Navigating digital transformation in the battery information ecosystem: a roadmap for the UK toward compliance with EU Battery Passports and Smart Labeling regulations

1 Introduction

The global battery industry is undergoing a fundamental transformation, driven by the urgent need to improve sustainability, resource efficiency, and circularity. With the rapid expansion of electric vehicles (EVs), portable electronics, and renewable energy storage solutions, ensuring the responsible production, use, and disposal of batteries has become a critical priority. To address these challenges, the European Union (EU) has introduced the Battery Regulation (EU 2023/1542; European Commission, 2023), which replaces 2006/66/EC and introduces far-reaching sustainability and traceability requirements. Central to this Regulation are digital information systems—the Battery Passport and enhanced Smart Labeling (including for products containing batteries)—that will enable lifecycle transparency through standardized datasets on composition, carbon footprint, recycled content, and due diligence in supply chains (European Commission, 2023). These measures represent a major step toward data-driven sustainability governance in Europe.

However, the transition to digital compliance poses significant operational and informational challenges. Meeting the Regulation's digital obligations requires producers to generate, verify, and exchange complex datasets on across multiple stakeholders, many of whom lack interoperable ICT infrastructures (Berger et al., 2022). While large manufacturers are investing in Enterprise data systems, many smaller firms depend on legacy or manual processes. The situation is particularly acute for UK-based producers, who must navigate EU market requirements without an equivalent domestic regulation and amid post-Brexit regulatory policy divergence. Despite increasing policy attention to digital product passports, little empirical research has examined how prepared UK organizations actually are to meet these new digital compliance demands.

The research gap—the absence of evidence on the awareness, readiness and capability of UK producers to implement digital-compliance systems—motivates the present study. Previous work has primarily addressed the technical architecture of digital passports (Huikkola et al., 2022; Ströher et al., 2025) or their conceptual role in sustainable supply chains (Köhler and Pizzol, 2020), but few studies investigate the organizational and systemic barriers faced by industry actors during early implementation. Understanding these barriers is essential for aligning national policy, industry investment, and standardization efforts with emerging EU requirements.

Therefore, this paper aims to assess the state of digital readiness among UK battery producers in relation to the EU Battery Regulation's digital compliance obligations. It pursues four inter-related objectives:

• To evaluate current level of awareness and organizational preparedness regarding Battery Passports and Smart-Labeling requirements.
• To identify key technological, informational, and organizational barriers constraining digital transformation.
• To contextualize the UK's position by comparing it with leading EU initiatives and technical frameworks for digital compliance.
• To propose evidence-based policy recommendations, and for enhancing UK digital readiness through investment in interoperable infrastructures and participation in international standardization activities.

By integrating survey data, stakeholder dialogue, and expert interviews, this study provides the first systematic analysis of UK industry preparedness for battery-passport and smart label implementation. The findings offer practical insights for policymakers and producers seeking to align with EU sustainability and traceability objectives while maintaining competitiveness in global supply chains. Beyond the empirical contribution, the paper also adds to the academic discourse on digital product passports and regulatory digitisation, demonstrating how compliance systems can act as catalysts for wider digital transformation.

The remainder of this article is organized as follows. Section 2 reviews the regulatory background and outlines the main compliance obligations under the EU Battery Regulation. Section 3 details the mixed-methods approach employed. Section 4 presents the empirical findings on awareness, information availability, and digital-readiness challenges among UK producers. Section 5 and 6 discusses the findings in the context of existing research and implications for UK industry and policy, concluding with recommendations.

2 Background and context

To contextualize the study's focus on digital compliance readiness, this section outlines the main provisions of the EU Battery Regulation (EU 2023/1542), its implications for UK producers, and the international frameworks shaping emerging digital-passport architectures.

2.1 Compliance obligations under the EU Battery Regulation (EU/2023/1542): Battery Passports and Smart Labeling

Regulation (EU) 2023/1542 fundamentally reshapes European battery governance by imposing legally binding obligations on all batteries placed on the EU market (European Commission, 2023). It replaces Directive 2006/66/EC (European Commission, 2006) and targets resource efficiency, lifecycle transparency, and sustainable raw-material sourcing. Critically, the Regulation introduces digital compliance mechanisms that require manufacturers to create and maintain a “Battery Passport” for Electric Vehicle (EV) batteries, Light Means of Transport (LMT) batteries, and Industrial batteries exceeding 2 kWh (Articles 65, 77–78). From February 2027, such batteries must each carry a secure digital record of core data: material composition, carbon footprint, supply-chain due diligence evidence, and verified recycled content. This “passport” is accessed via a QR code affixed to the battery, allowing authorized stakeholders to interrogate and update lifecycle information in real time.

A second requirement mandates “smart labeling” for all battery categories from December 2026 (Article 13(5)–(6)). Through QR-based codes and standardized data fields, end-users and downstream operators can retrieve details on performance, safety, and end-of-life handling (European Commission, 2023). Alongside these digital obligations, the Regulation stipulates further compliance measures: compulsory carbon footprint disclosures (Articles 7–8), escalating recycled content targets for cobalt, lithium, nickel, and lead (Article 8; Annex X), and performance and durability standards aimed at prolonging operational life (Articles 9–10). Due diligence provisions (Articles 39–47) require producers to establish traceable, responsible supply chains addressing environmental and social risks in raw material extraction. Together these measures position the Battery Passport as a central instrument of Europe's circular economy and product traceability strategy.

