Closing the Cell-Level Gap: Why the EU Battery Passport Needs to Reach Disassembled Modules and Cells – REBELION Policy Brief

Policy brief of the REBELION project (Horizon Europe, GA 101104241). The EU Battery Regulation and its Digital Battery Passport track batteries at pack level, but traceability is lost once packs are disassembled into modules and cells for second-life use or recycling. Building on REBELION's work on Electrochemical Noise Analysis and its Digital Battery Passport for second-life batteries, the brief recommends three actions to close this cell-level gap: extend passport granularity to disassembled modules and cells; mandate minimum data capture at the disassembly point; and extend financing traceability so that Producer Responsibility Organisations can track module-level removal and substitution.