As demand for electric vehicles accelerates, the minerals inside their batteries — lithium, nickel, cobalt and copper — now carry more scrutiny than ever. Yet following these materials from extraction through processing, manufacturing and recycling remains one of the clean-energy sector’s most persistent challenges.
A new United Nations white paper led by Associate Professor Jeanne Huang from the University of Sydney attempts to clarify what a more transparent system could look like. Rather than focusing on technology alone, the report outlines the legal groundwork needed to support digital traceability across global battery supply chains.
Produced with Fudan University and published by the UN Economic Commission for Europe, the work centres on digital product passports (DPPs) — secure digital records that track a mineral or battery through its entire lifecycle. In theory, these passports could offer consistent, verifiable information on provenance, processing, ESG compliance and recycling, giving governments and buyers a clearer line of sight into how responsibly materials have been sourced.
A shifting regulatory landscape
The timing is notable. Clean-energy supply chains have become geopolitically sensitive, and the regulatory environment is tightening. Europe is preparing new battery rules that will require detailed lifecycle data from 2027, while the US continues expanding mineral-origin and human-rights requirements under the Inflation Reduction Act. China is strengthening its domestic battery-tracking and recycling systems. And the US and Australia recently announced a US$3 billion joint investment to support critical minerals supply.
Despite this momentum, the white paper argues that the current system remains fragmented. The EU, the US and China all use different traceability frameworks with different priorities — sustainability disclosure, geopolitical security and lifecycle management, respectively. As a result, the same material can be subject to incompatible reporting rules depending on its destination.
For companies operating across multiple jurisdictions, this creates complexity and cost. It also opens the door to forum shopping, where materials move through regions with less-strict reporting requirements, undermining the intent of traceability measures.
What the paper contributes
The Sydney–Fudan research is primarily a legal analysis, identifying several challenges that would need to be addressed for DPPs to function across borders. These include:
- Varying definitions of critical minerals, even among major economies.
- Competing claims over data jurisdiction, particularly when supply-chain information is stored or processed outside the importing country.
- Different privacy, security and trade-secret rules, which influence what data companies are allowed to share.
- Lack of interoperability between national and industry traceability systems.
- And the risk that smaller producers and Global South economies face barriers if compliance systems become overly burdensome.
To underscore the stakes, Huang warned that “without mutual recognition of regulatory outcomes, overlapping due diligence laws and fragmented reporting regimes will drive businesses to seek loopholes rather than uphold genuine ethical standards”.
“Governments would also struggle to enforce modern-slavery and environmental laws effectively,” she added. “Transparent digital traceability is essential to a fair, low-carbon and cost-effective energy transition.”
Rather than building entirely new systems, the report argues that policymakers should draw on existing international frameworks — including WTO rules, UN/CEFACT standards, digital-trade agreements and mutual-recognition pathways — to avoid duplication and reduce friction. The authors also highlight the importance of designing safeguards so transparency requirements do not unintentionally exclude emerging-market producers or smaller mining companies.
What this might mean for industry
For the battery and minerals sectors, the direction is clear: downstream manufacturers will increasingly expect verified data from their suppliers. As DPP-style requirements emerge in major markets, miners, processors and recyclers may need to invest in more robust data-collection and reporting systems to maintain access to global supply contracts.
In the longer term, functioning DPPs could help differentiate responsibly sourced materials, improve the consistency of ESG claims and streamline due-diligence processes. Recyclers may also gain an advantage if recovered materials can re-enter supply chains with well-documented provenance, supporting circular-economy objectives and reducing reliance on new extraction.
At the same time, the paper cautions that poorly aligned regulations could add cost or slow adoption. If Europe, the US and China develop parallel systems without interoperability, the burden will fall on companies to reconcile those differences. Ensuring clarity, legal consistency and data protection will be essential to keeping compliance manageable.
A gradual but important shift
The UNECE expects the work to progress towards a formal policy recommendation by 2027 — a relatively long runway, but one that aligns with typical development timelines for new mines, refineries and battery facilities. For investors, it reinforces a broader trend: transparency is becoming a structural feature of the clean-energy transition, not an optional one.
The minerals powering the world’s electrification push will increasingly need verifiable data as part of their value proposition. The new UN white paper does not resolve every challenge, but it helps outline the legal architecture needed for a more accountable supply chain — one where accuracy, consistency and traceability become standard expectations rather than aspirations.