Digital product passport concepts more broadly derive from lifecycle management and circular economy principles, providing structured mechanisms to store, verify, and exchange relevant product information from manufacture to end-of-life (Adisorn et al., 2021; Walden et al., 2021; Götz et al., 2022; Jousse, 2024). Battery Passports focus on granular attributes such as chemical composition, carbon footprint, and State of Health (SoH). Products containing batteries—such as e-scooters and power tools—may require both a product-level DPP under the forthcoming Ecodesign for Sustainable Products Regulation (ESPR; European Commission, 2022) and a battery specific BP to comply with the new rules. This dual obligation highlights the importance of interoperable and integrated digital infrastructures that can link product and component-level datasets seamlessly.

2.2 Implications for UK businesses

UK exporters to the EU must fully comply with the EU regulation by the 2026–2027 deadlines, with full Battery Passport implementation due by February 2027. Producers, importers and distributors will need to generate and maintain verified digital records in line with the EU standards. Non-compliance may result in market access restrictions, financial penalties, or reputational damage. UK producers must therefore invest in robust digital infrastructures capable of real-time data collection, secure storage and interoperability with EU-mandated platforms. Such systems will enable traceability for raw materials and accurate calculations of sustainability metrics but demand enhanced digital expertise, either internally or through partnerships with specialized IT providers. Because the UK has not yet introduced equivalent domestic regulation, firms may face dual compliance obligations and additional costs to maintain EU market access.

2.3 International frameworks and supporting digital product passport implementation

To situate these regulatory developments within the broader digital governance landscape, a secondary horizon scanning review was conducted of major EU and international initiatives. Table 1 summarizes the key frameworks shaping the technical and governance foundations for Battery Passports and Digital Product Passports.

Table 1. Key international initiatives and frameworks relevant to battery passports and digital product passports.

These initiatives collectively show that global efforts are converging toward federated data-space architectures standardized identifiers, and common interoperability standards. They provide an essential contextual reference for the empirical analysis that follows, illustrating the technological environment within which UK battery producers must operate.

3 Methodology

This study adopts a mixed-methods research design, integrating quantitative survey data with qualitative insights from a round table discussion and follow-up interviews. This approach enables a comprehensive analysis of digital compliance readiness among UK battery producers, combining broad industry trends with in-depth perspectives from key stakeholders. The study aligns with the broader research objectives but focuses specifically on digital transformation challenges and opportunities within the evolving regulatory landscape. While the full empirical results have been made available in a full-length report format (King and Timms, 2023; Timms and King, 2023), this article synthesizes and interprets these findings through the lens of digital readiness and data-governance capability.

The data collection period spanned February to September 2023 with ongoing horizon scanning analysis to capture emerging regulatory and technical developments. Stakeholders represented in the research included battery manufacturers, supply chain stakeholders, digital infrastructure and solution providers, retailers, regulatory and legal experts, recycling and compliance, academics, cybersecurity and data governance specialists.

3.1 Data collection methods

A structured online survey was conducted to capture the current level of awareness, readiness, and perceived challenges regarding digital compliance obligations for Battery Passports and Smart Labels. The survey targeted UK-based organizations and companies that supply into the UK, focusing on: regulatory awareness, organizational readiness, information and data availability, and barriers to digital transformation. A total of 80 responses were received, representing large enterprises (21), medium-sized enterprises (28), small enterprises (23) and micro-businesses (8). The survey was distributed via targeted emails to organizations listed on the UK's Public Register of Battery Producers and through industry stakeholder networks, including DEFRA's Batteries Working Group.

A follow-up roundtable discussion was convened to contextualize the survey findings and explore industry perspectives on digital compliance. The session included seven expert participants from academia and industry, complemented by four semi-structured interviews with compliance officers, digital transformation experts, and representatives from retail and global battery supply chains. Participant selection followed a purposive sampling strategy designed to capture a diversity of organizational scales and positions across the supply chain. Round-table invitations were issued to individuals with demonstrable expertise in battery manufacturing, compliance, and digital-system development, while interviewees were chosen from survey respondents who volunteered for follow-up engagement and from key organizations identified by sectoral diversity and relevance to EU market access. This approach ensured the inclusion of varied stakeholder perspectives while remaining focused on those directly affected by the EU Battery Regulation.

In addition to the primary data collection, a secondary horizon scanning review was undertaken to situate the empirical findings within the evolving international regulatory and technical landscape. This review systematically examined European Commission communications, CEN-CENELEC and IEC standardization documents, project reports (e.g., CIRPASS, Battery Pass, Catena-X, Global Battery Alliance), and relevant academic and industry literature.

3.2 Analytical approach

A sequential explanatory design was employed, in which quantitative survey findings provided a baseline understanding, later contextualized through qualitative discussions and interviews. Survey data were analyzed using descriptive statistics, focusing on key indicators of digital readiness, awareness, and challenges. Round table and interview transcripts were analyzed using thematic coding, identifying recurrent patterns in industry concerns, technical barriers, and strategic recommendations. Triangulating data from multiple sources ensured a robust and multi-faceted analysis of the UK battery industry's digital transformation readiness.

