Technical Insight

GAR INSIGHT
EV Batteries Under New Rules: Homologation, Durability & the Battery Passport

The electric-vehicle battery is no longer simply a component that must demonstrate electrical and crash safety before a vehicle receives type approval. It is becoming one of the most closely regulated systems throughout the vehicle lifecycle.

EV battery compliance now extends across several interconnected areas: rechargeable electrical energy storage system safety, vehicle homologation, battery durability, state-of-health monitoring, performance retention, carbon footprint, material information, traceability and increasingly the digital Battery Passport.

This creates a fundamentally different compliance environment. Manufacturers must be able to demonstrate not only that a battery is safe when a vehicle is approved, but also how it performs, deteriorates, is identified and ultimately moves through its wider lifecycle.

The regulatory question surrounding the EV battery is changing. It is no longer simply: “Is the battery safe?” It is increasingly: “Is it safe, durable, traceable, environmentally accountable and capable of providing reliable lifecycle information?”
01
THE COMPLIANCE LANDSCAPE

The EV Battery Is No Longer Just a Vehicle Component

The traction battery sits at the intersection of automotive regulation, electrical safety, environmental regulation, product conformity and circular-economy requirements.

As a result, different regulatory frameworks can address different aspects of the same battery.

Vehicle Safety

Electrical, mechanical, thermal and post-crash battery safety form part of vehicle homologation.

Battery Durability

Regulatory frameworks increasingly assess how battery performance deteriorates during vehicle use.

Environmental Performance

Carbon footprint, materials and lifecycle impacts increasingly influence battery conformity.

Traceability

Battery identity and lifecycle information need to remain connected to the physical battery.

Second Life

Re-use, repurposing and remanufacturing create compliance requirements beyond first vehicle use.

End of Life

Collection, recycling and material recovery complete the regulatory lifecycle.

The battery therefore has two regulatory identities. It is both part of the homologated vehicle and a regulated product with its own increasingly extensive lifecycle obligations.
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02
UN R100 & REESS SAFETY

The Foundation of EV Battery Homologation

UN Regulation No. 100 is one of the principal international regulations governing the safety of electric powertrains and Rechargeable Electrical Energy Storage Systems — REESS — used in road vehicles.

Its role is fundamentally safety-oriented. The regulatory objective is to ensure that high-voltage propulsion systems and rechargeable energy-storage systems provide appropriate protection against electrical, mechanical and thermal hazards.

VEHICLE LEVEL Electric Powertrain Safety

The complete vehicle must satisfy requirements relating to protection against electric shock and other high-voltage hazards.

REESS LEVEL Battery System Safety

The rechargeable energy-storage system is subjected to defined safety assessments addressing foreseeable mechanical, electrical and thermal stresses.

Passing a cell test is not equivalent to homologating the vehicle battery.

Vehicle-level conformity depends on the complete REESS architecture, including cells, modules, enclosure, electrical protection, thermal management, battery management and integration into the vehicle.

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03
BATTERY SAFETY TESTING

What Must an EV Battery Survive?

Battery homologation requires assessment against a range of conditions intended to demonstrate that the REESS remains acceptably safe when subjected to foreseeable vehicle stresses and abnormal events.

Vibration

Evaluates the ability of the battery system to withstand mechanical vibration associated with vehicle operation.

Mechanical Shock

Assesses battery integrity under defined mechanical acceleration and impact conditions.

Mechanical Integrity

Evaluates the REESS response to mechanical loading representative of severe vehicle events.

Fire Resistance

Assesses the battery system’s behaviour when exposed to defined external fire conditions.

External Short Circuit

Evaluates protection against hazardous consequences arising from an external electrical short.

Overcharge Protection

Verifies that the battery system can manage abnormal charging conditions safely.

Over-Discharge Protection

Evaluates safeguards against excessive battery discharge.

Over-Temperature Protection

Assesses the effectiveness of protective systems when battery temperature moves beyond intended operating conditions.

The BMS is part of the safety architecture. Battery safety increasingly depends not only on cell chemistry and mechanical containment but also on sensors, software, control logic, contactors, thermal management and protective functions.
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04
IN-VEHICLE BATTERY DURABILITY

Safety at Day One Does Not Tell Us How the Battery Will Age

Battery degradation is unavoidable. Charge and discharge cycles, temperature, operating conditions, charging behaviour, calendar ageing and battery chemistry all influence how much usable energy remains available as the vehicle ages.

This is the purpose of the UNECE in-vehicle battery durability framework.

UN GTR NO. 22 Electrified Light-Duty Vehicles

Establishes a harmonised framework addressing in-vehicle battery durability for applicable light-duty electrified vehicles.

UN GTR NO. 25 Electrified Heavy-Duty Vehicles

Extends the international battery-durability framework to electrified heavy-duty vehicle applications.

The important shift is from initial performance to retained performance.

The regulatory concern is increasingly whether the traction battery can continue to deliver an acceptable proportion of its original capability as the vehicle accumulates age and mileage.

