EU consultation
12 submissions from 12 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission received 14 submissions on this file. Shown here: the 12 from organizations. Not shown: 2 from private individuals. Their submissions are personal data; the Commission publishes them under its own legal basis, and republishing them by name here would need one we do not have. Organizations act in a public capacity, so their positions are public record. About this data →
11 submissions from industry (companies and their trade associations) against 1 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 11 industry submissions for every one from civil society.
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations: a body that filed twice is counted twice.
The file, right now
The consultation is open: 20 days left to submit. It closes on 16 Nov 2026.
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How it got here
Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned, Implementing regulation.
Showing 12 of 12 submissions.
· · filed 26 Oct 2026 · source
Vetta Advisory is an independent consultancy on digital product passports and EU product regulation, based in France. We do not provide passport software and have no commercial ties with passport providers. We support the draft and its purpose-based approach. Our comments are requests for clarification on how it will work in practice for the economic operator that has to apply it. 1. Proving entitlement.
Umicore welcomes the Commissions draft implementing rules on access rights to certain parts of the battery passport and supports the recognition of recyclers and waste management operators carrying out treatment as actors with a legitimate interest in accessing relevant battery passport information.
Marklytics (UK) (www.marklytics.co.uk) develops VoltTrail, an EV battery passport and lifecycle traceability platform, and ESG/compliance analytics for automotive suppliers, many of whom place batteries on the EU market from outside the Union. 1. Proving entitlement. Article 1 names categories but not how a person proves it belongs to one.
DPPera (Poland) is a small Digital Product Passport service provider for SMEs. Our editor has a battery profile and serves passports with separate restricted layers. We support the draft and its purpose-based approach. Six points, from the perspective of a system that has to implement it for 18 February 2027. 1. Verification of roles.
· · filed 22 Oct 2026 · source
TerraNEXT GmbH operates Centralize by TerraNEXT, a platform supporting understanding and practical implementation of Digital Product Passport requirements. Our work connects regulation with standards, data structures and operational responsibilities.
· · filed 22 Oct 2026 · source
Circunomics GmbH operates a B2B marketplace and analytics platform for battery lifecycle management. We welcome this draft. Naming repurposers and vocational training centres explicitly, and placing safety information outside the restricted regime (Article 2(5)), are both practical improvements. Our comments concern the secondary market the Regulation is intended to enable. 1.
· · filed 22 Oct 2026 · source
Transpareo operates a digital product passport platform for battery passports. We welcome the draft and would like to help make Article 1(4) workable in practice. The draft gives the information in point 4 of Annex XIII to "the purchaser of the battery" and to third parties acting on its behalf, but leaves open how either proves its status. Two facts make this pressing. Batteries are resold, often several times.
Ref: Draft Implementing Regulation on Battery Passport Access Rights (Ares(2026)9814179) As an economic operator and a key stakeholder in the lithium battery supply chain, we welcome the opportunity to submit our feedback on the draft Implementing Act regarding access rights to the battery passport.
· · filed 21 Oct 2026 · source
As Dr. Ou from GAC International, an economic operator placing batteries and battery-equipped vehicles on the EU market, we welcome the draft Implementing Act on Battery Passport Data Access and would like to submit the following focused comments, presented as rationale and corresponding suggestions.
Submitted by Steven Capell, Project Lead of the UN Transparency Protocol (UNTP) and Vice Chair of UN/CEFACT. This is the technical position of the UNTP project, not a formal UN/CEFACT position. A fuller response is attached. The draft takes the right approach.
· · filed 20 Oct 2026 · source
Traceable Digital (https://traceable.digital/) operates a battery passport platform and has implemented the public, legitimate-interest and authority access levels of Article 77(2). We welcome this draft and offer seven comments. 1. Verification. Article 1 names whole categories (repairer, recycler, repurposer, training centre) as persons with a legitimate interest but not how a claim is checked.
**A common framework for cross-border digital identity and authorisation is essential** The proposed access rules need a practical, interoperable way to verify identities, professional roles and access entitlements across the EU. Without such a framework, implementation risks becoming fragmented between Member States and individual service providers.
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed”. You read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.