Comparable mixed-methods approaches have been widely used to assess industry preparedness in rapidly evolving regulatory or technological contexts (e.g., Mittal et al., 2018; Ghobakhloo et al., 2022), providing a methodological precedent for combining quantitative and qualitative stakeholder data in this study.

3.3 Study limitations

Several limitations should be acknowledged. Although the survey achieved a reasonable response rate (n = 80) across enterprise sizes, the sample may not fully represent the breadth of the UK battery sector. Respondents were self-selecting and more likely to be organizations already aware of regulatory developments, potentially introducing bias toward higher readiness levels. The qualitative sample, comprising a single round table and four interviews, provided valuable depth but limited generalisability. Nevertheless, triangulation across methods, participant categories, and data sources mitigated these risks and supports the credibility of the overall conclusions.

4 Findings: UK readiness

Section 4 presents the empirical findings on the level of awareness, information availability, and digital-readiness challenges among UK producers. Quantitative results from the national survey are integrated with qualitative insights from the round-table discussion and follow-up interviews.

4.1 Awareness and readiness among UK producers

4.1.1 Levels of regulatory awareness

The survey of 80 organizations revealed considerable gaps in the overall awareness of the new EU Battery Regulations among UK producers. Notably, 63% of all organizations surveyed indicated they were unaware of the incoming regulations, a figure rising to 73% among UK-based suppliers exporting to the EU market. This general unawareness was particularly pronounced amongst importers and manufacturers, who are notably responsible for regulatory compliance but showed the lowest awareness levels.

The roundtable participants, experts from industry and academia, expressed little surprise at this lack of awareness, attributing it primarily to the vast increase in regulatory complexity compared to previous directives. One participant highlighted, “The comparison is immeasurable—the 2006 battery directive document was about 20–26 pages long, while this document for the battery regulation is in the hundreds.” They also noted the difficulties in tracking evolving regulatory obligations across multiple revisions of the regulatory texts, which have created an environment of uncertainty, described vividly by an expert from the EV battery sector as “an avalanche or tsunami of new regulations coming from the EU” indicating the challenge of maintaining awareness amidst a rapidly evolving regulatory landscape.

4.1.2 Understanding of digital compliance requirements

The survey further indicated that even among those organizations aware of the regulations, the understanding of specific compliance obligations was limited. For instance, after being provided with a regulatory summary, less than half (48%) of respondents responsible for batteries at the Beginning of Life (BoL) acknowledged accountability for compliance. Of these, only 32% were aware of the QR code requirement, and even fewer knew about obligations related to lifelong digital electronic records (18%) or the need to commission digital systems for battery passports (18%). This clearly indicates substantial gaps in both awareness and detailed understanding of specific digital compliance requirements.

Industry roundtable discussions supported these findings, noting that while larger companies might have dedicated compliance roles, awareness and strategic readiness were still questionable. The roundtable discussions confirmed these survey findings, noting extensive uncertainty regarding roles, responsibilities, and practicalities of implementation. Participants highlighted the need for clear, specific guidance due to confusing regulatory language and unclear definitions. As one participant succinctly expressed, “It's so confusing it's unbelievable,” capturing industry frustration.

4.1.3 Information and technological readiness

When considering readiness to meet the digital requirements, survey responses indicated significant concerns about data and ICT readiness. A majority of respondents (76%) described themselves as “Yet to consider changes”—in terms of readiness for SL and BP requirements. Only 7% had advanced beyond this initial stage, suggesting most organizations have not even begun significant preparatory actions.

Further discussions during the round table underscored these technological readiness challenges. Participants identified that many organizations, particularly SMEs, currently lack suitable IT infrastructure or expertise to implement compliant systems. One panel member clearly outlined this issue: “SMEs are more likely not to have any infrastructure and will be starting from scratch, while big businesses will have legacy systems underpinning their operations and manufacturing and will need to create modules to adapt them.”

4.1.4 Organizational and structural readiness

Organizational readiness was another significant concern identified by the survey, where 58% of respondents indicated that substantial organizational restructuring would be necessary for compliance. Furthermore, only 23% of organizations reported existing structures enabled efficient data collection, creation, and reporting. The scarcity of dedicated roles like enterprise architects (12% prevalence) exacerbates the issue.

The roundtable experts emphasized that regulatory compliance demands a holistic organizational shift, extending beyond compliance departments to encompass procurement, operations, and strategic management. Yet, less than 10% of respondents indicated having clear roadmaps for developing their business and technical capabilities. As one participant noted, “It can easily take 2 years to develop, test, and implement a modification like this,” stressing the urgency for action due to lengthy development timelines for necessary ICT changes.

4.1.5 Data accessibility and quality concerns

Both the survey and roundtable discussions revealed substantial concerns regarding the accessibility and quality of data required for digital compliance. The survey results showed limited availability of essential battery information, such as recycled content (64% unavailable), hazardous material (58%), and critical raw material content (56%). Even among organizations with data access, many questioned the accuracy or completeness of their existing records.

Roundtable participants expanded on these issues, particularly highlighting the challenges in tracing detailed supply chain data beyond immediate suppliers. One expert pointedly stated, “Once you get past the first or second tier of the supply chain, you're operating on faith rather than knowledge,” reflecting the difficulty in obtaining verifiable and complete information. Another expert remarked on the disproportionate cost of accessing accurate data compared to its value for some intermediary battery products.

