About
Regulatory experience for EU Digital Product Passport readiness.
Our story
Built with a team that delivers the data.
PASSready was founded by Amy Ward, a senior regulatory and compliance lawyer. With her team, we combine legal, compliance and data-transformation experience to help manufacturers, suppliers and public bodies establish what is required and close the gaps, starting with the EU Battery Passport.
Founder
Amy Ward
Founder, PASSready · Senior Regulatory and Compliance Lawyer
Senior regulatory and compliance lawyer currently based in Bangkok. Regularly advises on legal and risk matters arising from complex regulatory frameworks across Australia, the Pacific, APAC and the Middle East, with a particular focus on clients in Thailand, Vietnam, India and Chinese markets.
Previously advised national Australian research and development organisations and corporate Commonwealth entities on export controls; supported enterprise and commercial software companies on data privacy and broader compliance regimes, including work connected with Salesforce; and advised global FMCG businesses such as British American Tobacco, Asahi Beverages and Tabcorp in the highly regulated tobacco, alcohol and gambling sectors.
Frequently Asked Questions
What you need to know.
Digital Product Passports in general, and the Battery Passport, the first to apply.
Can't see your question?
Ask us on WhatsApp01What is a Digital Product Passport?
A structured, machine-readable electronic record for a product, reached through a data carrier such as a QR code. It holds information on the product's identity, composition, origin, environmental footprint, repair and end of life, with different parts visible to consumers, businesses and authorities. The EU is introducing passports product group by product group.
02Which products need one, and when?
Batteries are first: from 18 February 2027, Regulation (EU) 2023/1542 requires a Battery Passport for EV batteries, LMT batteries and industrial batteries above 2 kWh. Other product groups follow under the Ecodesign for Sustainable Products Regulation (EU) 2024/1781, with textiles, iron and steel, aluminium, furniture, tyres and mattresses among the first prioritised. Each group's requirements are set in its own delegated act, and generally apply no earlier than 18 months after it is adopted.
03Why start with batteries if our other products come later?
The Battery Passport is the first with a fixed date, and its evidence challenges (supplier data, composition, carbon footprint, unique identifiers, QR codes) are the same ones later passports will raise. A process built for batteries now is one you reuse for each product group that follows.
04What evidence will we need for a battery passport and its QR code?
Illustrative evidence for a single lithium-ion battery product line may include:
- Manufacturer identity, plant location and manufacturing date recordsAnnex XIII
- Battery model identifiers and unique product ID systemArt. 77
- Category, weight, capacity and chemistry dataAnnex XIII
- Full carbon footprint declaration and supporting life-cycle studyArt. 7
- Carbon footprint performance classArt. 7
- Recycled content shares for cobalt, lithium and nickelArt. 8
- Critical raw materials and hazardous substances informationAnnex XIII / Art. 6
- Performance, durability and expected lifetime parametersArt. 10
- State-of-health and usage data model capabilityArt. 14
- Dismantling, safety and repair informationArt. 11
- Supply-chain due diligence documentationArts. 47–52
- EU Declaration of Conformity and complete technical fileArts. 17–18
- Test reports, certificates and labelling artworkArt. 13
- QR code generation and EU Registry registration readinessArt. 13 & 77
This list is illustrative only. It is not a complete compliance checklist and does not replace a formal Gap Analysis against the full requirements of Regulation (EU) 2023/1542.
05Who carries responsibility for the passport?
The economic operator placing the product on the EU market must make sure its passport is complete and accurate. For batteries, depending on the route to market, that may be a manufacturer, importer or authorised representative. Suppliers further up the chain are usually the ones who hold the evidence.
06Which information belongs in the record?
It depends on the product group. For batteries, it reaches across product identity, material composition, emissions, due diligence, circularity, durability, performance, conformity and labelling evidence. Later passports will draw on similar categories of evidence with their own data points.
07Why does a missing passport create a commercial risk?
After the deadline, a covered product without the required passport may not be placed on the EU market. That can translate directly into delayed or blocked shipments, and lost contracts with European customers who need the data.
08How is the physical product connected to its data?
A data carrier on the product, usually a durable QR code, resolves to its electronic passport. For batteries, each QR code leads to the unique record for that individual battery.
09Can the process be managed in a spreadsheet?
Spreadsheets may help during collection, but they do not provide the final identity, access controls, machine-readable delivery and long-term availability the system needs.
10Is the record created at model level or item level?
It depends on the product group: each delegated act sets whether passports are kept per model, batch or item. For batteries, shared model information can be maintained centrally, but each battery still needs its own identifier and passport.
11What supports confidence in the underlying data?
Keep supplier provenance, supporting reports and declarations, field-level validation and a traceable history of review and change.