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05
EURO 7

Battery Durability Becomes a Vehicle Homologation Requirement

Euro 7 brings traction-battery durability directly into the European vehicle environmental-performance framework for applicable battery-electric and externally chargeable hybrid vehicles.

Passenger Cars — M1

UP TO 5 YEARS / 100,000 KM Minimum Energy State of Health: 80%

The applicable traction battery must retain the defined minimum proportion of its original energy capability.

UP TO 8 YEARS / 160,000 KM Minimum Energy State of Health: 72%

A further minimum performance threshold applies during the later defined durability period.

Light Commercial Vehicles — N1

UP TO 5 YEARS / 100,000 KM Minimum Energy State of Health: 75%

Applicable battery-electric and externally chargeable hybrid light commercial vehicles are subject to the defined initial durability threshold.

UP TO 8 YEARS / 160,000 KM Minimum Energy State of Health: 67%

The minimum required battery-energy performance continues into the later durability period.

EV range is therefore no longer only a sales specification. Battery degradation and the ability to demonstrate retained performance increasingly form part of the vehicle’s regulatory conformity case.
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06
STATE OF HEALTH

How Much of the Original Battery Is Still Available?

State of Health — SoH — is becoming one of the most important concepts connecting battery engineering, vehicle homologation, consumer information and lifecycle management.

In simple terms, it describes the condition of an ageing battery relative to an appropriate reference point such as its original usable energy capability.

Beginning of Life

Establish the battery’s initial reference performance and relevant parameters.

Vehicle Operation

Battery-management systems observe parameters associated with charging, discharge, temperature and battery use.

Degradation

Usable energy and other performance characteristics change as the battery ages.

State-of-Health Determination

The battery’s remaining performance is evaluated against the applicable reference and regulatory methodology.

SoH is becoming much more than a dashboard number.

Reliable battery-health information can influence regulatory compliance, warranty assessment, used-EV valuation, second-life suitability and eventually the battery’s digital lifecycle record.

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07
EU BATTERY REGULATION

From Product Compliance to Lifecycle Regulation

Regulation (EU) 2023/1542 fundamentally broadens the regulatory treatment of batteries placed on the European market.

For EV batteries, the framework progressively connects technical performance with environmental information, responsible material sourcing, carbon footprint, recycled content, labelling, conformity assessment, traceability and end-of-life management.

TRADITIONAL APPROACH Battery as a Technical Product

Compliance focuses heavily on product safety, electrical performance and suitability for the intended application.

EMERGING EU APPROACH Battery as a Lifecycle-Regulated Product

Compliance increasingly follows the battery from materials and manufacture through use, performance, second life and recycling.

This creates a second compliance layer for EV manufacturers. Vehicle homologation and battery-product regulation increasingly need to be managed together rather than as completely separate regulatory programmes.
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08
BATTERY CARBON FOOTPRINT

The Environmental Cost of Manufacturing the Battery Becomes Measurable

EVs eliminate tailpipe emissions during electric operation, but producing a traction battery requires energy and materials. The EU Battery Regulation therefore introduces a progressive carbon-footprint framework for electric-vehicle batteries.

The lifecycle calculation considers the battery’s environmental impact across defined stages rather than looking only at emissions from vehicle operation.

Raw Materials

Extraction, processing and preparation of battery materials contribute to lifecycle carbon performance.

Battery Manufacturing

Cell, module and battery production — including the energy used at the manufacturing plant — affects the declared footprint.

Distribution

Supply-chain and transportation stages contribute to the battery’s lifecycle assessment.

End of Life

Recycling and material-recovery processes form part of the broader lifecycle framework.

Two technically equivalent batteries may therefore have different regulatory environmental profiles.

Chemistry, material sourcing, manufacturing location, electricity mix and production efficiency can all influence lifecycle carbon performance.

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09
THE BATTERY PASSPORT

A Digital Identity That Travels with the Battery

One of the most significant innovations introduced by the EU Battery Regulation is the digital Battery Passport.

From 18 February 2027, each EV battery placed on the EU market is to have an electronic battery record meeting the applicable passport requirements.

The Battery Passport should not be understood simply as a QR code. The QR code provides an access mechanism. The real regulatory innovation is the structured digital information associated with the individual battery and maintained across relevant stages of its lifecycle.
Battery Identity

Information identifying the battery, its model and relevant economic operators.

Technical Characteristics

Relevant capacity, performance, composition and durability information.

Carbon Footprint

Applicable lifecycle environmental information can become part of the battery’s digital compliance record.

Material Information

Relevant composition and recycled-content information supports transparency and circularity.

State of Health

Battery-health information helps connect the original product with its changing condition during use.

Lifecycle Status

The passport can reflect whether the battery is original, re-used, repurposed, remanufactured or has become waste.

The physical battery and its digital identity become inseparable.

That connection creates new requirements for data quality, traceability, access rights and consistency between technical evidence and the information associated with the battery.

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10
TRACEABILITY & LIFECYCLE DATA

The Compliance Record Must Follow the Battery

Battery lifecycle regulation depends on the ability to maintain a reliable relationship between the physical battery and the information describing it.

