
• Which data can be inferred responsibly, and how should uncertainty be shown?

Only after those questions are answered does it make sense to discuss a product, protocol, scoring model, or marketplace.

Conclusion

The battery passport is a major step toward a more transparent and circular battery economy. It creates a structured lifecycle record, formal access classes, state-of-health visibility, and responsibility transfers. But the passport does not remove the need for triage. It makes triage more possible.

The hard problem is not whether data can exist. It is whether the next actor can trust the right evidence, at the right level, from the right authority, for the decision in front of them.

A battery at handoff is not just a pack. It is a physical object, a legal product, a potential waste item, a set of BMS readings, a history of use and incidents, a chemistry stream, a safety risk, and a future economic claim. Triage is the discipline that determines which of those identities controls the next step.

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Last revised 2026-05-04. This is a research article. It intentionally does not propose a platform, product, scoring method, marketplace, or implementation architecture.

Cover image: "Battery Pack for BMW-i3 Electric Vehicle" by RudolfSimon, via Wikimedia Commons, licensed under CC BY-SA 3.0.

Footnotes

1. European Parliament and Council. Regulation (EU) 2023/1542 concerning batteries and waste batteries. EUR-Lex, current consolidated EUR-Lex record accessed 2026-05-04. https://eur-lex.europa.eu/eli/reg/2023/1542/oj?locale=en ↩

2. Battery Pass Consortium / DIN / DKE. Battery Passport Content Guidance / DIN DKE SPEC 99100. acatech, content guidance published 2023-12-08; DIN DKE SPEC 99100 published Jan/Feb 2025. https://en.acatech.de/publication/battery-passport-content-guidance/ ↩ ↩²

3. UL Standards & Engagement. UL 1974: Evaluation for Repurposing or Remanufacturing Batteries. Second edition, published 2023-11-10. https://www.shopulstandards.com/ProductDetail.aspx?productId=UL1974_2_S_20231110 ; ULSE overview, 2023-11-22. https://ulse.org/insight/ul-standards-engagement-un-sustainable-development-goals-2030-updated-standard-contributes-ev/ ↩ ↩²

4. Smith, K. Battery Second-Use Reconditioning Based on Sparse Data and Models: Cooperative Research and Development Final Report, CRADA Number CRD-21-17528. NREL/TP-5700-93187, 2025. https://doi.org/10.2172/2583494 ↩ ↩² ↩³

5. National Renewable Energy Laboratory. Battery Recycling Supply Chain Analysis and LIBRA-related research pages; see also Weigl, D. and Young, D. "Impact of Automated Battery Sorting for Mineral Recovery from Lithium-Ion Battery Recycling in the United States." Resources, Conservation and Recycling 192, 2023. https://www.nrel.gov/transportation/battery-recycling-supply-chain-analysis ; https://doi.org/10.1016/j.resconrec.2023.106936 ↩ ↩²

6. Kaarlela, T., Villagrossi, E., Rastegarpanah, A., San-Miguel-Tello, A., and Pitkaaho, T. "Robotised disassembly of electric vehicle batteries: A systematic literature review." Journal of Manufacturing Systems 74, 2024, 901-921. https://doi.org/10.1016/j.jmsy.2024.05.013 ↩ ↩²

7. Gaines, L., Dai, Q., Vaughey, J., and Gillard, S. "Direct Recycling R&D at the ReCell Center." Recycling 6(2), 31, 2021. https://doi.org/10.3390/recycling6020031 ↩ ↩²

8. International Energy Agency. Global EV Outlook 2025: Electric vehicle batteries. 2025. https://www.iea.org/reports/global-ev-outlook-2025/electric-vehicle-batteries ↩ ↩²

9. Regulation (EU) 2023/1542, Articles 77 and 78 and Annex XIII. These provisions establish the covered battery categories, battery passport content, public and restricted access classes, unique identification, responsibility for accuracy and updates, responsibility transfer after reuse/repurposing/remanufacturing/waste status, and passport termination after recycling. https://eur-lex.europa.eu/eli/reg/2023/1542/oj?locale=en ↩ ↩² ↩³

10. Regulation (EU) 2023/1542, Article 14 and Annex VII, "Information on the state of health and expected lifetime of batteries." https://eur-lex.europa.eu/eli/reg/2023/1542/oj?locale=en ↩ ↩² ↩³

11. Battery Pass Consortium. Technical Guidance: Requirements for the Digital Product Passport. Press release and resource page, 2024-03-26. https://thebatterypass.eu/news/consortium-publishes-technical-guidance-and-software-demonstrator-for-eu-battery-passport/ ↩

12. Wautelet, T. and Ayed, A-C. Exploring possible Digital Product Passport (DPP) use cases in battery, electronics and textile value chains. CIRPASS D2.2, Version 2.0, 2024. https://zenodo.org/records/10974901 ↩

13. Regulation (EU) 2023/1542, Annex XIV, "Minimum requirements for shipments of used batteries." https://eur-lex.europa.eu/eli/reg/2023/1542/oj?locale=en ↩ ↩² ↩³

14. Regulation (EU) 2023/1542, Article 3, including definitions of state of health, preparation for re-use, preparation for repurposing, repurposing, remanufacturing, treatment, waste battery, waste management operator, and recycler. https://eur-lex.europa.eu/eli/reg/2023/1542/oj?locale=en ↩