From Mine to Battery: What EU Regulation 2023/1542 Means for Indonesian Nickel Exporters

What battery manufacturers are now asking their nickel suppliers

Across the nickel supply chain, a shift is underway. Battery cell manufacturers in Japan, South Korea, Germany, and China are sending data requests to their upstream suppliers that look nothing like the purchase orders and certificates of analysis they previously exchanged.

They are asking for carbon footprint per tonne of nickel by lifecycle stage. They are asking for the GPS coordinates of the mining concessions that produced specific shipments. They are asking for third-party audit documentation on human rights and environmental practices, referenced to specific OECD frameworks, that can be pulled programmatically into a data system.

This is the upstream consequence of EU Battery Regulation 2023/1542, which mandates Digital Battery Passports for EV batteries and industrial batteries above 2 kWh placed on the EU market from February 18, 2027. The battery manufacturer creates the passport. But the passport's supply chain fields (origin, carbon, due diligence) can only be populated with data that comes from the nickel producer.

This article describes the specific data points the regulation requires, what each means in practice for Indonesian nickel operations, and how KALIRA enables collection and sharing of this data.

The five data categories EU Battery Regulation requires from raw material suppliers

1. Geographic origin of raw materials

Regulation EU 2023/1542, Annex VI, Part A requires battery manufacturers to declare the geographic origin of cobalt, lithium, nickel, graphite, and copper used in each battery. "Geographic origin" means the country and, where applicable, the region or specific site of extraction.

For Indonesian nickel, this means:

• The IUP (Izin Usaha Pertambangan) reference number for the extraction concession
• The administrative location (kabupaten and provinsi) of the mining operation
• For more precise declarations: GPS coordinates of the concession boundary or centroid

This information exists in every mining company's permit documentation. The challenge is making it linkable to specific production batches so that a battery manufacturer can declare "the nickel in batch NL-2026-Q3-047 came from concession IUP-B-14782 in Kabupaten Morowali Utara, Sulawesi Tengah."

2. Carbon footprint of extraction and processing

Regulation Article 7 and Annex II require the total carbon footprint of each battery to be declared, broken down by lifecycle stage:

• Raw material extraction and processing (Stage 1)
• Battery component manufacturing (Stage 2)
• Battery assembly (Stage 3)
• Transport and distribution (Stage 4)

Indonesian nickel producers are responsible for Stage 1 data. The calculation covers:

Mining operations: Diesel consumption by mining equipment (excavators, haul trucks, bulldozers), explosives, and mine ventilation. Converted to kg CO2e using IPCC emission factors.

Ore processing: Electricity consumption is the dominant factor for RKEF (rotary kiln electric furnace) and HPAL (high-pressure acid leach) operations. The carbon intensity depends on the energy source: coal-fired captive power produces approximately 0.85 kg CO2e per kWh; grid electricity from PLN averages approximately 0.78 kg CO2e per kWh in Sulawesi; geothermal or gas-backed operations can be substantially lower.

Steam and heat: HPAL operations use significant steam. If the steam is generated from coal-fired boilers, this contributes substantially to the carbon footprint.

Transport to downstream: The carbon of shipping nickel sulfate or MHP from the processing facility to the cathode manufacturer is typically assigned to Stage 1.

The result is a carbon intensity figure in kg CO2e per tonne of nickel (or per tonne of nickel sulfate equivalent, depending on the processing output). This figure must be calculated per production facility. If a producer operates two processing plants with different energy sources, they require separate calculations.

A third-party verifier with experience in mining lifecycle assessment (SGS, Bureau Veritas, TÜV Rheinland, or similar) should validate the methodology and the figures. Self-declared figures without verification will not satisfy downstream battery manufacturers who face their own third-party verification requirements.

3. Due diligence documentation on human rights and environmental impact

Article 8 of the Battery Regulation requires battery manufacturers to implement and declare supply chain due diligence aligned with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

For Indonesian nickel producers, this means maintaining documentation of:

Risk assessment: An assessment of the human rights and environmental risks in their operations and supply chain, conducted against the OECD framework.

Mitigation measures: What actions the company has taken to address identified risks. This might include grievance mechanisms, community consultation programs, environmental impact management systems, and third-party social audits.

