You can build battery-passport infrastructure in-house. The question is whether you should. The regulation’s details — per-item identifiers, field-level access tiers, durable hosting, lifecycle state changes — are easy to underestimate.
| Concern | DIY | Self-serve SaaS |
|---|---|---|
| Unique identifiers | You implement ISO/IEC 15459 + GS1 | Built in |
| Access tiers | You enforce Annex XIII server-side | Built in |
| 10-year hosting | Your responsibility | Provided |
| Time to first passport | Engineering project | Minutes |
DIY can make sense at very large scale with deep ERP integration. For most manufacturers and importers, a self-serve generator is faster and lower-risk.