The EU Battery Regulation 2023 significantly increases compliance complexity and costs for automotive manufacturers. While its intention is to improve raw material circularity and market access for independent second-life operators, it also opens opportunities to maximize residual battery value along the value chain. However, merely complying with the regulation is insufficient to reap the full benefits of a circular economy.
In addition, the battery passport aims to ensure transparency and sustainability. To achieve this, it mandates a unique identifier for each battery as a QR code, which points to a web page with information on the basic characteristic and lifecycle data about the battery.
Requirements from the new battery regulations can be grouped into functional categories:
• Cradle-to-gate environmental footprint, calculated for each battery production batch and accessible online.
• Capability for legitimate parties (recyclers) to retire the battery passport upon recycling.
• Technical documentation to enable third parties to safely operate batteries in second life or disassemble them for repair, refurbishment, or remanufacturing
• Publicly available information to estimate residual value, such as available energy and residual lifetime, via BMS
• Capability for third parties to reset the BMS and operate batteries independently under their own responsibility
These requirements create a conflict between protecting manufacturers’ reputation and intellectual property on one side and the necessary openness for a cost-effective circular economy on the other side.

The digital battery passport, calculation of the state of certified energy, and provision of a BMS reset function for users with legitimate interests are novelties in the new EU Battery Regulation. These new topics will be beneficial for circular economy but pose difficulties and dangers without offering clear benefits to individual producers or consumers.
The digital battery passport lacks critical information for determining residual value, such as the State of Health and estimated residual lifetime, which must only be readable on the BMS, raising the questions of how open and easy such access could be. The regulation introduces the State of Certified Energy (SOCE) to measure energy guaranteed at the current aging state and mandates the publication of the residual lifetime. However, it does not specify user profiles for this calculation.
Regardless of how these values are calculated, they should be visible on the BMS and Battery Passport and accessible to third-party actors to make informed End-of-Life decision. The regulation does not specify a communication standard for third parties, this could cause a multiplicity of connectors, protocols and procedures to access the information on the BMS.
Third parties should be able to reset the BMS and implement their own application-specific software, while staying within safety limits specified in the battery passport. However, this raises two issues: potential cyberattacks via the BMS reset function and possible reputational damage to first-life manufacturers from second-life battery accidents.
One final aspect not covered by the regulation is measures to help recyclers deep-discharge batteries safely and quickly without proprietary BMS information or disassembling the batteries, which can be especially dangerous with slightly damaged batteries.
FEV proposes an integrated solution to fulfill regulatory compliance and the broader legislative goals of enabling a circular economy for automotive batteries in both End-of-Life and second-life phases while minimizing safety, security, and image concerns for automotive manufacturers.
This presentation suggests a modular hardware and software architecture for batteries and BMS.
This approach involves a cloud-based battery passport updated regularly, a modular BMS architecture enables a proper digital battery passport, and an End-Of-Line connector rated for second-life power and capable of CAN communication to trigger reset function.
The first step involves equipping the BMS with a cyber-secure microcontroller to store encrypted proprietary functions and a private key and adding an End-of-Life connector accessible via the OBD protocol.
This ensures that durability data on the BMS is available in an open, readable format without compromising cybersecurity. The End-of-Line connector triggers the reset function securely, sending an authenticated message over the OBD protocol.
A second step addresses recyclers‘ issues with unknown, potentially damaged batteries by preserving part of the memory from the reset function to enable a second, deep-discharge function triggered by authenticated messages from legitimate users.
Further steps involve using an OBD device connected to the internet to authenticate the battery to the cloud-based battery passport and update lifetime dynamic data such as durability, cycles, negative events etc., making batteries searchable and marketable as ready for 2nd life.
This presentation critically analyzes the EU Battery Regulation’s requirements, identifying where legislation alone is insufficient to achieve stated goals. Proposed technical solutions for software and hardware architectures address these issues modularly, enabling various circular economy aspects without compromising safety or cybersecurity, with minimal additional costs and complexity.