GLOBAL BATTERY PASSPORT
IMPLEMENTATION GUIDELINES FOR
A DECENTRALIZED CROSS-BORDERCOMPLIANT SOLUTION
MOBI BP0001/TG/2023 Version 1.1

MOBI
Supply Chain (SC) Working GroupMOBI BP0001/TG/2023 Version 1.0

INTRODUCTION

MOBI BP0001/TG/2023 Version 1.0

Lead Author:

Rajat Rajbhandari, PhD, MOBI

Reviewers:•

Steven Douglas, DENSO•

Yasuhiko Ogushi, Kaula Lab•

Francesco Guaiana, Stellantis•

Fabio Severino, Traentof many of the world’s largest vehicle manufacturers, startups, governments/transit•

Hisashi Matsumoto, Anritsu•

Yuhei Takai, ITOCHU

agencies, NGOs, financial institutions, e-mobility providers, consultancies, suppliers,•

Pramita Mitra, Ford•

Praveen Abbaraju, Hitachi•

Michael Gorny, Stellantis•

Steve Amancha, State Farm•

Kumara Guru, Blockedge

MOBI is creating standards to identify vehicles, individuals, businesses, and•Mark Anders, Ford•

Ivan Gutierrez, State Farm

MOBI Trusted Trips in order to securely exchange and share data, and pay for•

Hiromasa Aoki, Trade Log•

Shigemitsu Hara, Orico•

Alessandro Arciero, Henshin Group•

Kinoshita Hiroshi, Mazda•

Mitsuharu Arinori, Trade Log•

Felix Huang, DENSO•

Anna Baranskaya, Nissan•

Yawen Huang, DENSO•

Patrick Bartsch, AWS•

Chris Hwee, Honda•

Massimo Belluz, Henshin Group•

Momo Ichihara, Trade Log•

Roger Berg, DENSO•

Tooru Inoue, Orico•

Manjiri Birajdar, Arxum•

Alvin Ishiguro, Trade Log•

Mike Brown, Nissan•

Hitoshi Iwamoto, Honda•

Lucie Chabert, Stellantis•

Nick James, AWS•

Raullen Chai, IoTeX•

Sajit Janardhanan, AWS

The procedures used to develop this document and those intended for its further•

Alex Choo, ASJade Tech•

Mikael Johansson,

maintenance are described in the working group charter. In particular, the different•

Nicola Cianci, Stellantis

approval criteria needed for the different types of MOBI documents should be noted.

•

Kerry Cote, State Farm•

Masaru Kakuchi, OricoApprovals of MOBI Steering Committee and Board of Directors are obtained upon•

Claudia Damari, Henshin Group•

Kazuya Kamata, Trade Log

the final document release. Attention is drawn to the possibility that some of the•

Pierre Delaunay, Stellantis•

Motohisa Kamijo, Nissanelements of this document may be the subject of intellectual property rights. In•

Steven Douglas, DENSO•

Ami Kamikihara, Trade Log

accordance with MOBI IPLR policy, a 60-day review period is provided to the MOBI•

Steve Dunstan, State Farm•

Okamoto Katsuji, Kaula Lab•

Olivier Emsalem, Stellantis•

Naoyuki Kawaguchi, Trade Log•

Miho Etchu, Trade Log•

Hiromi Kawanishi, Mazda•

Xinxin Fan, IoTeX•

Yoji Kawanishi, ITOCHU•

Josh Fodale, Ford•

Ogawa Kazuya,•

Aaron Fong, Honda•

Jean-Marc Fournier, Stellantis•

Masahiro Fujita, Trade Log•

Sanshiro Fukao, ITOCHU•

Toru Kimura, Honda•

Matteo Gandolfi, Henshin Group•Kim Kloeppel, State Farm•

Fabrizio Garetto, Stellantis•

Christian Koebel, Honda

Group. Sincere thanks and appreciation are extended to those who contributed their•

Kamil Gaweda, Arxum•

Yasuhiro Komine, Honda

unique insights to this report.

•

Avinash Ghorpade, DENSO•

Karthik Krishnamurthy, AWS•

Alan Gordon, Ford•

Karthik Krishnan, AWSThis standard was issued by MOBI and its members. MOBI is a nonprofit alliancelogistics providers, and blockchain protocols working to create standards and build
the Web3 digital infrastructure for connected ecosystems and IoT commerce.

mobility services, with the goal of making transportation more efficient, equitable,
decentralized, and sustainable, all while preserving the data privacy of users andproviders alike. MOBI is technology and ledger agnostic.
The work of preparing standards is carried out through MOBI Working Groups. Eachmember of the consortium interested in a subject for which a working group has
been established has the right to be represented and participate in that working
group.

community to disclose any and all IP matters pertaining to this standard. MOBI shallnot be held responsible for identifying any or all such rights. Details of any IP rights
identified during the development of the document will be in the Introduction upon
public release of this standard.
Any trade name used in this document is information given for the convenience ofusers and does not constitute an endorsement.
The working group responsible for this document is the Supply Chain (SC) Working

3© 2023 MOBI. All rights reserved.

Contributors:.

Toyota Industries Corporation

Toyota Industries Corporation•

Ohashi Kenji,
Toyota Industries Corporation© 2023 MOBI. All rights reserved.

4

MOBI BP0001/TG/2023 Version 1.0

Contributors
Continued:•

Yasuyuki Kubota, Mazda•

Sandeep Kulkarni, AWS•

Subrata Kundu, Hitachi•

Larry Pang, IoTeX•

Cedric Labry, Vitesco•

Drew Paroz, Honda•

Frederic Legrand, Stellantis•

Sunil Paul, Spring Free EV•

Phebe Lu, ASJade Tech•Francesco Petrignani, Traent•

Tatsuro Otsu,•

Vijay Madhavan, Blockedge•

Damien Pierre, Stellantis•

Ishii Makoto, Mazda•

Christian Poulain, Stellantis•

Will Maney, USAA•

Lorenzo Prestia, Stellantis•

Domenico Mangiacarpa, Henshin Group•

Jonas Rahm,•

Hisashi Matsumoto, Anritsu•

Eiji Matsumura, Anritsu•

Moin Rahman, State Farm•

Diego Mazzieri, Stellantis•

Mathias Reinartz, Stellantis•

Brad Miller, National•

Sandeep Saini, Vitesco

Automotive Dealers Association•

Futoki Saito, ITOCHU•

Takuya Mimori, Vitesco•

Yoshihide Sakai, ITOCHU•

Lauren Mitchell, State Farm••

Pramita Mitra, Ford•

Toyota Industries Corporation•

Vitthal Thamke, Vitesco•

Spencer White, Ford•

Nakaya Tomofumi, Mazda•

Phil Windley, AWS•Long Tran, AWS•

Hu Xu,•

Nonoyama Tsuyoshi,

Toyota Industries Corporation

Toyota Industries Corporation•

Xin Xu, DENSO•

Takayuki Udagawa, Orico•

Katsutoshi Yamazaki, Honda•

Huub van der Wouden,•

Hideo Yoshida, Nissan

Toyota Industries Corporation•

Yasuhiko Yuasa, Honda•

Takuya Watanabe, Anritsu•

Kitaoka Yusuke,•

Takashi Watanabe, Anritsu•

Tony Welcome, State Farm•

Xiaoliang Zhu, Hitachi•

Ross Wheeler, State Farm•

Thomas Ziebro, Vitesco•

Tram Vo, CEO + Founder•

Chris Ballinger, Advisor + FounderDavide Salerno, Henshin Group•

Rajat Rajbhandari, Head of Standards and Certification•

Shoki Sato, ITOCHU•

Andreas Freund, CTO

Stefano Monti, Stellantis•

Otto Schell, Stellantis•

Matt Shi, Supply Chain Lead			•

Emmanuel Monzies, Stellantis•

Takashi Sendo, Trade Log•

Betul Kahya, Mobility Lead•

Tsune Murai, Orico•

Paras Sethi, ParkMyFleet•

Griffin Haskins, Mobility Finance Lead•

Hiroaki Murase, ITOCHU•

Fabio Severino, Traent•

Parth Bhatt, Technical Product Manager•

Ash Naik, AAIS•

Jigneshkumar Shah, DENSO•

Grace Pulliam, Communications Manager•

Hitoshi Nakajima, Orico•

Vyacheslav Sharipov, AUCNET•

Kierra Maggs, Digital Media Associate•

Taro Nakata, Kaula Lab•

Kenji Shibata,•

Yasuhiro Nakayama, AUCNET•

Matsuo Naoya, Trade Log•

Mark Shih, ASJade Tech•

Alberto Nasi, Stellantis•

Kikuchi Shinichi, Mazda•

Andrea Neri, Stellantis•

Takahara Shinji, Mazda•

Keisuke Nisugi,•

Erik Skyten, State Farm

Toyota Industries Corporation•

Sunil Srinivasa, Vitesco

Rodolfo Occari,•

Raj Srinivasaraghavan, Blockedge

Toyota Industries Corporation•

Sudha Sriram, Ford•

Yasuhiko Ogushi, Kaula Lab•

Suresh Sundaraj, Ford•

Hidenori Ohashi, Aucnet•

Yoshinori Suzue, Nissan•

Shuichi Ohki, Kaula Lab•

Hirotaro Suzuki, AUCNET•

Harunobu Ohmae, ITOCHU•

Tetsuya Takahashi, Hioki•

Tomonori Okada,•Yuhei Takai, ITOCHU

Toyota Industries Corporation•

Kimihito Tanaka,•

Toyota Industries Corporation

Toyota Industries Corporation•

Mitsuyuki Okano, Orico•

Adewale Omoniyi, AWS•

Leonardo Tapanelli, Stellantis•

Shinji Omuro,•

Jan ten Hove,

Toyota Industries Corporation

5

MOBI BP0001/TG/2023 Version 1.0© 2023 MOBI. All rights reserved.