4.1.6 Concerns over compliance burdens

Organizations consistently viewed compliance as a substantial administrative, technical, and financial burden. The survey noted that a majority (52%) viewed compliance as primarily administrative burdensome. Experts at the roundtable reinforced these concerns, citing the significant ongoing operational costs and potential competitive disadvantages. Some examples were given where organizations had withdrawn from certain markets due to “certain country-specific requirements” and the overhead of delivery.

Specific contentious points included the complexity of calculating accurate environmental impact assessments, such as the carbon footprint, where methodologies remain undefined or contested. One participant remarked on the ambiguity of certain metrics like recycling rates and suggested a more detailed focus on tracing all materials through their entire lifecycle. Moreover, experts indicated that the operational burden could potentially result in competitive disadvantages or market withdrawal, especially for SMEs, due to the disproportionate cost and complexity. One stakeholder pointedly expressed, “If my company becomes legally responsible to compile these records, it might be necessary to withdraw from this marketplace.”

4.2 Information availability and perspective on information requirements

The majority of participants across the survey, roundtable, and interviews expressed deep-seated concerns about the difficulty of gathering robust data on materials, processes, and environmental impacts. Despite existing business practices for product information, many felt ill-equipped to fulfill the enhanced disclosure obligations required under the new EU Battery Regulation.

4.2.1 Missing data and hard-to-obtain parameters

Quantitative survey findings indicate that many organizations lack critical details about their battery products:

• Recycled material content: 64% reported incomplete records.
• Hazardous material composition: 58% lacked full documentation.
• Critical raw materials (e.g., cobalt, lithium, nickel): 56% indicated insufficient data.
• Battery separator info: 86% unavailability.
• Electrolyte composition: 85% unavailability.
• Cell casing supply chain: 80% unavailability.
• Cathode and anode supply chain: 76% unavailability.

Notably, these gaps were not limited to SMEs. Larger manufacturers with extensive supply chains reported similar challenges. As one interviewee stated, “We have a multi-tiered supply network worldwide, and it's virtually impossible to verify every detail needed for compliance.” This missing data undermines efforts to declare accurate recycled content or to validate a battery's overall carbon footprint.

Respondents also highlighted that State of Health (SoH) data—a metric crucial for second-life applications and end-of-life valuation—was often missing or recorded inconsistently. About 68% said they had no reliable mechanism to track SoH across a battery's lifetime, which is particularly relevant for industrial and electric vehicle (EV) batteries.

4.2.2 Information quality and reliability challenges

Where data existed, its quality was frequently questioned. Over half of the survey's free text responses mentioned “unverified supplier statements” and “fragmented records,” painting a picture of patchy documentation. One roundtable participant lamented, “We rely on a patchwork of spreadsheets and ad hoc reporting—none of which is standardized or auditable.” This lack of harmonization impacts all battery types but is especially pronounced for industrial and EV batteries, which typically demand more detailed technical reporting.

A recurring point of contention was the inconsistency of data formats and the absence of standard methodologies to gather and verify information. Participants expressed concerns that even well-intentioned compliance efforts might fail if official audits discover discrepancies or a lack of systematic documentation.

4.2.3 Uncertainty about regulatory requirements

Stakeholders frequently cited confusion regarding the depth and scope of required disclosures. Terms such as “carbon footprint,” “lifecycle assessment,” and “recycled content” were viewed as inconsistently or insufficiently defined in the secondary legislation, leaving producers uncertain of what authorities expect. One interviewee commented, “We don't mind investing in better data processes, but we need clarity. Are they asking for a cradle-to-gate carbon footprint or a cradle-to-grave one?”

In the free text section of the survey, multiple respondents requested clearer benchmarks or approved calculation methods. The perceived ambiguity particularly affected light means of transport (LMT) batteries and portable batteries, for which stakeholders reported limited guidance on how to measure or certify compliance, given the varying scales and end-user contexts.

4.2.4 In-use “battery events” tracking

A key aspect of the regulation is the requirement to document “battery events” during a product's in-use phase; covering data on maintenance, repairs, repurposing, and refurbishment. About 62% of surveyed respondents indicated they had no systems in place to track these events in real time. This shortfall was most acute for EV and industrial batteries, where the high value of second-life applications (e.g., stationary energy storage) makes accurate in-use tracking even more critical.

Roundtable participants underscored that many existing ERP or PLM systems do not readily capture in-field battery performance data, let alone more granular events such as partial repairs or cell replacements. One industrial battery manufacturer summarized, “We're not just dealing with a single battery anymore, it's multiple lifecycles, possibly in different geographies. The regulation expects us to track all of that. Right now, we can't.”

4.2.5 Which battery types are most affected?

Overall, industrial and EV batteries appear to face the greatest data-related challenges, largely due to their complex architectures and multi-tier supply chains. Nonetheless, the new obligations for LMT and even portable batteries also present major hurdles, with a significant portion of producers lacking the resources or clarity to document compliance adequately. Several respondents stressed that smaller-volume portable batteries are subject to nearly the same level of scrutiny, risking disproportionate cost burdens.

4.2.6 Balancing feasibility and regulatory goals

While most interviewees acknowledged the rationale behind transparency, sustainability, and circular economy targets, they cautioned that the regulatory requirements might be “too ambitious too quickly.” Many repeated the call for a phased approach to data obligations, along with robust guidance on standards and best practices. Without such direction, they fear the mismatch between regulatory ambition and on-the-ground feasibility will result in widespread non-compliance.

