EU Battery Regulation

Regulation: (EU) 2023/1542 on batteries and waste batteries

Status: Reference case — this regulation was the source from which the framework was extracted.

Full implementation: eu-digital-product-passport Smart contract: Battery Smart Contract — UTxO diagrams, guard table, lifecycle state machines, hardware signing flow.

Constraint check

Constraint	Assessment	Notes
Data cadence	Pass	SoH readings monthly at most. Lifecycle events are rare.
Sequential access	Pass	One manufacturer per trie. Relay on repurposing.
Liveness	Pass	Penalties are set by Member States under Art. 93. The regulation also supports market restrictions and withdrawal for non-compliance. Slot-based timeouts can still be enforced at protocol level.
Fee alignment	Pass	Manufacturers pay ~$0.10-0.15 per reading. Compliance value far exceeds cost.
Identity delegation	Pass	NFC secure element (SE050) signs readings. Consumer taps phone, no wallet needed.

Element	Battery Regulation
Regulator	European Commission
Obligated parties	Manufacturers, importers, distributors
Reporting obligations	SoH, recycled content %, carbon footprint, composition
Verification bodies	Market surveillance authorities, notified bodies
Beneficiaries	Consumers, second-life market, recyclers
Penalties	Member State penalties under Art. 93, plus market restriction or withdrawal measures elsewhere in the regulation
Timeline	2027 EV batteries, 2028 industrial, phased

Data	Type	Access tier
Product identity, chemistry, manufacturing date	Static	Public
Carbon footprint per kWh, performance class	Static	Public
Recycled content percentages	Static	Public
State of Health (SoH)	Dynamic	Restricted to the lawful purchaser, parties acting on their behalf, and other actors expressly entitled by the regulation
Cycle count, capacity fade	Dynamic	Restricted with the SoH access tier, not generally public
Detailed composition	Static	Authorized operators
Disassembly instructions	Static	Authorized operators
Full SoH history	Dynamic	Authorities
Supply chain audit trail	Event-driven	Authorities

Two-transaction protocol for authenticated readings:

Virgin → Active → Repurposed → Recycled
                ↘ Recycled

Cross-operator handoff on repurposing: new leaf in new operator's trie with back-link to original.

Invariant	Lean theorem	Status
Single-use commitment	`commitment_cleared_after_submit`	Proved
Reward monotonicity	`credit_increases`	Proved
MPT consistency	`transition_preserves_consistency`	Proved

Party A	Party B	Trust	Risk	Mitigation
Manufacturer	Consumer	Low	SoH manipulation	Immutable on-chain history
Manufacturer	Regulator	Medium	Selective reporting	Completeness proofs via MPT
Consumer	Consumer	None	Counterfeit resale	On-chain provenance
Sensor	Chain	Hardware	Analog tampering	Expensive, destructive