MOBI Team:

Contact:

Toyota Industries Corporation

connect@dlt.mobi

Toyota Industries Corporation

Toyota Industries Corporation© 2023 MOBI. All rights reserved.

6

TABLE OF
CONTENTS

Executive Summary
Glossary of Terms
Introduction to Battery Passport
3.1

Objectives of this Document

3.2

Target Audience

3.3

About the Battery Passport

3.4

Digital Twin of a Battery

3.5

Benefits of a Battery Passport

Stakeholders and Their Roles
4.1

Stakeholder Groups

4.2

Information Contributors and Receivers

4.3

Economic Operator as Defined by the EU

4.4

Stakeholders That Qualify as Economic Operators

4.5

Assumptions of Stakeholder Roles

High-Level Requirements
5.1

Managing and Retaining Battery Pack Identity

5.2

Preservation of Proprietary Data

5.3

Truth in Battery Data

5.4

Traceability and Accountability

5.5

Data Interoperability

5.6

Flexibility and Inclusivity

Decentralized Approach to Battery Passport
6.1

Rationale for Decentralized Approach

6.2

Decentralized Architecture

Reference Implementation
7.1

Self-Sovereign Digital Twin™

7.2

Battery Self-Sovereign Digital Twin™

7.3

Battery Passport: A Verifiable Credential

7.4

Verifiable Credential Chaining

7.5

Lifecycle of the Battery SSDT™

7.6

Use of Integrated Trust Network

7.7

Use of Citopia

7.8

Implementation in a Zero Trust Environment

Implementation Challenges
8.1

Need for Clear Regulatory Specifications

8.2

Unclear Implementation Costs

8.3

Undue Financial Burden on Small Businesses

8.4

Lack of Data Interoperability Framework

8.5

Easy Access to the Passport Information

8.6

Governance of Decentralized Systems

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01

EXECUTIVE SUMMARY

A battery passport is defined as an “electronic record” of a battery, as per Article 77 of the EU Battery
Regulation. Although the battery passport centers around achieving sustainability and regulatory compliance,
battery value chain members can also use the passport as a source of information about material traceability,
managing life cycle events, secondary usage, etc.
The purpose of this document is not to recommend which attributes about a battery should be included in the

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02

GLOSSARY OF TERMS
BIN

		 -

Battery Identification Number

B-SSDTTM		
-Battery Self Sovereign Digital TwinTM

DLT

Decentralized Ledger Technology

		 -battery passport. The purpose of this document is to provide a guideline on how to implement a battery
passport, regardless of the regulations. Although this document mostly refers to the EU Battery Regulation,

DID			 -

Decentralized Identity

EC			 -

European Commission

EO			 -

Economic Operator

EU

		 -

European Union

EV			 -

Electric Vehicle

ITN			 -

Integrated Trust Network

IMDS			 -International Material Data System

SSI			 -

Self Sovereign Identity

SSDTTM			 -Self-Sovereign Digital TwinTM

VC			 -

Verifiable Credential

VIN			 -

Vehicle Identification Number

VP			 -

Verifiable Presentation

W3C			 -

World Wide Web Consortium

future regulations pertaining to the battery passport might also appear outside of the EU, particularly in theUS.
We believe a decentralized approach, compared to a centralized approach, will better satisfy the EU
Regulation’s requirements of preserving proprietary information within organizational firewalls, ensuring easeof traceability and accountability, promoting inclusivity of smaller stakeholders and value chain members,
and safeguarding against collusion between a centralized entity and battery information contributors. In
this document, we describe the high-level requirements for a battery passport, recommended decentralized
approach, implementation architecture, and reference architecture including the use of Web3 components.
Finally, this document acknowledges the challenges associated with decentralized implementation of thebattery passport and presents ways to overcome those challenges.

9© 2023 MOBI. All rights reserved.

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INTRODUCTION TO BATTERY PASSPORT

to be tagged, identified and linked to data relevant to their circularity andsustainability:“Digital product passports will help businesses along the value chain, frommanufacturers, importers, distributors to dealers, repairers, remanufacturers,

3.1 Objectives of this Document

and recyclers, to access information that is valuable in their work to improve

Battery Passport has emerged as a key

Battery passport has emerged as a key concept in creating a sustainable battery

environmental performance, prolong product lifetime, boost efficiency and theconcept in creating a sustainable battery

supply chain, especially for rechargeable batteries. However, its implementation

use of secondary raw materials, thus lowering the need for primary natural

supply chain, especially for rechargeable

is in the early stages of design and development. Within the global battery

resources, saving costs and reducing strategic dependencies.”and electric vehicle (EV) batteries.

value chain, there are thousands of stakeholders (public and private) withunique databases, processes, and regulations for handling business data andcustomer personally identifiable information (PII). As a result, the cost of trust
is prohibitively high. Solving this challenge requires industry-wide efforts to

The battery passport shall “electronically

Following the same principle, the EC defines a battery passport as an “electronic

register, process and share product-

record for each battery placed on the market….it is a “a structured collection ofrelated information amongst supply chain
businesses, authorities, and consumers.

create interoperable and standards-based battery passport systems.

supply chain businesses, authorities, and consumers.”

stakeholders can have greater autonomy in sharing their battery-related data.
Our objective of this document is to provide a comprehensive overview of the

a comprehensive overview of the benefits

benefits of implementing the battery passport in a decentralized environment,of implementing the battery passport in adecentralized environment.

The Global Battery Alliance, a partnership of over 130 institutions with a mission
to ensure sustainable battery production, defines a battery passport as a “digital
representation of a battery that conveys information about all applicable ESG
and lifecycle requirements based on a comprehensive definition of a sustainable

design guidelines for industry stakeholders and regulators, and a description ofbattery.” 2

the necessary elements for a decentralized battery passport system.

3.4 Digital Twin of a Battery

IMPORTANT: The guidelines in this document should not be construed as
mandatory requirements in compliance with any existing or future batteryrelated regulations. The use of words such as “must” and “should” denotes
strong recommendations and not mandatory requirements.

The battery passport should serve as a

Analogous to a digital twin of a battery pack, a battery passport should becomprehensive digital representation of theperceived by the industry as more than just a compliance tool. It should serve

battery, offering not only information forthe public and regulatory bodies but also

3.2 Target Audience
The intended audience of this guideline includes any entity that will be required
either by law or by contractual obligation to contribute battery information to abattery passport system.

access rights conveyed through a unique identifier.” The battery passport shall“electronically register, process and share product-related information amongst

We at MOBI believe that such a system must be decentralized such that all

Our objective of this document is to provide

product-related data with a predefined scope and agreed data ownership andvaluable insights for stakeholders.

as a comprehensive digital representation of the battery, offering not only
information for the public and regulatory bodies but also valuable insights forstakeholders. The battery passport should be thoughtfully designed to enhanceinternal practices such as sourcing, manufacturing, distribution, and evensecond-life management, including the recycling of batteries. By considering itin this broader context, the industry can harness the passport’s potential to drive
improvements across the entire battery life cycle.

3.3 About the Battery Passport

As a digital twin of a battery, the battery passport should include both static andIn 2020, the European Commission’s

In 2020, the European Commission’s (EC) Circular Economy Action Plan

dynamic attributes about a battery. For the purposes of this document, we define(EC) Circular Economy Action Planemphasized the importance of adopting a comprehensive approach to productstatic attributes as those that are first provided by the manufacturers and dolife cycles. This approach entails considering every stage from production to

not change over time unless the batteries are repurposed. Static attributes may

end-of-life disposal, encompassing processes such as materials sourcing,include battery type, weight, number of modules, original battery composition,

production, and supply chain management, in line with sustainability objectives.

rated capacity, and original temperature range. Dynamic attributes refer toTo this end, the Circular Economy Action Plan proposes the implementation of

attributes whose values change over time, such as a battery’s state of health.

emphasized the importance of adopting
a comprehensive approach to product life
cyclesdigital product passports , which is defined as a system that enables products
1

1

European Parliament legislative resolution of 14 June 2023 on the proposal for a regulation of the European

Parliament and of the Council concerning batteries and waste batteries, repealing Directive 2006/66/EC and amending

2

Battery Passport, The Global Battery Alliance, November 2020, https://www.globalbattery.org/media/publications/wef-gba-battery-passport-overview-2021.pdf

Regulation (EU) 2019/1020 (COM(2020)0798 – C9-0400/2020 – 2020/0353(COD)), European Union, Brussels,
14.06.2023. https://www.europarl.europa.eu/doceo/document/TA-9-2023-0237_EN.pdf

3

Katharina Berger, Josef-Peter Schöggl, Rupert J. Baumgartner, Digital battery passports to enable circular andsustainable value chains: Conceptualization and use cases, Journal of Cleaner Production, Volume 353, 2022, 131492,
ISSN 0959-6526, https://doi.org/10.1016/j.jclepro.2022.131492.

11© 2023 MOBI. All rights reserved.

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The purpose of this document is not to

The purpose of this document is not to recommend specific attributes in therecommend specific attributes in thebattery passport. However, regulations in individual nation-states and/or regions

battery passport.

may outline specific attributes that must be conveyed in the battery passport

04

STAKEHOLDERS AND THEIR ROLES

and made available to the general public and regulators. Stakeholders seeking
resources on this matter may reference the attributes outlined by Battery Pass,

The battery value chain is characterized

The battery value chain is characterized by its complexity, involving numerous

the Global Battery Alliance, and Berger et. al.

by its complexity, involving numerous

stakeholders spanning both upstream and downstream operations. These3

stakeholders spanning both upstream anddownstream operation.

stakeholders engage in intricate business relationships that entail multifaceted

3.5 Benefits of a Battery Passport

contracts, confidentiality agreements, partnerships, and more.

