How to Collect Supply Chain Data from Tier 2 and Tier 3 Suppliers for EU DPP Compliance

Why Supply Chain Data Collection for DPP Matters

EU Digital Product Passport compliance does not stop at your factory gate. Several battery passport data points depend on inputs from your upstream suppliers, and Regulation (EU) 2023/1542 sets dates from which that information is required.

What the Battery Regulation Actually Requires You to Collect

Regulation (EU) 2023/1542 (the EU Battery Regulation) specifies several categories of information that must appear in the battery passport. Under Article 77(2), the passport must include, to the extent applicable to the battery category, the following data drawn from Annex XIII, point 1:

• Material composition of the battery, including hazardous substances other than mercury, cadmium or lead. Hazardous substances here means substances classified as hazardous under Article 3 of Regulation (EC) No 1272/2008, not simply substances on the REACH SVHC list.
• Carbon footprint information, governed by Article 7 and built on the essential elements in Annex II. Article 7(1) applies from dates that depend on the delegated and implementing acts it refers to.
• Recycled content information under Article 8(1), which applies from 18 August 2028 or 24 months after the entry into force of the delegated act it refers to, whichever is the latest, and from 18 August 2033 for LMT batteries.

These values often cannot be produced from internal data alone. Material composition depends on what your cell and module suppliers put into their products. Annex II, point 5, which sets essential elements for the carbon footprint methodology, requires activity data for the anode, cathode, electrolyte, separator and cell casing to refer to a specific battery model produced in a specific plant, and permits no default activity data for those inputs. Recycled content figures must reflect the actual sourcing decisions made further up the chain.

Which Suppliers Are Legally Bound to Give You Data

Article 39 of Regulation (EU) 2023/1542 places a direct legal obligation on suppliers of battery cells and battery modules. They must provide the battery manufacturer, free of charge, with the information and documentation necessary to comply with the Regulation. The Article sets no condition that the supplier be established in the EU.

Other upstream suppliers carry no general duty under the Battery Regulation to hand over passport data. Where suppliers in the chain hold third-party verification reports on their battery due diligence policies, Article 49(2) requires those reports to be made available to downstream operators. For everything else, you secure the data by contract. From 18 August 2027, operators within the due diligence scope must incorporate their battery due diligence policy into contracts and agreements with suppliers, as required by Article 49(1)(e).

Separately, suppliers of substances and mixtures must provide safety data sheets in the cases set out in Article 31 of REACH, Regulation (EC) No 1907/2006. Those sheets are a useful starting point for hazardous substance data, but they do not replace the full material composition disclosure the passport requires.

Due Diligence Obligations and Traceability from 18 August 2027

Articles 48 to 52 of Regulation (EU) 2023/1542 require battery due diligence covering the raw materials listed in Annex X, point 1: cobalt, natural graphite, lithium, nickel, and the chemical compounds based on them that are needed to make battery active materials. The obligation applies from 18 August 2027 under Article 48(1), as amended by Regulation (EU) 2025/1561.

Article 47 excludes operators whose net turnover in the financial year preceding the last financial year was below EUR 40 million, provided they are not part of a group that exceeds that limit on a consolidated basis. If you are above the threshold, your traceability documentation must include at least, for each covered material, a description of the raw material, its supplier, its country of origin, the market transactions from extraction to your immediate supplier, and the quantities involved, as specified in Article 49(2).

From the same date, Article 49(1)(d) requires operators in the due diligence scope to run a chain of custody or traceability system that identifies upstream actors in the supply chain, supported by documentation of the market transactions from extraction to the immediate supplier (Article 49(2)). Waiting until 2027 to build supplier relationships and data flows for this is risky: the obligation applies from 18 August 2027, so the traceability system and its documentation need to be in place by then.

A Practical Approach to Supply Chain Data Collection for DPP

The Battery Regulation prescribes no format or channel for exchanging data with suppliers. That gives you flexibility, but it also means you must design your own process. The following steps combine what the law requires with practical suggestions. The Regulation does not refer to supplier tiers.