Third-party audit reports: Verification by an independent auditor that the self-declared risk assessment and mitigation measures are accurate. Organizations recognized for this work include SGS, Bureau Veritas, and Earthworm Foundation.

Conflict mineral self-declaration: A formal declaration that the mineral extraction does not finance armed groups or contribute to conflict, aligned with OECD Annex II definitions.

This documentation must be stored and shareable in a format that downstream partners can reference by a document ID or pull via an API, not emailed as PDF attachments on request.

4. Recycled content percentage

From 2030 onward, EU Battery Regulation Article 8(4) requires batteries placed on the EU market to contain minimum percentages of recycled content for cobalt (12%), lithium (4%), nickel (4%), and lead (85%). From 2035, those targets increase significantly.

For nickel producers who source any portion of their feedstock from secondary sources (e.g., recycled battery black mass, nickel scrap), the recycled content percentage must be declared and verified.

Primary nickel miners without recycled feedstock will declare 0% recycled content. This is accurate and permissible. But producers who develop the capability to process secondary nickel may have a competitive advantage as the 2030 targets approach.

5. Batch-level traceability linkage

The four data categories above must not be declared at the company level alone. They must be linkable to specific production batches. A battery manufacturer who purchases 200 tonnes of nickel sulfate on a given date needs to be able to state, in their battery passport, the origin and carbon footprint of that specific shipment.

This requires that production records (extraction site, processing route, energy consumption, batch number, output quantity) be maintained with enough granularity to reconstruct the chain for any given shipment.

In practice, this means assigning batch IDs at the point of production and maintaining records that link each batch ID to the concession of origin, the processing facility, and the calculated carbon intensity for that batch.

What the data must look like: format requirements

PDFs, email attachments, and Excel spreadsheets do not meet the interoperability requirements implied by EU Battery Regulation and the GS1 Digital Link infrastructure that underpins the DPP ecosystem.

Battery manufacturers building DPP platforms need supply chain data in structured, machine-readable formats. In practice, this means:

A supply chain data package identified by a reference number (aligned with GS1 standards where possible) that contains the five data categories above in structured fields, not narrative text.

API accessibility: Downstream customers should be able to retrieve supplier data by reference number via an authenticated API call. This eliminates the manual data re-entry that currently happens when PDFs are received and typed into DPP platforms.

Audit trail: Every data record should include the date it was created, who created it, and links to supporting documentation (audit reports, permits, energy bills). This audit trail is what enables downstream battery manufacturers to demonstrate the provenance of their declared data to regulators.

The practical steps for Indonesian nickel operations

Step 1: Register production assets digitally: Every major piece of processing equipment should be in a digital asset register with its energy consumption data, maintenance history, and operational parameters. This is the foundation for carbon intensity calculation.

Step 2: Establish batch numbering: Implement a batch numbering system that links output batches to the input ore batches from specific concessions. For operations that blend ore from multiple sources, this requires decisions about segregation or mass balance approaches.

Step 3: Commission a carbon footprint study: Engage a third-party verifier to conduct a lifecycle carbon assessment of your operations aligned with ISO 14067 methodology and EU Battery Regulation requirements. Allow 3–6 months. The output should be a verified carbon intensity figure per tonne of output by production facility and by energy scenario.

Step 4: Structure your due diligence documentation: Conduct or update your OECD-aligned due diligence assessment. Engage an independent auditor. Store the resulting documentation in a system where it can be referenced by document ID in your supply chain data packages.

Step 5: Build your supply chain data package: Create a structured data record for each production batch that captures origin coordinates, carbon intensity (by the verified figure from step 3), due diligence documentation reference, recycled content percentage, and batch-specific production data.

Step 6: Enable API access: Ensure that downstream customers can retrieve your supply chain data via an authenticated API call, not by email request.

Start building your EU-ready supply chain records with KALIRA

KALIRA provides the digital infrastructure for each step above: asset registration, batch-level production records, document storage and referencing, structured supply chain data packages, and API sharing for downstream partners.

The system is designed for Indonesian industrial operations, with IDR pricing (Rp 2.249.000/month for the Professional plan), mobile-first field use, and support for the specific data fields required by EU Battery Regulation 2023/1542.

Start building your EU-ready supply chain records with KALIRA. Free to start.