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PM Case Study

OCX Labs

EU Battery Regulation Compliance Platform

Year
2026
Type
PM Case Study
Domain
B2B SaaS · Compliance · Automotive
Status
Prototype Live
Interactive Prototype available
Explore the working prototype — Battery Maker, Supplier, and OEM views.
View Prototype ↗

₹2–5 Cr a year. 2–3 weeks per batch. And a Feb 2027 deadline that won't move.

Battery manufacturers in India must comply with EU Battery Regulation Articles 62–69 (mineral sourcing — live since January 2025) and Articles 77–83 (Digital Battery Passport — deadline February 2027). The current process is entirely manual: 2–3 weeks per compliance batch, ₹2–5 Crore annually in compliance costs, and a ₹50+ Lakh export blockage risk for every non-compliant shipment.

Why now

Enforcement is active — not theoretical. The Feb 2027 Digital Battery Passport deadline creates a hard, visible catalyst. There is currently no existing automation in the Indian market. Battery manufacturers have an acute, unmet need with a clock running.

48 hours. Automated. Built for Tier 1 suppliers first.

An automated compliance platform that reduces the 2–3 week manual process to 48 hours. Built as a Tier 1 supplier solution with a clear expansion path to OEMs and vehicle-level compliance.

Phase 1
EU Battery Regulation — Mineral Sourcing
Articles 62–69. Mineral declaration with certificate/evidence upload (any format), supply chain declaration, compliance attestation and QR code generation. Already active enforcement — the immediate commercial opportunity.
Phase 2
Digital Battery Passport
Articles 77–83. Full DPP compliance ahead of the February 2027 deadline. Geolocation mapping for mine sourcing, auto-validation against conflict lists, OFAC, and EU databases, plus risk assessment dashboard.
Phase 3+
Vehicle Compliance for OEMs
Component-level compliance tracking for OEMs against their full supply chains. Extends the platform from battery makers to Hyundai, Tata Motors, Ashok Leyland and their hundreds of Tier 1 and Tier 2 suppliers.

Tier 1 battery makers first. OEMs in Phase 2.

Tier 1
LG Energy Solution India, Tata Green Batteries, Reliance New Energy — primary targets carrying the compliance burden
OEM
Hyundai India, Tata Motors, Ashok Leyland — Phase 2 expansion once Tier 1 network is established
48h
Target compliance turnaround, down from 2–3 weeks manually

Two enterprise insights that sharpened the model

Primary research — Ashok Leyland

World-class traceability. Zero compliance proof.

During calls with deputy managers at Ashok Leyland, I discovered they run a sophisticated QR/RFID tagging hierarchy: VIN → Parts → Suppliers, fully integrated across SAP, Cloud, and PLM systems. Real-time telemetry feeds back to the vehicle VIN for batch-level troubleshooting.

The gap: they can trace any part to any supplier, but cannot prove that supplier meets EU compliance requirements — mineral sourcing, UFLPA, PFAS, forced labour. OEMs have world-class infrastructure but no compliance connector. This validates both the Tier 1 pain and the Phase 2 OEM opportunity simultaneously.

Additional insight: QR tagging process is not always strictly followed — batches occasionally ship without tagging. A data maturity problem that our platform needs to accommodate.
Competitive intelligence — Volvo / TrusTrace

Why the T1-relay model breaks — and why ours doesn't.

Volvo evaluated TrusTrace's Supply Chain Mapping product for automotive compliance. It failed because it depended on one Tier 1 supplier to source compliance data across 300+ components — too much volume for any single T1 to chase and relay.

Our model inverts this: suppliers onboard directly (or via minimal-auth email flow) and see only their own slice of data. The platform consolidates centrally, avoiding the single point of failure. Clear compliance visibility then passes to OEMs without requiring the T1 to be the bottleneck.

Key differentiation: shared responsibility architecture, not T1-relay. Each supplier owns their own data.
Market signal — European Commission

€458M in fines. Enforcement is real.

The European Commission fined 15 major automakers and the ACEA a total of €458 million for colluding on end-of-life vehicle recycling — a compliance category considered far less acute than battery mineral sourcing. The enforcement risk for non-compliance with the Battery Regulation is credible and significant.

Zero competitors automating compliance for the Indian automotive ecosystem.

Company Technology Position Our Edge
Circulor Blockchain + AI $45M+, UK-based, OEM-focused First-mover in India
Circularise Blockchain + zero-knowledge proofs Enterprise, Honda partnership Tier 1 targeting: competitors chase OEMs, we target the burden-holder
Sourcemap Cloud mapping + verification US-based, mineral-heavy Network effects: first Tier 1 customer locks in others
TrusTrace Supply Chain Mapping T1-supplier intensive Shared responsibility: lightweight, passes ownership to individual tiers
OCX Labs Automated compliance + DPP India-first, Tier 1 entry Only automated platform for Indian automotive compliance ecosystem

What has to be true. What could break it.

Key assumptions
  • Tier 1 suppliers have acute, near-term compliance pain
  • EU enforcement continues and is not reversed
  • Feb 2027 Battery Passport deadline holds
  • Modular architecture enables Phase 3 add-ons without re-architecture
Key risks
  • Circulor or Circularise pivot to India market
  • Tier 1 prefers to build in-house over SaaS
  • Mineral sourcing data treated as competitive intelligence — sharing reluctance
  • UFLPA / PFAS enforcement ramps faster than expected, outpacing MVP scope

Customer discovery before any sales motion.

Initial GTM is discovery-led. Target customer calls are scoped to validate two hypotheses:

With LG Energy / Tata Green / Reliance New Energy: "How long does mineral sourcing compliance take today? What does it cost?" — validating the pain and willingness to pay for automation.

With Ashok Leyland: "How do you currently verify battery supplier compliance?" — validating the Phase 2 OEM expansion opportunity and testing the compliance connector concept.

Next steps: user interviews with Tier 1 suppliers to understand data maturity depth, competitor solution and packaging research, and confirming OCX Labs' existing relationships with LG Energy, Tata Green, Reliance, Hyundai, or Tata Motors that can accelerate access.

PM Case Study B2B SaaS Compliance Supply Chain Automotive EU Regulation Fintech India 0→1 Prototype