Collectively, these findings show that missing or unreliable data, the complexity of in-use battery event documentation, and ambiguous definitions combine to create a daunting compliance landscape. Significant investments in data infrastructure, clearer standards, and improved supplier collaboration are needed to address the EU Battery Regulation's ambitious new requirements effectively.

4.3 Challenges in digital readiness

The transition to digital workflows and systems for compliance under the EU Battery Regulation requires UK battery producers to establish integrated digital solutions for tracking, storing, and sharing data across the battery lifecycle. However, findings from the survey and roundtable discussions reveal significant technological, regulatory, financial, supply chain, and organizational barriers to successful implementation. Many UK businesses lack the necessary IT infrastructure, face uncertainties in regulatory interpretation, and struggle with interoperability issues across regional and global frameworks. Financial constraints, workforce capability gaps, and resistance to change further hinder digital transformation efforts, leaving producers concerned about future alignment with EU battery rules. The subsections below synthesize the most pressing challenges, incorporating the original evidence you provided as well as enhancements for clarity and structure.

4.3.1 Financial barriers: the cost burden of digital compliance

One of the most significant challenges for UK producers is the financial cost of implementing and maintaining robust digital compliance systems. In the survey, 54% of respondents explicitly cited financial constraints as their primary obstacle, underscoring the strain this places on businesses of all sizes.

While large multinational corporations can spread compliance costs across higher production volumes, many SMEs and mid-tier manufacturers simply lack the capital for substantial IT system upgrades, data management tools, and continuous compliance monitoring. Hidden expenses—like third-party audits, cybersecurity measures, and integrating legacy data—add an additional layer of complexity.

As one medium-sized battery producer emphasized, “For a company of our size, the cost of implementing a Digital Product Passport system is a major operational expense. We're talking about developing new digital infrastructure, retraining staff, and securing third-party compliance verification—all of which add up quickly.” Another survey participant warned, “It's not just about buying a system—it's about making it work with everything else we already have. Retrofitting digital compliance into our existing operations is a massive challenge.”

Roundtable experts remarked that in certain EU Member States, producers can access national-level grants or incentives to offset digital transformation costs. By contrast, UK respondents felt they were at a disadvantage because there is “nothing equivalent,” creating an uneven playing field for domestic producers competing with European peers.

Overall, many survey respondents and roundtable participants see digital compliance as an unfunded mandate—one that could widen the competitive gap between large industry players and smaller UK-based businesses.

4.3.2 Technological and informational barriers: legacy systems and data interoperability

A second pivotal challenge stems from outdated IT infrastructure and fragmented data systems. While certain producers have begun modernizing, 76% reported limited or no digital transformation plans aligned with compliance requirements. Additionally, 52% of survey respondents said their existing IT systems are not equipped for real-time data management or interoperability with external regulatory platforms.

• Reliance on legacy tools: many UK firms continue to rely on spreadsheets, siloed software, or offline databases—making large-scale data exchange and long-term monitoring impractical. One participant from the roundtable, representing an automotive supplier, observed: “Implementing a robust track-and-trace system with real-time data exchange is an ordeal—especially when so many of our suppliers still operate on pen and paper.”
• Data format and standardization gaps: approximately 44% of respondents pinpointed lack of data standardization as a key challenge. This problem is not confined to SMEs; larger enterprises with extensive international supply networks struggle to merge or compare data across multiple systems. A digital solutions expert warned, “Without standardization, we risk a patchwork of proprietary digital solutions that don't talk to each other. That's going to create massive inefficiencies and compliance gaps.”
• Cybersecurity concerns: while transitioning to cloud-based compliance systems can offer real-time oversight, multiple respondents flagged potential cybersecurity and privacy implications. A compliance officer remarked, “A Digital Product Passport means creating a permanent, verifiable digital record of every battery transaction and lifecycle event. But who is responsible for securing that data? What happens if the system is breached?”

These issues collectively point to a deep-rooted technological inertia. Even firms ready to invest are uncertain which platforms, standards, or security protocols will meet evolving EU and potential UK legislative benchmarks, causing them to delay major ICT rollouts.

4.3.3 Regulatory uncertainty and ambiguity

Unclear guidance regarding battery passport specifications, smart labeling standards, and data maintenance responsibilities emerged as a third prominent hurdle. In the survey, 67% of participants described the regulation's language around digital recordkeeping and accountability as “too vague,” making it difficult to decide on how to design or future-proof internal systems.

• Evolving technical guidelines: several respondents expressed frustration that technical parameters for Battery Passports (referenced in Articles 13(6), 77 & 78 of the EU Battery Regulation) remain incomplete or under revision. Many of these details will be set or refined via delegated acts issued by the European Commission, while others hinge on new or updated harmonized standards that the Commission has requested from CEN and CENELEC due for finalization 31st December 2025. One compliance manager put it this way: “We want to be proactive, but the rules keep shifting. How do we commit to an IT investment when we don't know if the system we build today will be compliant in 2 years?”
• Divergent trajectories: concerns also surfaced about the potential divergence between UK and EU regulations, especially post-Brexit. One participant warned of a “nightmare scenario” in which UK producers are forced to maintain two distinct sets of digital compliance frameworks—one tailored to EU markets, the other aligned with any future standalone UK rules.
• Global mismatches: the interviews highlighted apprehension about parallel or conflicting standards in North America and Asia. If US or Chinese battery regulations mandate different data structures or reporting cadences, UK-based global firms could be compelled to juggle multiple overlapping compliance platforms. As one multinational battery producer stated, “That's a nightmare for businesses operating across borders.”

