Yes, you can prepare part of the digital battery passport yourself: gathering product data, technical specifications and documentation required by the regulation. The more challenging part lies in the technical implementation: putting the data in the correct data format, keeping it accessible for ten years, and creating a QR code that meets the requirements. Whether you set that up yourself or outsource it depends mainly on how many product types you carry and whether you already have systems suitable for managing this long-term.
The regulation itself does not prescribe who technically builds the passport. Regulation (EU) 2023/1542 determines what must be in the passport and who is responsible for it, but leaves the implementation free. This means that a company can in theory do everything itself, from compiling the dataset to hosting the page behind the QR code. In practice, it is especially the components with a long shelf life that call for a deliberate choice.
What you can do yourself
Gathering the basic data usually already lies with you or your supplier. Think of the battery type, chemical composition, serial number, manufacturing date and documentation on origin and recyclability. If you are an importer, you often already need this information for other purposes, such as customs or warranty. Compiling these data into a clear document is work that most companies can do themselves, especially if there is already a fixed process for product documentation.
It is also something you can make a first estimate of yourself: working out what role your company precisely has in the chain, and which data belongs with it. Those who still lack that overview can answer a few questions to get an initial direction before further steps are taken.
Where it becomes more difficult
The regulation requires that the passport remains available for ten years, even after a possible takeover, system change or cessation of an activity. This is a different kind of obligation than drawing up a document once: it is about continuity. An Excel file on an internal server does not automatically meet that requirement, and the question of who will still have access to the correct version of the data in five years becomes relevant.
Furthermore, the QR code must point in the correct way to a working page, in a data format that can be read by different parties in the chain. This requires a technical layer that not every company standardly has in-house. If a company enters into discussion with a software supplier about this, it is advisable to know beforehand which parts are already arranged internally and which are not, so that the discussion focuses on what is actually missing.
The choice between doing it yourself and outsourcing
The consideration is fundamentally a question of scale and management. A company with a handful of product types and an IT department accustomed to long-term data management can choose to build a solution itself. A company that carries many different battery types, or that has no permanent IT capacity, is more likely to face the question of who will maintain the passport over the years if the responsible employee is no longer in service.
It is advisable not to make this assessment solely on the basis of costs, but also on the basis of what happens if the hosting is withdrawn or if an audit asks to demonstrate that the data has been correct and traceable throughout those years. More background on how such a passport is created and where the data comes from can be found on the page showing how the information is compiled and hosted.
What if you start yourself anyway
If you choose to get started yourself, it is advisable to first clarify which data are already available and which are still missing. This prevents time being spent on building a system before it is clear what information must go into it. Questions that frequently come up at this first step, with a brief and concrete answer, are collected on the overview of frequently asked questions about the passport.
Whether you proceed yourself or outsource part of it, the final responsibility for the accuracy of the data remains with the company that is designated as the manufacturer or importer. For the precise interpretation of that responsibility in your own situation, the official text of the regulation, or advice from a lawyer or the competent supervisory authority, is the appropriate starting point.
Would you like to first get an idea of what is involved for your company? The free quick-scan provides an initial indication in a few questions, and the knowledge base with topics per situation goes into more detail on the steps that follow.