By providing clear information andBattery passports, much like product passports, serve as powerful facilitators

The design and implementation of a battery passport system must fully

documentation throughout the battery’s

for sustainable management of battery life cycles and the promotion of

acknowledge the existing realities and dynamics within the stakeholder

value-retaining operations. They act as instrumental tools in enabling morelandscape. The formal relationships between stakeholders play a critical role insustainable and circular value chains.4 By providing clear information anddetermining their ability to contribute data about a battery pack. It is crucial to

documentation throughout the battery’s journey, these passports contribute torecognize that certain entities may be restricted by confidentiality agreements

enhancing transparency, traceability, and accountability. For example, it enables

with their partner companies, preventing them from sharing specific information.

journey, these passports contribute toenhancing transparency, traceability, andaccountability.

traceability of critical minerals, ethical sourcing, and carbon footprint as wellas enables second-life operators to take informed decisions and recyclers to

The battery passport system consists of

The battery passport system consists of entities that provide information about

improve recycling efficiencies.

entities that provide information abouta battery and entities that utilize this information for their business operations.

a battery and entities that utilize thisinformation for their business operations.

The following sections describe•

a list of stakeholder groups in the battery value chain,•different kinds of information they provide about a battery, and•information entities consume about a battery.

4.1 Stakeholder Groups
It should be noted that some companies

Below is a comprehensive list of stakeholder groups involved in contributing to or

may fall into multiple groups due to theconsuming battery information, or both. It should be noted that some companies may fall

nature of their operations and hence may

into multiple groups due to the nature of their operations and hence may be responsible

be responsible for providing multiple pieces
of information about a battery.

for providing multiple pieces of information about a battery.

Raw Material Sourcing Companies
Mine and extract raw materials such as lithium, cobalt, manganese, nickel, and graphite.
This group also includes refiners and processors that purify the raw materials to produce
refined minerals suitable for use in technology.5

Cell Manufacturers
Cell manufacturers produce battery cells

Produce battery cells and consists of electrode manufacturing, cell assembly, and celland consists of electrode manufacturing,finishing. They provide information about cell performance to the pack manufacturers

cell assembly, and cell finishing.

that aggregate information at the pack level. Even though the EU Regulation does not
explicitly state that cell manufacturers must provide a battery’s chemical and mechanicalproperties, in most contexts, the cell manufacturers are responsible for providing such

4

M. Heinrich, W. Lang, Materials Passports - Best Practice (2019)https://www.bamb2020.eu/wp-content/uploads/2019/02/BAMB_MaterialsPassports_BestPractice.pdf, Accessed

5

Carreon, A., EV Batteries 101: Supply Chains, Rocky Mountain Institute, March 08, 2023, https://rmi.org/ev-batteries-

101-supply-chains/

March 30, 2023.

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information to the pack manufacturers, who then associate the information with individual
battery packs.

Battery Swapping/Reuse Companies
Allow consumers to swap an old battery

Allow consumers to swap an old battery with a new one. This use case has not gainedwith a new one.

much traction in large-form batteries but has gained popularity for smaller batteries used

Battery Pack Manufacturers

in two-wheelers.

Assemble and produce battery packs. They may also be involved in cathode and cell

Battery Testing Companies

manufacture. Each pack consists of cells that are assembled into modules, accompaniedby the battery management system.

Provide battery testing and certification services, ensuring energy storage technologies
meet performance, reliability, and safety criteria.

Manufacturers/Suppliers that Install Batteries in Final ProductsElectric vehicle manufacturers or OEMS

Responsible for manufacturing end-user products such as electric vehicles, light means ofare responsible for manufacturing electrictransport, grid storage. In certain cases, they may also assemble their own battery packs

vehicles.

and install them into the product during the assembly process. This involves assigning

Transport Companies
Serve manufacturers and distributors to physically transport and store minerals,
manufactured components, and battery packs.

a battery pack with a unique identity, typically a serial number provided by the battery
manufacturer, to the vehicle or other products.

Battery Passport System Providers
As battery passports become common, we envision companies will develop systems

Dealers and Repair Shops

that gather and present information about batteries to the general public, regulators, andReceive requests from vehicle and fleet owners to inspect and repair batteries. While

auditors.

they may identify issues in the battery pack, they are typically not qualified to perform
repairs at the module level. In such cases, they will notify the vehicle manufacturers, who

Online and Offline Marketplaces

may request the dealers to ship the faulty battery/module to the battery manufacturer for
further assessment and repair.

Owners/Fleets/Rental Companies
Monitor the performance of batteries during regular usage. As end-consumers of batteries
and battery passports, they rely on the information provided to make informed decisions

Before placing used batteries on the

As more and more used batteries enter the market, we anticipate the rise of online andmarket, marketplace operators must ensure

offline marketplaces specifically designed for the selling and buying of used batteries.

their performance quality.

Before placing these batteries on the market, marketplace operators must ensure theperformance quality of the used batteries.

regarding the purchase, sale, or usage of their vehicles. It is essential for them to have

Government Regulators and Policymakers

access to the state of batteries, both new and used, in order to make well-informed buying

Propose and enforce local and national level regulations concerning battery recycling

and selling decisions.

to meet sustainability goals. For these stakeholders, traceability of the battery’s criticalminerals is important to align with the goals and long-term economic policies on reducing

Collection and Sorting Companies

reliance on mineral import.

Collection and sorting companies gather

Gather used batteries from designated locations and safely store them in warehouses.

used batteries from designated locations

While collection and sorting companies may be separate entities in certain cases, they

Insurers of Owners

and safely store them in warehouses.

must undergo proper training to ensure safe handling and storage practices. They supply

Insure vehicles /grid storage/industrial batteries and even may separately underwrite theused batteries to other companies engaged in recycling, repurposing, or reusing batteries.

battery packs. One particularly critical battery attribute is the state of health, which canbe used to determine it’s residual value.

Battery Recycling Companies
Recycle material from used batteries through various mechanisms such as pyrometallurgical

Certifying and Auditing Agencies

and hydrometallurgical processes, and extract critical minerals.

Perform audits and certify sustainability-related business activities. They may be called
upon to certify sustainability claims by mineral sourcing companies, battery manufacturers,

Battery Repurposing Companies

etc.

Repurpose used battery packs and/or modules for secondary purposes such as grid
storage and utility backups.

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4.2 Information Contributors and Receivers
At a high level, stakeholders play a direct or

At a high level, stakeholders play a direct or indirect role in contributing

indirect role in contributing necessary datanecessary data to be included in the battery passport as per regulations or

to be included in the battery passport as
per regulations or general industry practice.

general industry practice. Direct contribution refers to stakeholders originating
the information and sharing it either with downstream partners or with thebattery passport system itself. For example, electric vehicle manufacturers will

Stakeholder Group

Contribute Battery
Information

Use Battery
Information
State of battery usage — how many

Vehicle/Grid Storage
Manufacturers

Audited/certified battery pack datafrom upstream stakeholders.

provide battery identity, physical attributes, chemical composition, and otherare in use, how many are recycled/
repurposed, etc. Marketing to show
ethical and responsible sourcing
and production.

relevant details to the battery passport.
Indirect contribution refers to stakeholders providing information to theirrespective partners, which is subsequently packaged with other relevant data.

Dealers and Repair Shops

Documentation of maintenanceperformed on battery packs.

Prior maintenance history,changes in cell configuration after

repurposing, and software updates.

For instance, battery manufacturers may provide information about battery
packs, who then assume the responsibility of providing the information to thebattery passport system. In this scenario, the battery manufacturer may not bedirectly accountable for ensuring the accuracy and completeness of the final

Vehicle Owners/Fleets

The current state of physical attributes

Battery performance history to make

Carbon footprint data and physicalUse labels and battery state for safe

Carbon footprint and material

Use labels and battery state for safe

Carbon footprint data, physical/

Use labels and battery state for safe

and second-life use.

storage.

(e.g., state of health, charge cycles)

informed buying/selling decisions.

information included in the battery passport attributes.
It’s important to note that future

Battery passport information users consume data available in the passport for

regulations may specify and impose upon

their own commercial benefit and/or to provide services to the customers. Table

the stakeholders’ specific data they must
contribute to the battery passport.

Collection and Sorting
Companies

1 below shows a comprehensive list of stakeholder groups that contribute toBattery Recycling Companies

must contribute to the battery passport.

General Public andConsumers

Contribute Battery
Information
Current performance state of batteries.

Use Battery
Information

Companies

practices, adherence to ethicalstandards, and compliance with

Chemical composition, recycled
mineral content.

Battery pack identity, labels,Battery Manufacturers

physical attributes, and newbattery performance data, linked to
information provided by upstream
suppliers.

17© 2023 MOBI. All rights reserved.

Battery Swapping/Reuse
Companies

material changes to the battery pack,handling and storage.

handling, cell reconfiguration, andCarbon footprint data and physical/

material change to the battery pack.

Use labels and battery state for safe
handling and storage.

N/A
Battery Testing Companies

environmental regulations.

Cell Manufacturers

Companies

recycling.

sustainability information of battery
production

demonstrating responsible sourcing

Battery Repurposing

Make purchasing decisions based on

Documentation or certifications
Raw Material Sourcing

handling, sorting, and storage.

and/or consume battery passport information. It’s important to note that future
regulations may specify and impose upon the stakeholders’ specific data they

Stakeholder Group

traceability of used packs/modules.

Certifications regarding the usedbattery pack’s current state.

Use labels and battery state for safe
handling and testing.

