China’s Regulation No. 73 and the EU Batteries Regulation look like opposite poles. One relies on a central state platform, the other on decentralised, cryptographically signed passports. One knows no public consumer tier, the other puts the QR code on every product. Anyone supplying both markets rightly asks: do I need two systems?
The answer is no. A single product data set can serve both, if the architecture is right.
Two regimes 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 artefact 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 legal jurisdiction, 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 an architectural property: the product data set itself is neutral towards the legal jurisdiction. The rule-specific work is a projection - reading the same data set and bringing it into the form a regime expects.
One freezing, two destinations. On publishing, the battery is committed once as a signed DPP version. The EU path registers it - as soon as the EU register is live - there and delivers the public view. The China path reads the same DPP version, extracts the recycling and lifecycle data and reports it to the MIIT platform. The DPP version does not change in the process, and the signature stays the same.
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, reporting will be done externally in future, as soon as the EU register is in place. A report to the MIIT platform is the same mechanism, only directed at a different destination.
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 the platform. Our archive serves both regimes without a second data store.
For access too there are already tiered views: public, on request, for authorities, purely internal. For China one axis is added - a recycler’s access is bound to both legal space 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
Three points belong said openly:
- 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: maintain one product data set and serve both the EU and the China obligations from it, instead of reconciling two systems in parallel.