FIRST LIFE Traction Battery

The battery operates as part of the electric vehicle and accumulates performance and condition information during use.

SECOND LIFE Repurposed Energy Storage

A battery no longer suitable for vehicle propulsion may still retain sufficient capability for another application, subject to applicable technical and regulatory requirements.

This makes accurate state-of-health information particularly important. Decisions about continued vehicle use, repair, resale, remanufacturing, repurposing or recycling increasingly depend on trustworthy information about battery condition.

Traceability gives the Battery Passport its practical value. Without reliable linkage between the physical battery, its technical history and its lifecycle data, a digital passport would provide information without dependable identity.
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11
MANUFACTURER READINESS

Battery Compliance Can No Longer Be Managed by One Department

The expanding regulatory scope means that battery compliance increasingly connects vehicle homologation teams with battery engineering, laboratories, sustainability specialists, suppliers, quality functions, IT systems and lifecycle-management processes.

01 — Regulatory Mapping

Identify the vehicle, REESS, battery-product, environmental and market-access requirements applicable to the battery.

02 — Safety Test Planning

Establish the required battery, REESS and vehicle-level safety verification programme.

03 — Durability Strategy

Develop evidence and monitoring capable of demonstrating battery performance retention over time.

04 — Lifecycle Data Architecture

Determine where required battery information originates, how it is verified and how it remains linked to the individual battery.

05 — Supply-Chain Evidence

Coordinate material, component, carbon-footprint and conformity information across battery suppliers and manufacturing sites.

06 — Battery Passport Readiness

Build the technical and data infrastructure needed to support passport information, access and lifecycle updates.

The challenge is integration. A battery may pass its safety tests yet still require durability evidence, environmental declarations, traceability data and lifecycle information before the complete compliance picture is established.
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12
THE FUTURE OF BATTERY ASSURANCE

From Component Approval to Lifecycle Conformity

EV battery regulation illustrates a wider transformation taking place across testing, inspection, certification and vehicle homologation.

The traditional model concentrates conformity evidence around the point at which a product enters the market. The emerging battery model extends assurance much further.

TRADITIONAL MODEL Design → Test → Approve

Demonstrate that the product satisfies applicable technical requirements before market entry.

LIFECYCLE MODEL Test → Approve → Monitor → Trace → Reuse → Recycle

Safety, performance, environmental information and battery identity increasingly remain relevant throughout the product lifecycle.

The Battery Passport makes this transformation visible. The future battery is not only a physical energy-storage system. It is increasingly a physical product accompanied by a persistent digital compliance identity.
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Beyond Battery Safety

The first generation of EV battery regulation concentrated heavily on one essential objective: ensuring that high-voltage batteries could be integrated safely into road vehicles.

That requirement remains fundamental, but it is no longer sufficient to describe the emerging compliance environment.

Battery durability, state of health, carbon footprint, material transparency, lifecycle traceability and digital product information are progressively extending assurance beyond the original homologation test.

The defining question is therefore changing.

If the battery must remain safe, retain performance, disclose its environmental characteristics and carry a digital identity throughout its lifecycle, where does battery homologation end — and where does lifecycle conformity begin?

The future EV battery will carry more than energy. It will carry evidence.
Regulatory context: EV battery requirements depend on vehicle category, battery type, target market and applicable regulatory framework. UN vehicle regulations, Global Technical Regulations, Euro 7 requirements and Regulation (EU) 2023/1542 contain different scopes, implementation schedules and conformity obligations. Delegated and implementing legislation continues to develop in several areas. Applicable requirements should therefore be confirmed for the specific battery, vehicle and market before commencing a homologation, testing or Battery Passport compliance programme.
GLOBAL ALLIANCE REGISTER

How Global Alliance Register Can Support You

Global Alliance Register supports manufacturers, suppliers and responsible economic operators with independent technical-assurance services relevant to electric-vehicle homologation within the automotive context. Based on the article's emphasis on performance and reliability verification and regulatory review, GAR can coordinate competent specialists, laboratories, inspectors, auditors and accredited conformity-assessment resources as appropriate to the actual technical need. Within the context of this article, Global Alliance Register can support you in the following areas:

01

Review commissioning readiness and coordinate functional, performance and acceptance verification relevant to electric-vehicle homologation, including defects, retesting and close-out evidence.

02

Verify performance, durability and reliability characteristics relevant to electric-vehicle homologation, review the resulting data and identify deviations, weaknesses or corrective actions affecting dependable operation.

03

Define and coordinate appropriate laboratory, factory or field testing for electric-vehicle homologation, including representative configurations, test methods, operating conditions and acceptance criteria.

04

Review the applicable regulatory, technical and scope requirements for electric-vehicle homologation and define the responsibilities, classifications and assurance pathway relevant to the product or equipment.

05

Determine the applicable conformity-assessment route for electric-vehicle homologation, coordinate the required technical evidence and support independent third-party or Notified Body involvement where the governing framework requires it.

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