Query data about battery

performance from the system anduse it to improve the cell design.

Transport Companies

Carbon footprint data during transportand storage.

N/A

Query data about battery

performance from the battery

passport and use it to improve thepack design.

Battery Passport System
ProvidersCreation of the battery passportsystem.

N/A© 2023 MOBI. All rights reserved.

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Contribute Battery
Information

Stakeholder Group

Online and Offline
Marketplaces

Government Regulators andPolicymakers

Insurers of Owners andBatteries

Attributes of used battery performanceand physical characteristics.

Create and update policies as well as

define specific attributes that must be
included in the battery passport.

N/A

4.3 Economic Operator as Defined by the EU

Use Battery
Information

According to the EU Battery Regulation, the economic operator (EO) serves avital role in the development of the battery passport6 since it is responsible to:

Verify attributes of used batteries

before making them available forresale.

1
Verify sustainability claims by“ensure that each battery passport consists of a combinationof data common to its battery model and data specific to its
particular battery and usage of that battery” (Article 77(4));

battery and vehicle manufacturers.

2

Use battery state information

to create and modify insurance“ensure that the data included in the battery passport isaccurate, complete and up-to-date” (Article 77(4));

premiums.

Article 3,(22) of the regulation defines an EO as “the manufacturer, the authorized
Certifying and Auditing
Agencies

Provide third-party certifications ofsustainability claims by manufacturers.

representative, the importer, the distributor or the fulfillment service provider,

N/Aor any other natural or legal person who is subject to obligations concerning
manufacturing batteries, preparing batteries for reuse, preparing batteries for
repurpose, repurposing, or remanufacturing of batteries, making them available
or placing them on the market, including on-line placing, or putting them into
service in accordance with this Regulation.”

4.4 Stakeholders That Qualify as Economic
Operators
Based on this definition, several stakeholder groups may fall under the categoryof an EO. Below are a few key examples of situations wherein entities (e.g., EV
manufacturers, grid storage providers etc.) may be considered an EO as per the
regulation:
Manufacturers putting the battery into its own service:
An EU-based automotive OEM

Because the automotive companies manufacture electric vehicles (and other providers of

manufactures a ready-for-use EV battery

grid storage, battery swapping companies) that include batteries in products and are theand puts it into service for testing purposes.

ones that put the batteries into service, they may be considered an economic operator.

Installation of a battery by a service provider:
A battery cell manufacturer delivers energy storage modules to an energy company, which
are connected and installed by a third party. In this case, the EU Battery Regulation does
not clearly define at which point the battery is considered “ready for use” and whether
the responsible economic operator is the cell manufacturer or the service provider who
installs the battery.

6

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL, Concerning batteries and waste batteries,

repealing Directive 2006/66/EC and amending Regulation (EU) No 2019/1020,
https://data.consilium.europa.eu/doc/document/ST-5469-2023-INIT/en/pdf

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From outside the EU: A “ready for use”

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Battery placed on the market offline:

Non-EOs will provide data to their partner

This covers batteries sold in physical stores. For example,

certify the data before inputting it into thebattery is imported from outside the EU to
be used in an EV/energy storage systemin the EU. In this case, the importer is the
economic operator.

»

companies and EOs, which may audit/
battery passport.

From inside the EU: an EU-based automotive manufacturer imports battery cells from

Non-EOs will provide data to their partner companies and EOs, which
may audit/certify the data before inputting it into the battery passport.

»

The smallest unit of reporting object in the battery passport is abattery pack and not a module or a cell since packs are the ones put

inside the EU and assembles these into a “ready for use” battery within the EU, installs it

into service by the EOs.

in a vehicle, and sells it to a customer. In this example, the automotive manufacturer is the
manufacturer and therefore the economic operator.

»

Based on the EU’s definition, a battery’s passport “becomes” live once

From outside the EU: A “ready for use” battery is imported from outside the EU to be used

it is put into service. However, the data in the passport can be shared/

in a vehicle/energy storage system in the EU. In this case, the importer isused by battery supply chain entities even while the battery is in thethe economic operator.

production process.

Battery placed on the market online:

In practice, individual stakeholders gather

This definition covers batteries being sold on online platforms or directly to consumers,

information to their downstream partners

such as energy storage batteries.
With the seller based inside the EU: For example, if an EV with a “ready for use” battery issold online through a direct-to-consumer business model, the automotive manufacturer

carbon footprint emissions and provide theor an EO such as an OEM.

»EOs will have the final responsibility of submitting certain aggregateddata, such as total carbon emissions, for a new battery pack. The
total emissions are an aggregate of carbon footprints collected during
the entire supply chain process. In practice, individual stakeholders
gather carbon footprint emissions and provide the information to theirdownstream partners or an EO.

may be considered an economic operator.
With the seller based outside the EU: If an energy storage battery is directly marketed
to EU consumers by a non-EU online seller (e.g., online platform), the online seller may beconsidered the economic operator.

4.5 Assumptions of Stakeholder Roles
In order to define a guide for the

In order to define a guide for the implementation of the battery passport

implementation of the battery passportsystem, we assume the following roles and responsibilities of the value

system, we assume the following roles
and responsibilities of the value chain

chain stakeholders in contributing and sharing battery data. Please note thatstakeholders in contributing and sharing

while we are using the example of an economic operator as described in thebattery data.

EU regulation, future regulations may specify other stakeholder groups tocontribute data about batteries.
»

EOs are obligated, per regulation, to directly contribute data to thebattery passport system.

»

Non-EOs such as material distributors and cell manufacturers will not
directly input data in the battery passport system since 1) they are
not required to do so, 2) contractual obligations and confidentiality
agreements with EOs may prevent them from inputting data without
the partner company’s consent, and 3) upstream stakeholders suchas mining companies will have difficulty associating their output to aparticular battery put to service by an EO.

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New battery (first life): Vehicle and equipment manufacturer

HIGH-LEVEL REQUIREMENTS

Although MOBI advocates for adecentralized approach to battery passport
implementation, the following highlevel requirements should be consideredregardless of implementation architecture.

creates a BID and includes BIN, serial number, and other newbattery-related attributes.

This chapter describes the high-level requirements for a battery passport. These

Battery Identity (BID) will remain the same

Repair and reuse (second-life but for the same purpose): BID

requirements are not derived from any existing or soon-to-be-enacted battery

but the parameters in the battery passport

will remain the same but the parameters in the battery passport

passport or battery traceability-related regulations. They were expressed by
the MOBI members in the Supply Chain Working Group. The requirements areare updated by the entity that puts thebattery back into service.

are updated by the entity that puts the battery back into service.
For example, the mineral content or the number of cells in the packmay have changed. The repaired/reused battery may go back to

forward-looking, regulation-agnostic, and applicable to all battery types.

the original equipment or a different one produced by the different
manufacturers.

Although MOBI advocates for a decentralized approach to battery passportsystem implementation, the following high-level requirements should beconsidered regardless of implementation architecture. Note: MOBI may revise

The repurposing company may have toRepurpose (second-life, different purpose): If the battery has

the requirements in future versions of this document as the battery industries

coordinate with the dismantlers to keep

not been dismantled, the original assigned BID may be updated

evolve.

track of which pack was dismantled andregister the fact that the original BID has
been deprecated.

with the information that the battery is now used for a different
purpose. The BID may be deprecated if the battery was dismantled

5.1 Managing and Retaining Battery Pack Identityand put back into service by a company that is different from the

The development of a globally unique

The development of a globally unique identity of battery packs is foundational

identity of battery packs is foundational

for enabling supply chain traceability. To address this need, MOBI developedwith the dismantlers to keep track of which pack was dismantled

for enabling supply chain traceability.
To address this need, MOBI developed

original one. The repurposing company may have to coordinate
and register the fact that the original BID has been deprecated.

an indelible identifier called Battery Identification Number (BIN) in 2022.7

an indelible identifier called Battery

However, it is important to note that both the BIN and manufacturer-provided

Identification Number (BIN) in 2022.

serial numbers only serve as static identities. A clear guideline is necessary

Recycle (end-of-life): BID is deprecated by the recycling company
and registers such events in the battery passport.

to ensure industry-wide consistency in deprecating static battery identities
when packs are recycled, repurposed, or reused. Overlooking correct identity
maintenance may result in unreliable battery passport information, especiallywhen a battery is repurposed for a different utility or an old static identity is

5.2 Preservation of Proprietary Data

falsified and attached to a repaired pack.

The battery supply chain includes many stakeholders. MOBI members havevoiced concerns that sharing information (as simple as identifying company

Hence, we propose that the static identifiers such as BIN and manufacturer

names) regarding downstream and upstream suppliers and stakeholders canserial numbers be encapsulated inside a digital Battery Identity (BID). In

be considered proprietary and disclosing such information in a public setting

addition to static identifiers, BID also encapsulates other physical, chemical, andmay not be desirable.

traceability attributes.
We recommend the following scenarios in which BIDs are managed by the
stakeholders in the battery passport.

The battery passport system should

The battery passport system should possess the necessary flexibility topossess the necessary flexibility to

distinguish between the information intended for sharing with regulators/

distinguish between the information
intended for sharing with regulators/

auditors and that which is meant for the public. It should enable the secure andauditors and that which is meant for thecontrolled sharing of data between, for example, a vehicle manufacturer andpublic.

regulators without exposing it to other manufacturers. In this context, it may
be preferable for the battery passport system to serve as the final data storage
point rather than relying on a third-party entity seeking to aggregate battery
data from multiple manufacturers. However, the decision to share data withsuch third-party entities remains at the discretion of the manufacturers.

7

First Open Battery Identity Standard Enables Web3 Supply Chain Efficiency, MOBI, July 19, 2022,

https://dlt.mobi/bin-release23© 2023 MOBI. All rights reserved.