1. Map your supply chain to at least Tier 3. Identify every supplier of battery cells, modules, active materials, and the raw materials listed in Annex X, point 1. You cannot collect data from suppliers you have not identified.
2. Segment by legal obligation. Cell and module suppliers owe you data under Article 39. Raw material and chemical suppliers do not, so you need contractual clauses. Draft those clauses now and include the Article 49(1)(e) due diligence policy requirement for suppliers in scope.
3. Send structured data requests. Common requests include: material composition certificates, country-of-origin declarations for raw materials, recycled content certificates with methodology, REACH SVHC declarations (useful context even though SVHC status does not define hazardous substances under the passport), and carbon footprint data for the supplied component.
4. Ask for supporting evidence. A number in a spreadsheet is not enough. Request test reports, third-party certificates, or safety data sheets to support each value. For carbon footprint, remember that Annex II, point 5 allows battery-specific activity data to be combined with PEF-compliant secondary datasets, so suppliers do not need to measure every value from scratch, but the activity data for the anode, cathode, electrolyte, separator and cell casing has to refer to a specific battery model and plant, so you will need those inputs from your suppliers.
5. Set contractual deadlines and consequences. Suppliers who are not legally obligated to respond may not prioritise your request without contractual pressure. Tie data delivery to purchase order terms or annual supplier agreements.
6. Verify and store with an audit trail. Market surveillance authorities can request access to the underlying documentation. Keep version-controlled records that show when each data point was received, from whom, and what evidence supported it.

Common Problems and How to Avoid Them

Suppliers claim they do not have the data. For cell and module suppliers, Article 39 obliges them to provide the information and documentation necessary to comply with the Regulation. Put the obligation in writing, cite the Article, and set a response deadline. For other suppliers, the issue is often that they have the data in a different format. Provide a template that maps to the specific Annex XIII data points you need.

Carbon footprint activity data is missing or generic. Annex II, point 5 says that no default activity data are to be used for the anode, cathode, electrolyte, separator and cell casing, and the carbon footprint methodology to be adopted by delegated act under Article 7(1) must build on that essential element. If a supplier sends you an industry average for those inputs, it will not meet that element. Ask for plant-specific production volumes and energy consumption figures instead.

Country-of-origin data stops at Tier 1. For the raw materials listed in Annex X, point 1, Article 49(2) requires traceability from extraction to your immediate supplier. Your Tier 1 supplier will therefore need to collect this from their own suppliers. Build that requirement into your contracts before 18 August 2027.

Data arrives in incompatible formats. The Regulation sets no standard format, but you can. Define a data schema in your supplier agreements and validate incoming data against it automatically. This reduces manual reconciliation.

Connecting Supplier Data to the Passport

Once collected, supplier data must map to specific Annex XIII data points. Material composition sits under Annex XIII, point 1(b), which is publicly accessible under Article 77(2); the detailed composition, including the materials used in the cathode, anode and electrolyte, sits under point 2(a), which is not public. Carbon footprint and recycled content also fall under point 1. Individual battery data, such as state of health and remaining capacity, sit under Annex XIII, point 4, which is accessible only to persons with a legitimate interest. Understanding the access structure matters because it affects how you store and expose data in your passport system.

See also the EU Battery Regulation supply chain requirements guide.

Building the Process Before the Deadlines Hit

The due diligence traceability obligation under Article 49(1)(d) applies from 18 August 2027. The battery passport obligation under Article 77(1) applies from 18 February 2027 to LMT batteries, industrial batteries with a capacity greater than 2 kWh and electric vehicle batteries. Building supplier data collection processes takes time: supplier onboarding, contract negotiation, data validation, and gap remediation all need to be planned. Companies that start now have time to iterate. Companies that start later will be managing compliance under pressure.

Prioritise cell and module suppliers first, because Article 39 gives you a legal basis to demand data immediately. Then move to Tier 2 and Tier 3 suppliers of the raw materials listed in Annex X, point 1, using contracts to secure the traceability records Article 49(2) requires. Run both workstreams in parallel if your resources allow.

To see how Traceable could handle this for your products, register for a free trial.