One data set, two regimes: a single DPP for the EU and China

A pack manufacturer ships the same battery to Stuttgart and to Shanghai. Europe wants a QR code on the casing that anyone can scan, with a signed passport behind it. China wants a filing within 40 days to a platform of the ministry that only licensed recyclers may read. The question in the company is: do we need two data systems now?

The answer is no. A single product data set can serve both, if the architecture is right. This article shows what the two sets of rules require, why they can still draw on the same data, and where the honest limits lie.

The two sets of rules look like opposite poles. One relies on a central state platform, the other on passports every manufacturer publishes and signs itself. One knows no public consumer tier, the other puts the QR code on every product.

Two sets of rules side by side

The EU Batteries Regulation 2023/1542 becomes mandatory from 18 February 2027 for batteries above 2 kWh. Its model: the economic operator publishes the passport, reachable via a GS1 Digital Link, and the trust sits in a signature on the passport itself. The addressees are the public, authorised third parties and authorities.

China’s Regulation No. 73 has applied since 1 April 2026 and governs the recycling of traction batteries for electric vehicles. Its model is the opposite: a central platform of the ministry (MIIT), identification following the Chinese standard GB/T 34014, a reporting obligation for every relevant event within 15 to 40 days, read access exclusively for licensed recyclers - and even that only to the disassembly data.

What Regulation No. 73 concretely requires

• a digital identity per battery, coded following GB/T 34014, on a tamper-evident label
• a manufacturer code assigned by the MIIT that allocates every battery to the factory
• reports on production, sale, repair, collection, recycling and reuse to the national platform
• read access for licensed recyclers, limited to the technical data needed for disassembly
• retention for the lifetime of the platform

Striking is the fourth rule: it binds access not only to the country, but to the purpose. A recycler sees only what it needs for disassembly.

Why this seems irreconcilable - and is not

Reading both regulations side by side, no common denominator seems to exist. The key lies in a property of the architecture: the product data set itself belongs to no jurisdiction.

The work per market is an output: reading the same data set and bringing it into the form a set of rules expects.

One set of facts, two destinations. On the EU side, the battery is committed once as a signed DPP version; the EU path prepares the register entry the economic operator makes itself, and delivers the public view. On the China side, the same recycling and lifecycle facts are what a Regulation No. 73 report draws on. That report is filed on the MIIT platform, in China and by the responsible actor there, not by our platform pushing data across the border. What is shared is the underlying data, not one system filing in both places.

The event log already speaks recycling

The lifecycle log of a Transpareo DPP already knows the events that China requires today: collection, recycling, remanufacture, reuse.

The China report therefore invents nothing new, it uses existing events.

The pattern is also not unfamiliar: for the EU, the economic operator enters the passport in an external register, operational since 20 July 2026 and with its interface still being specified. Feeding the MIIT platform is the same shape of mechanism, the same underlying data directed at a different destination, with the difference that on the China side that step is completed domestically rather than by us.

Retention and access are already in place

As soon as the DPPs are registered with the EU register, every DPP version is additionally archived immutably for ten years. The EU generally requires ten years of retention for registered passports from registration - for batteries it ends with recycling (Art. 77(8)). China requires the lifetime of its platform, and that retention lives on the Chinese side. What our archive removes is the need for a second EU data store; it does not hold, and does not need to hold, China’s domestically governed records.

For access too there are already tiered views: public, on request, for authorities, purely internal. For China one condition is added: a recycler’s access is bound to both country and purpose at once. That is a small, targeted extension of the existing access logic, not a second system.

One identifier that finds both routes

The GS1 Digital Link remains the anchor: it is on every internationally traded battery pack anyway. The MIIT identifier following GB/T 34014 travels along as an additional field on the same data set - a supplement, not a replacement.

Honest limits

A few points belong said openly:

• The authoritative Chinese records and their retention stay in China and under Chinese administration. A foreign platform does not hold them; what can cross the border is a small, purpose-bound and checkable extract. And the source-side work, linking data to the product, scoping the evidence, attributing responsibility and keeping it current, still has to happen at source before anything can be relied on elsewhere.
• The MIIT platform does not yet have a public interface specification. The integration can only be completed once a customer or integrator opens the access. The data model and the access rules can be in place beforehand.
• Regulation No. 73 is a recycling regulation for EV traction batteries, not a general product passport for every product group.
• In China there is no public consumer interface. The offer there is the rule-compliant data structure and retention, not the brand-pretty scan.

For a manufacturer supplying both markets today, however, exactly that counts: form and govern the underlying product facts once, and derive from them both the EU passport we host and the data your Chinese obligations draw on, instead of gathering and curating the same facts twice. The sets of rules stay separate, and China’s stays governed in China; the facts underneath them need not be collected twice over.