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5.3 Truth in Battery Data

5.5 Data Interoperability

Individual data points in the battery passport should be backed up by a digital

For this guideline, interoperability is limited

Interoperability may mean different things for different organizations. For thissignature of the data submitter (e.g., an EO.) There is a distant possibility thatto the ability of one system to be able toguideline, interoperability is limited to the ability of one system to be able tothe battery passport may be integrated with an EO’s systems. This will reduce
the risk of erroneous data being submitted to the battery passport. Until then,recognize, re-use, and process battery
passport data presented by anothersystem.

recognize, re-use, and process battery passport data presented by anothersystem. According to the UN Statistics Wiki,9 “Data is said to be interoperable

each data point submitted by an EO should be treated as a claim that should

when it can be easily reused and processed in different applications, allowing

have a digital signature anchored onto a trusted ledger. Doing so will give thedifferent information systems to work together.” In order to achieve such limited

public and regulators visibility pertaining to the originator of the battery data. It

scoped requirements, the battery passport system should:

also allows the EOs and data contributors to be held accountable.

»

automotive supply chain uses standards such as the globally-accepted

5.4 Traceability and Accountability
Ensuring traceability is critical to enhancing

Ensuring traceability is critical to enhancing the transparency of the battery value

the transparency of the battery value chain.

chain.8 The battery passport provides two types of traceability: (1) traceability

Be compatible with prevalent material reporting standards. The
International Material Data System (IMDS) to disclose materials usedin automotive parts.10 The stakeholders may use IMDS-compatible
applications to report out materials in battery packs.

of information about stakeholders that submit battery data, and (2) traceability»of changes in the battery’s attributes/purpose/state from raw material sourcing

Be readable and resolvable by multiple systems. For example, theto end-of-life.

use of non-proprietary JSON format to encode the battery attributes.

The first type of traceability gives battery passport users visibility into which

system can read such files.

Due to the non-proprietary nature of JSON format, any modern digital

entities have provided relevant battery data. The second type of traceability»

gives stakeholders critical insights into a battery’s history from first-use, second-

Be able to share battery-related data across the value chain without
the need for translators and adopters between the systems.

use, and end-of-life. For example, stakeholders involved in the battery’s end-oflife management can reference the battery passport to identify the state of a

5.6 Flexibility and Inclusivity

given battery, which is helpful for storing/dismantling used batteries.
Flexibility and inclusivity pertain to theFlexibility and inclusivity pertain to the battery passport’s ability to easily

battery passport’s ability to easily allow

allow changes to the battery’s attributes, especially during second-life, and bechanges to the battery’s attributes,
especially during second-life, and be able
to encode those changes in the passport.

able to encode those changes in the passport. Second-life use cases may beundertaken by small and medium size companies. That means they should not
be subject to significant costs to contribute data to the battery passport. “Thecosts and technical hurdles to participate in the battery passport must not beso high that they exclude small economic actors.”11 Inclusivity means that the
stakeholders are not bound by technologies or vendors and enables them tobuild their solutions or use inexpensive solutions to contribute information to
the battery passport system.

8

Katharina Berger, Josef-Peter Schöggl, Rupert J. Baumgartner, Digital battery passports to enable circular and

10

International Material Data System, https://www.mdsystem.com/imdsnt/startpage/index.jsp

11Guth-Orlowski, S., The digital product passport and its technical implementation,

sustainable value chains: Conceptualization and use cases, Journal of Cleaner Production, Volume 353, 2022, 131492,
ISSN 0959-6526, https://doi.org/10.1016/j.jclepro.2022.131492.

https://medium.com/@susi.guth/the-digital-product-passport-and-its-technical-implementation-efdd09a4ed75,
925© 2023 MOBI. All rights reserved.

Data Interoperability Guide, https://unstats.un.org/wiki/display/InteropGuide/Introduction, October 21, 2018.

October 18, 2021.

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DECENTRALIZED APPROACH
TO BATTERY PASSPORT

We recommend a decentralized battery passport approach for the following
reasons:»

Decentralized storage means stakeholders
can keep their proprietary data with them

Easily enables authorized stakeholders to plug into the system, thereby
lowering the entry barrier. However, we recognize the criticality ofto prevent data leakage.

standardization and interoperability.

6.1 Rationale for Decentralized Approach»

Decentralized storage means stakeholders can keep their proprietary

MOBI’s definition of a decentralized approach to the battery passport systemdata with them to prevent data leakage. Stakeholders maintainconsists of the following:

control over their private data, including which partners receive which
updates.

The decentralized approach emphasizes

The approach emphasizes that the battery passport system is not a centralizedthat the battery passport system is notplatform with all layers of implementation managed by a single entity

a centralized platform with all layers of
implementation managed by a single entity(government, private, or otherwise).

»(government, private, or otherwise). Instead, the system is divided into layers

It forces the industry to develop and use open standards for global
interoperability.

(as illustrated in Figure 1), which are managed by multiple entities.
»
Instead, the battery passport system is a network of enterprise systems of

There is no vendor lock-in and no single point of failure with one
company “brokering” data between the stakeholders.

stakeholders in the battery supply chain. We believe this approach is in linewith the framing of the Proposal for Ecodesign for Sustainable Products

6.2 Decentralized Architecture

Regulation (ESPR)12, outlining that product passports “should be based on adecentralized data system, set up and maintained by economic operators” (point
32, introductory text) and that “data included in the product passport shall be
stored by the economic operator”(Article 78(c)).

A fully decentralized system is

We believe that a fully decentralized system is architecturally, politically, andarchitecturally, politically, and logically

logically difficult to implement.13 Also, there are no standardized definitions ofdifficult to implement.

what constitutes a decentralized system. MOBI defines a decentralized battery
passport system as the following:»Architecturally: Data is created and stored in the stakeholder’sstorage system without a need for a single data broker controlled by asingle entity. This also reduces the risk of a single point of failure andallows the stakeholders to maintain the security and propriety of data.

»

Politically: No one company controls the computers/nodes comprising
the battery passport system. However, stakeholders digitally signactions and issue digital certificates for these actions.

»

Logically: There will be monolithic schemas enforced by standards
and common rules defined by the system’s participants.

This high-level architecture is agnostic to

Writing a comprehensive battery passport architecture is out of the scope of thisany country or region’s specific regulations,document. Comprehensive means describing every possible service package,

meaning it can be used as a guide by any
country or region to meet their specificneeds for battery passports.

requirements for entities, physical entities, roles and responsibilities, functions,communication standards, etc. This high-level architecture is agnostic to any
country or region’s specific regulations, meaning it can be used as a guide by
any country or region to meet their specific needs for battery passports.

Figure 1. A decentralized approach to the battery passport system implementation*All five layers of the arcitecture will not be implemented by a single identity

12

13

27

© 2023 MOBI. All rights reserved.

“Proposal for Ecodesign for Sustainable Products Regulation.” n.d. Environment.ec.europa.eu. https://environment.

ec.europa.eu/publications/proposal-ecodesign-sustainable-products-regulation_en.
https://medium.com/@VitalikButerin/the-meaning-of-decentralization-a0c92b76a274© 2023 MOBI. All rights reserved.

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Architecture Views
We recommend defining the battery

We recommend defining the battery passport system architecture using four

passport system architecture using four

views14 15 , which are described as follows:

views: Enterprise View, Functional View,»

What relationships need to exist between the stakeholders andoperators to facilitate services between and within jurisdictions?

»

What relationships need to exist between the providers of services
and the consumers of battery passport services?

Physical View and Communications View.

Enterprise View:

Functional View

Describes the relationships between stakeholders and the roles

1

those organizations play within the battery passport system.
It includes enterprise objects or roles they play in the battery
passport system.

The Functional View defines Processes tocontrol and manage system behavior, suchas monitoring, and other active control

The Functional View addresses the analysis of abstract functional elements andtheir logical interactions. A Process performs actions to achieve an application

elements that are part of describing theobjective or to support actions of another Process. This may involve data

functional behavior of the system.

collection, data transformation, data generation, or processing in performing
those actions. The Functional View defines Processes to control and manage
system behavior, such as monitoring, and other active control elements that are

Functional View:

part of describing the functional behavior of the system. The functional view can

Describes abstract functional elements (processes) and2

help these stakeholders answer questions such as:

their logical interactions (data flows) that satisfy the system
requirements. Functions interact with each other to provide»

What kinds of data are required to implement a given service?

»

What functionality is required to implement a given service?

services.

Physical View

Physical View:
Describes physical objects (systems and devices) and their

3functional objects as well as the high-level interfaces between
those physical objects. Physical objects include batteries, legacy
systems, distributed computers/storage, etc.

Communications View:
Describes the layered sets of communications protocols that are4

required to support communications among the physical objects
that participate in the battery passport system.

Physical Objects include four classes —Physical Objects are defined to represent the major physical components ofpersons, entities, devices, and subsystems

the battery passport. Physical Objects include four classes — persons, entities,— that together provide a set of capabilities
that are more than would be implemented
at any one place or time.

devices, and subsystems — that together provide a set of capabilities that are
more than would be implemented at any one place or time. The Physical View
enables the engineer to answer questions such as:»

What physical objects are involved in the delivery of a given service?

»

What interfaces are required between different physical objects?

»

What functionality is allocated to physical objects?

»

What are the security considerations for information exchanged
between physical objects?

Enterprise View
Enterprises have needs, roles, andEnterprises have needs, roles, and interfaces (e.g., contracts) to interact withinterfaces (e.g., contracts) to interact withother stakeholders. The Enterprise View enables the stakeholder to answer

other stakeholders.

questions such as:»

Who is responsible for providing battery passport-related services?

