Power Battery Passport and Carbon Footprint Compliance SaaS (Pay-per-Vehicle Model)

📌 Background

The EU New Battery Regulation entered into force in August 2023. Power batteries require carbon footprint reports starting February 2025, carbon footprint performance class labels starting August 2026, and mandatory implementation of battery passports starting February 2027. EU customs have already begun mandatory random inspections of passport data for imported batteries. Large-scale exports of Chinese electric vehicles and batteries to Europe have created a compliance gap, spawning a market for third-party digital service providers.

👤 Target Customers

Exporting enterprises facing the EU market, including automakers, power battery manufacturers, and upstream small and medium-sized suppliers, paying an annual fee based on vehicle VIN codes or battery serial numbers.

💰 Revenue Streams

1) Core revenue consists of annual fees for battery passport generation and compliance certification billed per VIN code; 2) Additional carbon footprint accounting software subscription fees, implementation service fees for integration with the EU DPP registry, and lightweight SaaS subscriptions tailored for small and medium-sized suppliers; 3) Ongoing compliance: annual maintenance and updates of battery passport data, with subscription fees charged annually for integration operations and maintenance with the EU DPP registry.

🧮 Cost Structure

Primary costs include the compliance expert team for regulatory interpretation and LCA modeling, platform R&D and data security investments, cross-border data compliance and integration costs with official EU registries, and labor costs for customer supply chain data verification.

🛡️ Moat

Regulatory expertise barriers and first-mover qualifications in completing system-level integration with the official EU DPP registry. Accumulated industry electricity mix factors and supply chain carbon databases form data moats, while leading automakers driving upstream suppliers onto the network create network effects.

🔑 Keys to Success

• Take the lead in completing system-level integration with the official EU DPP registry
• Establish reliable supply chain carbon data collection and green electricity certificate verification capabilities
• Bind leading automaker anchors and penetrate upstream suppliers

⚠️ Risks

• Collateral reputational risk caused by exported batteries being rejected by EU customs due to irregular passport data
• Delays in regulatory timelines or rule changes leading to postponed customer purchases
• Regulatory penalties arising from cross-border data compliance issues

🏢 Cases

• Sunwoda's battery passport platform completed system-level integration testing with the official EU DPP registry environment in June 2026, entering commercial operation
• Geely-led EVSA developed a lightweight SaaS allowing small and medium-sized suppliers to input electricity and gas usage data via mobile phones for automated carbon emission calculations
• Batteries exported from China to the Port of Rotterdam have already been inspected and penalized by EU customs due to irregular passport data submissions

📊 SWOT Analysis