In the short term, these ambiguities deter companies from substantial investments, fearing near-future rule changes could render current systems obsolete. Over half of the free text survey responses advocated a clearer, more prescriptive approach from regulators, particularly given that many obligations (for instance, those tied to Articles 7, 8, 10, and 14 on carbon footprint, recycled content, performance and durability, and battery state-of-health metrics) are waiting for further delegated acts and clarifications from standardization bodies.

4.3.4 Supply chain-related barriers: data availability and supplier engagement

A major obstacle to accurate digital compliance is the difficulty of collecting reliable, granular data from global supply networks. Indeed, 64% of surveyed respondents reported lacking critical material composition data, and 58% struggled to verify recycled content or hazardous substances.

• Cross-border data gaps: many UK producers rely on suppliers in regions not covered by EU rules. One compliance manager put it succinctly: “We are being asked to provide data that our suppliers don't even collect yet. If they're outside the EU, they have no legal obligation to provide this information, so we're stuck.” This misalignment can block essential data flows for verifying battery composition or lifecycle impacts.
• Trust and reliability issues: even within the EU, a roundtable participant stated, “Once you move beyond the first tier of suppliers, you're often operating on faith rather than knowledge. The deeper you go into the supply chain, the harder it becomes to verify information.” Another multinational power tool company voiced fears that forcing suppliers to disclose proprietary manufacturing details might lead them to withhold cooperation or pass on higher costs.
• Varying views on transparency: while some participants argued that granular reporting fosters sustainability and fosters higher social responsibility standards, others worried that it could impose disproportionate burdens. “Forcing suppliers to disclose everything about their materials and processes could have unintended consequences,” cautioned one participant, “especially if they see no direct business benefit.”

These findings highlight the tension between ambitious traceability goals and the on-ground realities of incomplete data, limited supplier buy-in, and potential pushback from partners outside the EU.

4.3.5 Organizational challenges: culture, skills, and change management

Beyond external barriers, many UK businesses grapple with internal constraints. Around 41% of survey respondents admitted to lacking in-house expertise for digital transformation, while only 23% reported having a comprehensive digital strategy that meshes with regulatory compliance objectives.

• Skill gaps and training: a compliance specialist lamented, “The reality is, most companies don't have dedicated digital compliance teams. The burden is falling on people who already have other responsibilities, and they simply don't have the expertise to implement these systems effectively.” Upskilling or recruiting specialized staff takes time and money, particularly for smaller firms.
• Management reluctance: several free text responses pointed out that senior leadership often prioritizes short-term operational efficiency over long-term digital investment. One participant noted, “Resistance to change is especially high among SMEs, where budgets are tight and owners are wary of intangible returns on compliance-driven upgrades.”
• Siloed departments: roundtable discussions emphasized that successful digital compliance requires cross-departmental coordination—spanning R&D, manufacturing, supply chain, and finance. However, many companies lacked formal structures or incentives to break down functional silos, making it difficult to centralize data or standardize reporting practices.

This points to a need for not just technical solutions but also organizational transformation that fosters collaboration, encourages upskilling, and legitimizes compliance as a strategic priority.

4.3.6 Interoperability and system fragmentation

Interoperability—defined as the seamless exchange and interpretation of data across different ICT platforms—emerged as a universal concern. Survey data indicates that 52% of UK firms still rely on disconnected or outdated systems, while 44% cited difficulties in data standardization. Fragmentation therefore poses risks of inefficiencies, inconsistent reporting, and heightened compliance costs.

• Patchwork of proprietary systems: a compliance manager from a UK-based battery manufacturer described how “We have suppliers using multiple different software systems, all with different data formats. There's no unified approach, and without interoperability, compliance becomes a logistical nightmare.”
• No agreed digital architecture: roundtable participants repeatedly stressed the absence of a globally accepted, standardized digital framework for Battery Passports. “Companies are waiting for guidance,” one technology provider noted, “but without alignment, we'll see a proliferation of proprietary platforms that don't communicate with each other.” This problem is exacerbated by potential divergence among China, North America, and the EU.
• Security and governance: even if companies adopt the same technical protocols, data governance remains a challenge—particularly around intellectual property, liability for inaccuracies, and system security. “A Digital Product Passport is essentially a shared ledger across multiple stakeholders,” remarked one roundtable expert. “If we don't define accountability and ownership, interoperability efforts won't solve deeper trust issues.”

4.3.7 Sustainable and circular business practices

Twenty-six respondents had an opinion on whether the new regulations would result in more sustainable and circular business practices. On the whole, there was a very positive attitude in relation to reporting requirements and business practices. 100% (n. 26/26) agreed that manufacturers would switch toward suppliers with better governance regimes, 92% (n. 23/25) agreed that manufacturers would improve the oversight of their value chains, 88% (n. 22/25) agreed that the impact of products on society and the environment would be reduced, and 81% (n. 21/26) agreed that importers, distributors, and retailers would prioritize products from suppliers with better governance regimes.