»

Who is responsible for the installation, operation, and maintenance ofservices, applications, and devices? (In this context, a device can be abattery pack.)»

What are the security considerations for physical objects?

Communication View
The Communications View provides a framework for identifying the protocols
necessary to implement an information flow between Physical Objects (asdefined in the Physical View). These protocols need to meet interoperability,
performance, functional, security, and environmental requirements while
addressing operational challenges and relevant policies (such as an assuranceof pseudonymity for mandatory data provision).

14

National ITS Reference Architecture, US Department of Transportation, https://www.arc-it.net/html/viewpoints/

viewpoints.html
1529© 2023 MOBI. All rights reserved.

ISO/IEC/IEEE 42010 - Systems and software engineering — Architecture description© 2023 MOBI. All rights reserved.

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The Communications View provides aframework for identifying the protocols
necessary to implement an information

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The Communications View structure enables stakeholders to answer

The service package allows credentials

grants trust credentials to qualified objects in the battery passport system soquestions such as:

to be requested and revoked and securesthat those objects may be considered trusted by other trusted objects. The

flow between Physical Objects.

»

What is the set of communications protocols that provides a complete

the exchange of trust credentials between
parties so that no other party can intercept
and use those credentials illegitimately.

interface solution to meet the needs of the stakeholders?

service package allows credentials to be requested and revoked and securesthe exchange of trust credentials between parties so that no other party canintercept and use those credentials illegitimately. The service package provides
security to the transmissions between objects, ensuring the authenticity and»What protocols address critical system-wide security issues, such as

integrity of the transmissions.

the provision for the protection of data confidentiality, protection of
message integrity, and defense against in-transit manipulation?
»

SP4: Object certification and enrollment
Closely tied to Object Registration and discovery as its precursor, this service

What organizations are responsible for the maintenance of data,

package permits objects to be authorized and enrolled as part of the battery

communications, security, and management standards/specifications?

passport system by trusted entities. This service package also grants accessand authority to perform specific actions in the battery passport system.

Service Packages
Service Packages represent slices of the Physical View that address specificSP5: Object attribute query and audit

services. A service package collects several different physical objects (systems

This service allows objects to query attributes about other objects under theand devices), along with their functional objects and information flows thatassumption that the first object has proper authority to view such attributes.

altogether provide the desired service.

SP6: Object attribute update

Service Packages to Support Battery Passport System
SP1: Object registration and discovery
In this service package, each object

This service package provides registration and lookup services necessary toregisters itself and tells the registry where

allow objects to locate other objects within the battery passport system. An

it lives in the system/network (e.g., host,port, node name) and information about theservices it provides.

This service package allows objects toThis service package allows objects to update their attributes or other objects.

update their attributes or other objects.

For example, a dealer object may update the last reported state of health of abattery on behalf of its customer.
SP7: Data distribution and authentication

object registry is like a phone book for all the “objects.’’ In this service package,each object registers itself and tells the registry where it lives in the system/

This service package manages the distribution of data between objects. It

network (e.g., host, port, node name) and information about the services it

informs objects of how to provide data, manages data subscriptions, andprovides. Other objects can use this information to determine the type ofprovides data forwarding capabilities.

service, the geographic scope of the service, and other details that help usersof the registry to make informed decisions about which object(s) support a

SP8: Data storage and reportingneeded service or information stream — i.e., discovery. A physical object may
be a battery, vehicle, individual, etc. The object may be represented by its digitalThis service package pertains to distributed data storage where an object’s

twin.

attributes may be stored in a third-party database/provider.

SP2: Communication between objects

Service Packages to Provide Battery Information

This service package provides secure, reliable communications between
objects. It provides layered protocols and communications services and includes
the physical network that supports communications. Communication includes

It is worth noting that other national and

For this guideline, as an example, we define service packages to provide battery

regional regulations may require different

information as required by the EU regulation. It is worth noting that other national

battery information.

and regional regulations may require different battery information. The detailed

access to battery information via cloud services or other wireless communication

scope and specification of these services is out of scope of this document. For

in a peer-to-peer environment.

brevity, the service packages are defined in a high-level and abstract manner.
The following list of service packages is not meant to be exhaustive.

SP3: Security and credentials management
This service package is used to ensure trusted communications between objects
and protect the data they handle from unauthorized access. The service package

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SP11: Raw material sourcing
This package gathers and provides information about the responsible sourcing

Presentation Layer = displays results about individual batteryof battery materials to downstream stakeholders. Such information includes
the source of materials, percentage of recycled materials, ethical sourcing
verifications, etc.

Business Layer = issues certs, access control, battery performance calc

SP12: Carbon footprint reporting
This service package gathers and provides

This service package gathers and provides carbon footprint information aboutcarbon footprint information about anan individual battery pack. Arguably, this service package requires the collection

individual battery pack.

of carbon footprint information from multiple stakeholders that are involved in

Data Layer = stores battery info, certificates, etc. in off-chain storage

mineral sourcing, distribution, transport, and more.
SP13: Electrochemical performance and durability parameter
This service package gathers and provides information related to the

Network Layer = P2P communication between the trading partners

electrochemical performance and durability of a battery. Such information may
include rated capacity and capacity fade, internal resistance, and indicationof the expected lifetime under the conditions for which the battery has been
designed.

Trust Layer = provides identifier anchor, decentralized ledger

SP14: Labeling of battery pack
This service package gathers and provides

This service package gathers and provides information that must be included

information that must be included in a label

in a label attached to the batteries. It may include the manufacturer’s name;attached to the batteries. Indelible labelingon batteries will help connect the physicalbattery with its digital twin.

Figure 2. Layers in the battery passport system.

registered trade name or trademark; the battery type; batch, serial number, orother element allowing its unequivocal identification; battery model identifier;date of manufacture; date of placing on the market; chemistry; safe handling
methods, etc. Indelible labeling on batteries will help connect the physicalbattery with its digital twin.
SP15: Battery life cycle stage reporting
This package gathers and provides information about whether a battery has
been recycled, repurposed, or reused, and whether a battery’s identity haschanged due to repurposing and/or deprecated due to recycling.

Layered System Implementation
The battery passport system will include

The battery passport system will include several layers, which should beseveral layers, which should be managed

managed by separate legal entities/networks/consortiums so that no one entity

by separate legal entities so that no one
entity has majority control.

33© 2023 MOBI. All rights reserved.

has control over the majority of the battery passport systems. Figure 2 below
illustrates the five layers.

© 2023 MOBI. All rights reserved.

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Trust Layer

Network Layer

The trust layer works as an underlying

A trust layer in a decentralized system reduces the risk of dealing with fraudulent

The network layer comprises peer-to-peer communication between theservice providing a feedback mechanism

counterparts. The trust layer works as an underlying service providing a

stakeholders. This layer ensures that the stakeholders can share information

feedback mechanism for end-users and maintaining trust relationships among

in a secured environment and synchronize to keep the underlying ledger in athem in the ecosystem accordingly.16 Generally, the trust layer ensures thecorrect state (if such a ledger exists.)for end-users and maintaining trust
relationships among them in the ecosystem
accordingly.

stakeholders that they are transacting with the correct entities. The trust layer
is implemented differently in centralized systems vs. decentralized systems.
In the centralized architecture, an entity primarily guarantees that the correct
stakeholders are transacting by providing a centralized identity framework
and access management system. In decentralized systems, some of that

Data Storage Layer
On-chain data provides a byzantine fault-

The data storage layer stores on-chain and off-chain data. On-chain data

tolerant ledger visible to the entire network

provides a byzantine fault-tolerant ledger visible to the entire network andand anchors business transactions toprevent double-spending.

responsibility is pushed to the edges or to the stakeholders themselves. Thereconfidential. For example, a vehicle manufacturer may not want to disclose toover the other. One such trade-off is the fact that the stakeholders are at thethe rest of the network the scope and size of its transactions with its material

mercy of such an entity in a centralized system to maintain the sanctity andsuppliers, cell manufacturers, or pack manufacturers.

security of their business data but reduce the cost of doing so.
In a decentralized battery passport system, the trust layer can provide athe trust layer can provide a federated

federated certificate authority that at a minimum allows stakeholders to anchor,

certificate authority that at a minimum
allows stakeholders to anchor, in a tamper-

in a tamper-evident way, their entity SSIs; verify the identities of their partner

evident way, their entity SSIs; verify thecompanies; and verify the identities of battery packs. It may also include a

identities of their partner companies; andconsensus mechanism and protocol by which it maintains the current state ofverify the identities of battery packs.

the battery passport requires such a ledger to store proofs of sharing battery
performance data. This is primarily because such transactions are considered

are significant trade-offs that stakeholders must consider when choosing one

In a decentralized battery passport system,

anchors business transactions to prevent double-spending. We do not believe

Such storages can be used to store

We believe the battery passport, based on our reading of the EU regulation,

calculation details of battery performance

only requires verification of claims provided by the economic operators, whichparameters, audit and certification reports,
as well as business transaction files

can be executed as verifiable credentials.

between upstream and downstream
stakeholders.

Off-chain storages are maintained and managed by individual stakeholders
within their firewalls. Such storages can be used to store calculation details

a tamper-evident ledger of transactions between the stakeholders. This layerof battery performance parameters, audit and certification reports, as well as

may also include a permissioned network of nodes that collectively provide abusiness transaction files between upstream and downstream stakeholders.

tamper-evident shared state ledger to store transactions, events, etc.

