Compliance with Regulation (EU) 2023/1542

AccuID is built to meet the EU battery regulation requirement by requirement. Here's how the platform already covers each one — expand a row for the details.

An engineering interpretation, not a legal certification

This page reflects our current understanding of Regulation (EU) 2023/1542, built on our own internal specifications — it is not a legal certification of compliance, nor legal advice. The Commission's implementing act that will fix the passport's detailed technical format (Art. 77(5)) has not been published yet; this page will be updated once it is.

Covered todayA QR code gives access to each battery's passportArt. 13(6)

Each passport receives a unique, non-guessable identifier as soon as it's created. The corresponding QR code exports ready to use as SVG, PNG, or PDF, sized and calibrated (high error-correction level) to withstand industrial engraving.

Covered todayA digital passport, always up to date, for every batteryArt. 77 + Annex XIII

Nearly 60 structured fields, organized into 7 regulatory categories, editable throughout the battery's life and served live from the QR code link — rather than printed once and never updated.

Covered todayDeclared carbon footprintArt. 7 + Annex XIII

A dedicated carbon-footprint category — total, lifecycle breakdown, methodology, verifying body — always public, never configurable as hidden data.

Covered todayRecycled content share (cobalt, lithium, nickel, lead)Art. 8 + Annex XIII

A dedicated recycled-content category, with the same permanent-publication guarantee as the carbon footprint.

Covered todayTiered access: some data public, some restrictedArt. 77 + Annex XIII

A role model distinguishes public data from data reserved for parties with a legitimate interest, and data reserved for authorities — enforced server-side on every read, regardless of the client used.

Covered todaySupply-chain due diligence, including child-labour riskArt. 52 + Annex XIII

A dedicated due-diligence category: policy reference, independent verification, risk categories, country of origin, corrective measures.

Covered todayThe passport follows the battery through reuse, refurbishment, and recyclingArt. 77(8), Annex XIII pt. 4

A lifecycle model where a responsibility transfer produces a linked successor passport, and a recycling declaration closes the original's public exposure — all of it append-only and fully auditable.

Covered todayLong-term availability of passport dataPlatform commitment, beyond the regulatory minimum

Published passports remain publicly accessible for at least 10 years, regardless of the manufacturer's subscription status.

Covered todayMultiple people at the same manufacturer can keep the data up to dateImplicit in Art. 77's update obligation

A Company account with scoped internal roles and an invitation flow, so data entry never depends on a single person.

Open points still pending

These are identified and tracked, but depend on EU texts not yet published, or on product decisions not yet made — we'd rather say so than leave it out.

  • Awaiting EU textCommission implementing act (Art. 77(5))

    This text is meant to fix the passport's detailed technical format. Until it does, our nearly-60-field data model is an engineering interpretation, built on industry best practice, that may need to change once the act is published.

  • Awaiting EU text"Legitimate interest" criterion (Art. 77(9))

    The regulation hasn't harmonized this criterion yet. In the meantime, the approved-operator and recycler roles are granted through manual platform-side verification — a provisional approach we'll revisit once the EU text lands.

  • Not yet implementedUpload to the EU central registry (Art. 77(10))

    A real, already-in-force obligation, but not yet technically implemented: the Commission has not published that registry's API yet. We track this separately and will prioritize it once it ships, ahead of the 18 February 2027 deadline.

These regulatory guarantees come with long-term reliability commitments too — custom domain, public availability, auditable history.

See the Independence & reliability page