5 Discussion

This study reveals a network of interdependent risks and opportunities shaping the digital-readiness landscape of the UK battery sector. The findings demonstrate substantial gaps in awareness, data governance, ICT capability, supply-chain coordination, and regulatory clarity. When interpreted alongside emerging academic research and international data-space initiatives, it becomes clear that UK producers face distinctive structural constraints in preparing for Battery Passports (BPs) and Smart Labeling (SL). The following discussion integrates empirical insights with the wider literature and identifies pathways for UK organizations, policymakers, and standards bodies to strengthen digital readiness.

5.1 Digital-readiness gaps and systemic risks

The findings highlight three interconnected domains of risk: (i) technological fragmentation; (ii) organizational capability deficits; and (iii) regulatory uncertainty, which collectively hinder digital readiness in the UK.

Technological fragmentation emerged as one of the most significant constraints. 76% of survey respondents and all round-table participants emphasized widespread reliance on legacy ICT, manual documentation, and unstructured data storage. Similar barriers have been identified in the wider digital-transformation and Industry 4.0 literature, which emphasizes that fragmented ICT infrastructures, inconsistent metadata structures, and poor systems integration significantly impede digital adoption (Gonzálvez-Gallego et al., 2015; Mittal et al., 2018; Ghobakhloo et al., 2022; Khan and Abonyi, 2022; Atieh et al., 2025). These challenges are also documented in recent analyses of Digital Product Passport (DPP) systems, which underline the centrality of machine-readable data and interoperable architectures for enabling circular-economy transitions (Kemmner et al., 2025).

Organizational capability and governance gaps form the second major risk domain. Participants described challenges in mobilizing cross-functional expertise in data governance, cybersecurity, and verification—competencies that are widely recognized as prerequisites for effective traceability systems (Razak et al., 2023). A distinctive UK-specific pattern was the expectation that domestic organizations must guide international suppliers who themselves lack regulatory awareness. This “reverse dependency” dynamic amplifies capability pressures and complicates supply-chain alignment. Parallel arguments in the policy literature show that insufficient organizational capacity can undermine even well-designed digital infrastructures (Tarroja et al., 2024).

The findings align with wider analyses showing that many organizations across industrial supply chains lack integrated information systems capable of supporting real-time data exchange and fragmented supply chains create additional complexities in material traceability and sustainability assessments (Garcia-Torres et al., 2024; Schaëfer et al., 2025). Similar research highlights that insufficient digital capability, limited systems interoperability, and immature enterprise architectures create major barriers to adopting data-intensive regulatory systems (Atieh et al., 2025). For SMEs in particular, these technical constraints are compounded by resource limitations and limited prior experience of digital transformation, as extensively documented in the digital-readiness literature (Mittal et al., 2018; Ghobakhloo et al., 2022).

Regulatory uncertainty further intensifies these challenges. Despite Regulation (EU) 2023/1542 being adopted law, stakeholders reported confusion around technical definitions (such as State of Health), reporting templates, verification processes, and division of responsibilities within multi-actor battery lifecycles. Similar observations appear in circular-economy research, which highlights that unclear responsibilities and inconsistent data requirements create major obstacles for lifecycle transparency (Köhler and Pizzol, 2020). In the UK context, the absence of clear dissemination channels and the need to navigate multiple EU Member State enforcement authorities further reduces confidence and slows preparatory action.

These three domains: (i) technology; (ii) organization; and (iii) regulation, mutually reinforce one another. Poor ICT capability intensifies staffing burdens; unclear obligations suppress investment; and inadequate guidance leaves firms without reliable interpretative support. Together, they form systemic obstacles to readiness.

5.2 Data governance, supply-chain collaboration and lifecycle complexity

Beyond these foundational risks, the study identifies several UK-specific structural challenges that merit deeper attention.

Supply-chain information bottlenecks remain a critical constraint. Participants reported difficulties accessing upstream data on composition, carbon footprint, and lifecycle events, with some suppliers reluctant to share information due to confidentiality or competitive concerns. These issues reflect well-established patterns of information asymmetry in digital-traceability systems (Kouhizadeh et al., 2019) and echo broader concerns in the battery-sustainability literature regarding the availability and reliability of data required for lifecycle assessments (Tarroja et al., 2024).

Lifecycle complexity presents another major challenge. Stakeholders emphasized the misalignment between the Regulation's “single responsible operator” logic and the reality of multi-actor battery systems spanning manufacture, integration, retail, repair, reuse, repurposing, and recycling. Academic analyses similarly show that in circular-economy contexts, decentralized lifecycles and shifting ownership structures complicate data continuity and responsibility allocation (Köhler and Pizzol, 2020). Second-life applications introduce further complexities with challenges relating to data availability, performance degradation, liability, and verification across repurposed batteries (Patel et al., 2024): concerns echoed by UK participants.

Standards, metrics and test-method uncertainty also impede progress. Stakeholders stressed that existing performance and State of Health (SoH) metrics do not consistently represent real-world battery conditions and expressed uncertainty about test-method uploading and data submission requirements. These concerns align with recent energy-systems research calling for standardized SoH methodologies and shared performance frameworks to support digital reporting (Bilfinger et al., 2025). Academic work on digital passports similarly emphasizes the need for context-specific data models and robust data-submission protocols (Walden et al., 2021; Götz et al., 2022).