Business Layer
The business logic layer handles the business rules, calculations, and logic
within an application. It determines how data from the data layer is accessed,
shared, and used by the stakeholders. It includes other capabilities such asservice discovery, access management, etc., and the potential use of smart
contracts to execute agreements between trading partners.
Application Layer
Web and mobile applications with proper

The application layer comprises programs (e.g., dApps) that the stakeholders

rights to access nodes, shared ledgers,

utilize to query and view information about the batteries. For brevity, this layer

and ability to present battery information,
allow the general public to query about

can also be thought of to include a presentation layer. This layer also includes

a battery and raise inconsistencies in theapplications by which the stakeholders view each other’s on-chain and off-

battery data.

chain data with their upstream and downstream partners. Web and mobile
applications with proper rights to access nodes, shared ledgers, and ability topresent battery information, allow the general public to query about a battery
and raise inconsistencies in the battery data.

16

Nguyen Truong, Gyu Myoung Lee, Kai Sun, Florian Guitton, YiKe Guo, A blockchain-based trust system fordecentralized applications: When trustless needs trust, Future Generation Computer Systems, Volume 124, 2021,
Pages 68-79, ISSN 0167-739X, https://doi.org/10.1016/j.future.2021.05.025.

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passports that are issued by government agencies.

REFERENCE IMPLEMENTATIONThe B-SSDT™ is where the information about a battery resides. The B-SSDT™
includes information such as the battery’s owner, birth certificate, materials,

7.1 Self-Sovereign Digital Twin™
A Self-Sovereign Digital Twin™ (SSDT™)

A Self-Sovereign Digital Twin™ (SSDT™) is a digital twin which is anchoredis a digital twin which is anchored by W3C-

by W3C-compliant Decentralized Identifiers (DIDs)17 in a decentralized trust

compliant Decentralized Identifiers (DIDs)
in a decentralized trust network.

network. Any entity with an SSDT™ can participate as an autonomous agent
in trusted transactions by issuing W3C-compliant Verifiable Credentials (VCs)18
linked to DIDs. SSDTs store a combination of encrypted static and real-time
data, which is not accessible to anyone without explicit permission from themaintenance history, warranty and recall logs, charging history, and state ofhealth, and has the capability to issue payments for services performed on thebattery.
Through the B-SSDT™, this vehicle owner

The holder of the B-SSDT™ can participate in transactions (including data

can selectively share information aboutsharing) by issuing VCs and VPs with a third party. For example, a holder ofthe battery with an insurance company orrepair shops.

owner and/or controller of the SSDT™.

battery attributes, and their consent is required to use those credentials.

across different platforms and networks. It is a software-based container that is

7.3 Battery Passport: A Verifiable Credential

owned by a distinct and unique entity or thing.
The newly created SSDT™ is given a unique DID. The DID is then used to

manage the life cycle of such DIDs – create,

authenticate the SSDT™ when it communicates with other SSDTs™. The

update, archive, and read.

SSDT™’s primary function is to manage the life cycle of such DIDs – create,
update, archive, and read. Note that one SSDT™ can house and manage avirtually unlimited number of DIDs.
The SSDT also manages the lifecycle of VCs that contain claims about thecredential subject (most often the DID(s) managed by the SSDT™) and assertionsof those claims by the VC issuer. When the SSDT™ needs to communicate withother entities (that have SSDTs™) within the decentralized trust network via its
APIs, it can use VCs to prove its identity and verify the identity proofs of otherthis vehicle owner can selectively share information about the battery with aninsurance company or repair shops. The vehicle owner controls the VCs with

SSDTs™ are designed to be interoperable and communicate with other SSDTs™

The SSDT™’s primary function is to

the B-SSDT™ can be a vehicle owner (an individual). Through the B-SSDT™,

In addition to holding the physicalThe battery passport is a VC presented by the holder of the B-SSDT™ to a third

attributes of the battery, the B-SSDT™

party. In addition to holding the physical attributes of the battery, the B-SSDT™

also stores traceability-related data in its
encrypted data vault.

also stores traceability-related data in its encrypted data vault. Because
traceability data will come from multiple sources (entities), the B-SSDT™ will
ensure the verifiability of such data by linking the identity of the entities to atrust anchor.
For example, when an EO presents a battery passport as a VC to another entity,
it will include the EO’s claims along with claims from several of its upstream
suppliers The battery passport VC would have an issuer, a holder, and verifiers,
as illustrated in Figure 3 below.

SSDTs™.
The SSDT™ can also create Verifiable

The SSDT™ can also create Verifiable Presentations (VPs) that may contain one

Presentations (VPs) that may contain one oror more VCs to share with other entities (with SSDTs™) based on presentation

more VCs to share with other entities (with
SSDTs™) based on presentation requests
for identification by other SSDTs™.

requests for identification by other SSDTs™. It leverages SSI to give SSDT™
owners/controllers autonomy over their identity and data, including who sees
their data, how much they see, and how that data is used. This is in contrast
with the centralized identity paradigm, where entities’ identities are controlled
by some outside entity.

7.2 Battery Self-Sovereign Digital Twin™
What is unique about the battery SSDT™

The battery SSDT™ (B-SSDT™) stores and receives information about theis that an outside issuing entity is notbattery from outside sources, responds to internal and external queries, andrequired, unlike travel passports that areissued by government agencies.

37© 2023 MOBI. All rights reserved.

asserts its identity and the information it stores/presents. What is unique about
the battery SSDT™ is that an outside issuing entity is not required, unlike travel

17“Decentralized Identifiers (DIDs) V1.0.” n.d. Www.w3.org. https://www.w3.org/TR/did-core/.

18“Verifiable Credentials Data Model 1.0.” 2019. W3.org. November 19, 2019. https://www.w3.org/TR/vc-data-model/.

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An example of credential chaining:battery passport credential = {		

ID = 9383jdy393746

BIN = 3039444847,# of cells/module = 10,# of modules = 20,
		CO2/cell = 80 kg,

		

Recycled lithium/cell = 5%,

		

Link to a VC provided by a cell 					manufacturer,....
…
proof
}

Figure 3. Example Flow of Battery Passport Credential.

Cell manufacturer credential = {7.4 Verifiable Credential Chaining
We anticipate that upstream companies,

We anticipate that upstream companies, such as mineral sourcers and cell

will share information pertaining to the

manufacturers, will share information pertaining to the source of materials,

source of materials and other relevant
details with their downstream customers.

		

Batch # = 03938474,

		# of cells/batch = 300,

CO2/cell = 80 kg,
Link to CO2 audit VC,

child labor practices, greenhouse gas emissions, and other relevant details with
their downstream customers. Eventually, this data will be consolidated and		Recycled lithium in batch = 5%,

		

Link to recycled lithium audit VC,

		….

provided by an EO in the battery passport. Since EO has the final responsibility}of submitting data about a battery put into service, it may desire to prohibit its
upstream partners from submitting battery data unanimously and independently,
which can cause contractual disputes among partners. Alternatively, the EO canuse credential chaining to back-refer data from its upstream providers and use

In the above example, the cell manufacturer’s VC is linked to the battery

the chain to provide proof of its claim about a battery.
When an OEM presents a battery passport

When an EO presents a battery passport as a VC to a third party such as a

as a VC to a third party such as a regulator,

regulator, it will include claims from several upstream suppliers of the EO.

it will include claims from several upstream
suppliers of the OEM.

battery pack configuration to the EO. This claim can be attached to the VC thatthe claims made by others in the supply chain. The EO may have to bear thelegal brunt of providing erroneous data provided by upstream data providers.
Credential chaining only points users to the data source and does not guarantee
the correctness and timeliness of the data provided by upstream vendors.

© 2023 MOBI. All rights reserved.

certified the use of recycled lithium.

7.5 Lifecycle of the Battery SSDT™

For example, battery pack manufacturers can provide a VC with claims about
the EO will provide to the third party. Hence, the regulator can view and verify

39

passport VC. The cell manufacturer’s VC includes the VCs of the auditors that

A battery manufacturer creates an SSDT for

A simple use case demonstrates the B-SSDT™ lifecycle management:a battery pack once it is off the production
line.

»

A battery manufacturer creates an SSDT for a battery pack once it
is off the production line. Hence, each battery has its own B-SSDT™
with a unique DID that is managed using the W3C Universal Wallet
implementation within the SSDT™.

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Battery manufacturers will use the W3C◦

VC Issuance & Verification component

7.6 Use of Integrated Trust Network

The battery DID is used to authenticate the B-SSDT™ whenit communicates with other SSDTs™ within the decentralized

within the SSDT™ to issue a Battery BirthCertificate (in the form of a VC), which istrust network, such as the SSDT™ of the vehicle that thestored in the B-SSDTTM.

battery is installed in, the SSDT™ of the battery owner, theregulatory agency, or of a vehicle service shop trying to analyze

MOBI designed ITN as a scalable, protocol-

The Integrated Trust Network (ITN) can be thought of as a base identity

agnostic digital infrastructure to provide

infrastructure (a federated certificate authority). In a battery passport system,

trusted identity services for connectedmobility and IoT commerce.

a malfunction and having to authenticate itself to gain accessthe ITN provides the following capabilities:»

The ITN implements identity and assurance services. The ITN’s
integrity layer component comprises initially one private Distributed

to battery data.

Ledger Technology (DLT) network with each ITN node operator◦

running a DLT node, and a public DLT.

Battery manufacturers will use the W3C VC Issuance &Verification component within the SSDT™ to issue a Battery
Birth Certificate (in the form of a VC), which is stored in the»»

ITN can be used to create/revoke/deactivate the identities of batteries
and stakeholder entities.

