Policy brief
Oct 22, 2026
Closing the cell-level gap: why the EU Battery Passport needs to reach disassembled modules and cells
From February 2027, EV, light means of transport and industrial batteries placed on the EU market will need a digital Battery Passport. However, the passport applies to the battery as placed on the market, not to the modules and cells recovered once it is dismantled. Drawing on evidence from REBELION’s pilot lines, this policy brief explores the resulting traceability gap for recyclers and second-life operators. It sets out three recommendations for EU policymakers and standardisation bodies.