Cybersecurity and trustworthiness constitute a further set of challenges. While interoperable data ecosystems offer substantial benefits, participants raised concerns about data authenticity, access control, and cyber-resilience. These concerns are well grounded in existing literature, which emphasizes that trust, authentication, and verification mechanisms are essential components of DPP architectures particularly across complex DPP ecosystems (Walden et al., 2021; King et al., 2023).

These challenges resonate with studies examining material traceability and sustainability assessment in fragmented supply chains, where inconsistent data availability, supplier reluctance, and variable digital maturity create significant barriers to lifecycle transparency (Garcia-Torres et al., 2024; Schaëfer et al., 2025) and persistent uncertainty regarding data-sharing obligations (Rizos and Urban, 2024). The absence of standardized data-sharing protocols further exacerbates these barriers, emphasizing the centrality of interoperability for effective DPP implementation (Stenzel and Waichman, 2023; Ströher et al., 2025).

Collectively, these challenges illustrate that digital readiness involves much more than technological investment: it requires enhanced data governance, clearer responsibility frameworks, and stronger coordination across multi-actor value chains.

5.3 International alignment, benefits and pathways for readiness

The horizon-scanning review and wider literature show that international initiatives provide clear reference models for addressing the risks identified in this study. Federated data-space architectures, such as those developed by CIRPASS, Catena-X, Gaia-X, and the International Data Spaces Association, demonstrate how interoperability and data sovereignty can be combined through decentralized identifiers, common ontologies, and distributed trust frameworks. These initiatives underpin pre-standardization work including DIN DKE SPEC 99100 and the harmonization activities of CEN-CENELEC JTC 24, which together form the basis for future European BP/DPP interoperability standards.

For UK organizations, early alignment with these frameworks offers a pragmatic route to reducing uncertainty and avoiding costly retrofits. SMEs may adopt low-entry QR-based approaches such as GS1 Digital Link, while larger firms can integrate passport-related data structures into existing PLM and PIM systems; strategies already demonstrated in European pilots.

Crucially, both the international evidence and academic literature underscore that digital passports offer significant long-term benefits. These include enhanced traceability, more accurate carbon-footprint reporting, improved material recovery, new forms of circular business-model innovation, and greater market transparency (Adisorn et al., 2021; Walden et al., 2021; Götz et al., 2022). Several UK participants echoed these opportunities, observing that high-quality digital information could reduce compliance uncertainty, support better decision-making, and improve sustainability performance across the battery lifecycle.

5.4 Policy and industry implications

The integrated evidence from the survey, round table, interviews, and horizon scan points to several areas requiring coordinated intervention.

Policy measures should include the development of authoritative UK-specific templates, guidance documents, and compliance roadmaps. A national dissemination hub is needed to coordinate training and regulatory interpretation, particularly given the fragmented nature of reporting channels across EU Member States. Engagement in European standardization, especially CEN-CENELEC JTC 24, will support UK alignment with emerging data-exchange specifications and reduce the risk of divergence.

Standards and infrastructure development should prioritize harmonization with evolving EU frameworks, including DIN DKE SPEC 99100, IEC 63278-1 and ISO traceability standards. Workstreams are required to clarify SoH methodologies, performance metrics, and test-method protocols, drawing on recent academic proposals for standardization (Bilfinger et al., 2025).

Industry capability-building will also be essential. Firms must invest in digital skills, governance structures, cybersecurity, and enterprise architecture. SMEs in particular require targeted support through funding, shared platforms, and training. UK-led pilot demonstrators would provide practical opportunities to test interoperability, governance models, and lifecycle event reporting.

These challenges and enablers are summarized in Table 2.

Table 2. Key UK readiness challenges and required enablers.

6 Conclusion

This study provides the first integrated empirical assessment of the UK battery sector's readiness for the digital-compliance requirements introduced by Regulation (EU) 2023/1542. The findings reveal substantial challenges across awareness, data governance, ICT capability, lifecycle coordination, and regulatory clarity, compounded by UK-specific structural issues including limited dissemination channels, fragmented guidance, and the need to navigate multiple EU enforcement authorities.

Yet the evidence also highlights significant opportunities. International data-space initiatives and academic research demonstrate that digital passports can act as powerful enablers of traceability, sustainability reporting, material recovery, and circular-economy innovation. Early alignment with federated architectures such as CIRPASS, Catena-X, and DIN DKE SPEC 99100 will reduce future compliance costs, promote interoperability, and facilitate continued access to EU markets.

Strategic interventions at policy, standards, and industry levels are needed to capitalize on these opportunities. These include developing national implementation guidance, establishing UK focal points for dissemination, supporting SME capability through funding and shared infrastructure, initiating UK-led pilot demonstrators, and coordinating UK participation in emerging EU standardization efforts. Digital compliance should thus be understood not only as a regulatory obligation but as an opportunity to drive system-wide improvements in data quality, supply-chain transparency, and organizational digital maturity.

Future research should examine the operational performance of emerging UK pilot projects, evaluate the impact of evolving standards in real-world settings, and explore cross-sectoral scaling of digital-passport systems. Longitudinal studies will be crucial for understanding how digital regulatory infrastructures contribute to sustainable and circular industrial systems over time.

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Footnotes

Edited by: Simon Lambert, Newcastle University, United Kingdom

Reviewed by: Wei He, Minjiang University, China

Patricia Urban, Centre for European Policy Studies, Belgium