B-SSDT™.
»

The battery manufacturer provides a Battery Birth Certificate to let’s

ITN can validate transactions and ensure that data is kept confidential.

say a vehicle manufacturer. It will install the battery in a vehicle and

MOBI designed ITN as a scalable, protocol-agnostic digital infrastructure toissue a Vehicle Birth Certificate linked to the Battery Birth Certificate.

provide trusted identity services for connected mobility and IoT commerce. The
ITN was launched by the MOBI community and is currently being developed incollaboration with MEF, AAIS, and other consortia.
The ITN provides a Zero Trust infrastructure which is important for the
stakeholders’ systems to significantly up-level their security posture due tothe unprecedented level of data exchange between stakeholder systems
horizontally and vertically in the battery value chain.
Using the ITN, businesses will be able

As the first federated Certificate Authority (CA) for IoT, eCommerce, andto create secure digital services thatbusiness automation, the ITN acts as a global trust anchor for digital business.

are locally highly performant while also
decentralized in their use.

Using the ITN, businesses will be able to create secure digital services that are
locally highly performant while also decentralized in their use.
ITN is a federated network of member-owned and operated ITN nodes
designed to overcome the security and resiliency failures of centralized systems.
For detailed information about ITN, please read the ITN Value and TechnicalNarrative White Paper.

An ITN node is the fundamental building

An ITN node is the fundamental building block of the ITN and enables

block of the ITN and enables organizationsorganizations to perform Zero Trust compliant digital business transactions byto perform Zero Trust compliant digitalbusiness transactions by providing a41© 2023 MOBI. All rights reserved.

providing a resilient and secure decentralized SSI infrastructure and businessresilient and secure decentralized SSI

transaction assurance services such as the Proof-of-Correct-Execution.

infrastructure and more.

Fundamentally, the ITN offers the following benefits:© 2023 MOBI. All rights reserved.

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Decentralization

The ITN provides benefits related todecentralized, security, accessibility, andefficiency.

1

ITN Nodes enable the creation of decentralized networks. This

Citopia allows SSDTs™ to discover each

Citopia allows SSDTs™ to discover each other and share information aboutother and share information about things

things like battery performance. SSDTs™ are linked by DIDs to a trust anchor

like battery performance.

such as the ITN. On top of that, Citopia leverages zero-knowledge proofs andother advanced cryptographic methods to give users control over who sees

ensures that the network is more resilient and less susceptible totheir data and how that data is used.

attacks as there is no single point of failure.

7.8 Implementation in a Zero Trust Environment

2

Security

To ensure global implementation of battery passports with visibility and

ITN nodes utilize standardized communication protocols and DLT

traceability throughout the value chain, especially in a decentralized

principles to ensure that transactions are secure and tamper-

environment, it is essential to adopt a zero trust architecture. This approach

proof. By utilizing cryptographic algorithms, ITN nodes can verify

prioritizes data security by implementing stringent measures to protect

the identity of participants, validate transactions, and ensure thatstakeholders’ information and prevents unauthorized access or breaches.

data is kept confidential.
The use of the ITN together with SSDTs™

The use of the ITN together with SSDTs™ enables applications to implement

enables applications to implement

nation-states’ mandates of more stringent cybersecurity frameworks as

nation-states’ mandates of more stringent

3

encapsulated by the US Government’s Executive Order to mandate a new

Accessibility

cybersecurity frameworks as encapsulated

ITN nodes can be accessed from anywhere with an internetby the US Government’s Executive Ordercybersecurity framework called Zero Trust. This is achieved by requiring thatto mandate a new cybersecurity framework

every participant utilizing the ITN through its SSDT™ authenticates andconnection, enabling organizations to participate in the network

called Zero Trust.

regardless of their location. Also, identity data anchored on-chain

authorizes every other participant for every single digital business interaction
at all times.

is replicated across all ITN nodes to avoid downtime for ITN coreservices.

Hence, the use of ITN and Citopia ensures a Zero Trust environment by thefollowing:

Efficiency

4»

The use of public/private key management services. These keys will be
used for signing all business transactions in a Zero Trust architecture.

ITN nodes allow for fast and efficient processing of transactions
as it is a permissioned network. This can lead to reduced costs,»

which can benefit organizations.

Furthermore, sensitive identity-associated data such as PII, VCs (held),and VPs (received) require an encrypted data vault (EDV) service.
SSDTs™ provides such a service, ensuring the privacy and security ofusers’ most sensitive data at all times.

7.7 Use of Citopia
The Citopia Network allows entities,

Citopia is a member-owned and operated federated Web3 marketplace for

In a Zero Trust environment, secureboth consumers and businesses, toconnected ecosystems and IoT commerce. In this marketplace ecosysteminteractions with business applications

stakeholders can securely and privately perform digital business across thenecessitate a reliable authentication service

independently offer and consume secure
and privacy-preserving mobility services.

Citopia ecosystem. The Citopia Network allows entities, both consumers andbusinesses, to independently offer and consume secure and privacy-preserving»

applications necessitate a reliable authentication service capable ofworking with both SSI and legacy certificates. This authentication

capable of working with both SSI andservice serves the purpose of granting access only to authorized

legacy certificates.

parties, ensuring that only the designated individuals or entities canmobility services.
Through Citopia, B-SSDTs™ will be made visible, discoverable, and available forcommunication with the battery passport stakeholders. For example, a vehicle
manufacturer may want to make the battery passport available to regulators.
Hence, these SSDTs™ must be onboarded into a network.

In a Zero Trust environment, secure interactions with business

access EDV data stored in the SSDT™ or specific SSDT™ services.
»

Lastly, secure data sharing with others and securely replicating
one’s data has become a cornerstone of business applications. The
SSDT™ offers both a secure data sharing service with other SSDTs™
and a secure data replication service for replication between a user’s
SSDTs™ while adhering to Zero Trust requirements without the needfor a third party.

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IMPLEMENTATION CHALLENGES

8.4 Lack of Data Interoperability Framework
These layers must be compatible with

Decentralized implementation will require more than one entity to be responsible

stakeholders’ legacy systems by ensuring

for maintaining the system layers. This means the entities and the layers theythat the battery passport system is

Implementation of the battery passport is not trivial for the reasons discussed
below:

compatible with at minimum standardsbased systems such as EDI, IMDS, etc.

We anticipate that future regulations will provide clarity regarding theprovide clarity regarding the necessary datanecessary data to be provided about a battery. These regulations should also

to be provided about a battery.

8.5 Easy Access to the Passport Information
Entities that need to find battery passport information vary from large companies
like vehicle/grid storage manufacturers to small/medium size companies likeoutline guidelines for the collection of data, specifying the required quality

repair shops. These small/medium sized companies will need easy access toand quantity. The Rulebook on Child Labor and Greenhouse Gas Emissions

battery information for example by simply scanning a QR code on the battery.

developed by the Global Battery Alliance (GBA) serves as an excellent exampleof specifications that can be adopted to meet these requirements. However, theRecycling/repurposing companies may need to query information from batches

EU regulation encompasses additional requirements that would benefit fromof batteries at the same time. The battery passport system should allow such

further specification and alignment with regulatory expectations.
Clear specifications in this regard would

For instance, the regulation emphasizes the inclusion of battery component

ensure consistency and enable effective

information in battery passports. While the regulation does not explicitly

compliance with the regulations while
facilitating transparency and traceability
throughout the battery value chain.

mention the specific names of these components, it is crucial to address thisgap. Given the diverse battery supply chain involving multiple companies“batch” access via API endpoints.
Battery value chain members may need

Battery value chain members may need to verify information provided by EOs

to verify information provided by EOs andand non-EOs in the battery passport. The technical requirements to verify such

non-EOs in the battery passport.

proofs of the data providers.

pack manufacturers, it becomes essential to establish specific names for thecomponents that must be included in the battery passport. Clear specifications

8.6 Governance of Decentralized Systems

in this regard would ensure consistency and enable effective compliance withbattery value chain.

8.2 Unclear Implementation Costs
The cost of creating a battery passport

The cost of creating a battery passport system and who will bear such a cost

system and who will bear such a cost isis unclear at the moment. It is also unclear how the system will be financiallyunclear at the moment.

sustained and what the appropriate business model may be. Because there arestill open questions about who will bear the most responsibility of “submitting”
data about a battery to the system, how will that entity bear the cost of doing
so and how it will “transfer” some of that cost to its upstream and downstream

information cannot be burdensome. They should be able to easily scan the QR
code, view the claims from the EOs (as an example), and ensure there are digital

responsible for manufacturing various battery components supplied to cell or

the regulations while facilitating transparency and traceability throughout the

stakeholders’ legacy systems by ensuring that the battery passport system iscompatible with at minimum standards-based systems such as EDI, IMDS, etc.

8.1 Need for Clear Regulatory Specifications
We anticipate that future regulations will

will maintain must be interoperable. These layers must be compatible with

We believe such governance should not be

At MOBI, our preference is decentralized data governance, in which thepushed to a centralized authority.

edges (the industry) play a more active role in governing the system because
ultimately it is they who will create the granular battery passport and who risk
great losses of market value for not providing accurate information. We believe
such governance should not be pushed to a centralized authority.
We take this position for another reason. We’re nearly certain that if the US
passes similar battery passport regulation, it will take a more decentralized(and hands-off approach) position in terms of how the industry builds the
passport system governance as it has done with other types of traceability

suppliers and customers is also unclear.

regulations, the most recent being the Title II of the Federal Drug Security Act

8.3 Undue Financial Burden on Small Businesses

the industry.19

in which responsibility of building the drug supply chain system is pushed to

The battery supply chain includes many small and midsize companies acrossthe globe. They may include distributors, scrap yards, collectors, and logistics
companies, many of whom do not have the budget to buy expensive software
subscriptions to input battery information.

19

US Congress, Drug Quality and Security Act, Nov. 27, 2013https://www.govinfo.gov/content/pkg/PLAW-113publ54/pdf/PLAW-113publ54.pdf

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