The archive · Climate & Energy · Strategic decision · 2017–2026
Circulor bets EU battery-passport law makes traceability a must-buy; Volvo EX90 first
UK startup Circulor bet EU battery-passport law would force automakers to prove provenance; the Volvo EX90 carried the world's first passport in 2024.
Circulor
What the business is
Supply-chain traceability SaaS that gives each batch of raw material a digital identity, letting automakers and miners prove origin, recycled content and carbon footprint.
Starting capital：About $44.2M raised by June 2022, including a $25M Series B led by The Westly Group, with Volvo Cars Technology Fund, BHP Ventures, Salesforce Ventures and JLR's InMotion Ventures participating.
How it started
Founded around 2017 by Douglas Johnson-Poensgen, Circulor started with battery metals such as cobalt, nickel and mica, then spent about five years with Volvo Cars working out how to trace a material from a specific mine into a specific car, a task Johnson-Poensgen said car manufacturing had never done.
What happened
After a 2021 Series A, Circulor raised a $25M Series B in June 2022 led by The Westly Group, and Germany's Battery Pass project named it a central partner for designing the passport's technical inputs and data space. On 2024-06-04 Volvo announced the world's first EV battery passport on the EX90, readable through a QR code inside the driver's door, and said it would be rolled out across Volvo's electric range.
No ending yet — it is still running.
Background
Circulor is a London-based supply-chain traceability startup founded around 2017 by Douglas Johnson-Poensgen. Its bet was that the EU Battery Regulation (Regulation (EU) 2023/1542, in force since 2023-08-17) would make provable battery provenance a legal requirement for selling cars in Europe, converting voluntary ESG data into software automakers must buy.
Its wedge was material-level digital identity: the platform piggybacks on suppliers' production systems, tracks each batch of material from mine to battery, and checks supplier energy bills to compute carbon footprint. Volvo Cars became the anchor customer and investor; Jaguar Land Rover, BHP, SYSTEMIQ and Salesforce Ventures also invested as Circulor raised about $44.2M by June 2022 and joined Germany's Battery Pass project as a central technical partner.
On 2024-06-04 Volvo unveiled the world's first EV battery passport on the EX90, built with Circulor over five years and readable via a QR code in the driver's door. Reuters and Electrek covered the launch as a landmark arriving nearly three years before passports become mandatory in the EU, and Volvo said the passport would extend to all its EVs.
What has to be true
- The EU Battery Regulation set a fixed date (2027-02-18) after which every EV battery sold in Europe must carry a digital passport, moving traceability from CSR to procurement.
- Circulor bound itself to a flagship automaker early: five years with Volvo produced the first production passport, a reference rivals had to match.
- The regulation made material origin, recycled content and carbon footprint contractually provable data, exactly what Circulor's platform stored.
- Participation in Germany's Battery Pass project let Circulor help shape technical standards while selling to the companies that would need them.
What can be applied
When a regulation turns optional data into a market-entry ticket, the supplier that builds the product with a flagship customer before the deadline captures the compliance window.
Aftermath
As of 2026-08-18: from 2027-02-18 every EV and industrial battery above 2 kWh placed on the EU market must carry a digital passport. The Commission missed its deadline for the implementing act on who may access passport data (adoption expected around Q4 2026); Taylor Wessing advises firms to build the access layer now, since the passport obligation is unaffected — the EU already postponed the Article 48 due-diligence duties by amendment. Volvo planned to extend the passport across its electric range, and the cited sources report no acquisition or wind-down.
Sources
- Volvo to issue world's first EV battery passport ahead of EU rules
- Volvo's new EX90 electric SUV will launch with the 'world's first' EV battery passport
- Circulor raises $25m for blockchain material supply chain monitoring
- Battery passport: access rules not adopted by 18 August 2026
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