The passport section is the strongest part of this and I still think you have the date wrong in a way that matters.
A registry going live means the plumbing exists. It does not mean anything is in it. The mandatory date for batteries is the one with teeth, and it is for electric-vehicle and industrial packs over 2 kWh: which is to say, not the things a consumer is holding in a shop. If you build ideas 9 and 10 for this year you will ship a scanner that finds an empty database and reads as broken, because users do not distinguish "no data yet" from "your app does not work".
The move is to build 11 first. Repair-or-replace is answerable today from parts prices and labour time with no passport at all, and the passport becomes an accuracy upgrade later instead of a launch dependency. Build the thing that works without the regulation, then let the regulation improve it.