Getting data from suppliers

Most of the information in the battery passport is known only to the manufacturer of the cells or the pack, often based in Asia. Yet the economic operator placing the battery on the EU market is responsible for an accurate, complete and up-to-date passport (Art. 77(4)). So you have to obtain, check and maintain the data.

What you need

• Master data: manufacturer with address, model identifier, battery category, plant, date of manufacture, weight, capacity in Ah and kWh.
• Composition: chemistry, hazardous substances, critical raw materials above 0.1 %, usable extinguishing agent, materials of cathode, anode and electrolyte.
• Performance and durability: nominal, minimum and maximum voltage, power, expected lifetime in cycles with reference test and C-rate, efficiency, internal resistance of cell and pack, temperature ranges.
• Circularity: part numbers, sources for spare parts, dismantling instructions, safety information.
• Documents: EU declaration of conformity and the test reports supporting it.
• Per battery: serial number and, if different, the date of manufacture.

According to the Commission's guidance (version 2.0), the carbon footprint, recycled content and the due diligence report do not have to be filled in on 18 Feb 2027. Ask for them anyway, so the supplier can prepare.

How to ask

1. State the model, battery category and legal basis: Regulation (EU) 2023/1542, Annex XIII.
2. Send a structured field list rather than asking for a data sheet, with units (V, Ah, kWh, W, mΩ, °C) and the mandatory fields marked.
3. Request the declaration of conformity, test reports and dismantling instructions as documents.
4. Set a deadline well ahead of the first delivery to be placed on the market from 18 Feb 2027.
5. Ask for a named technical contact, not only for sales.

With Batterypass Online, from the Business plan, you send a link. The supplier enters the values without a login, in one of 28 languages, including Chinese. You review the answers and take them over into the passport.

What belongs in the contract

• The list of fields and documents the supplier delivers, and by when.
• Serial numbers with every delivery, ideally as a CSV file.
• The obligation to announce changes to cells, chemistry, plant or performance values in advance. A battery model only covers units with the same technical characteristics and the same model identifier (Art. 3(1), point 19).
• An assurance that the information is accurate, and a rule for the case that it is not.
• The right to publish the data in the passport and to make the test reports available to authorities.
• Access to the battery management system data under Art. 14.

If you are a manufacturer yourself and buy in cells or modules, their suppliers must provide you with the necessary information and documentation free of charge (Art. 39).

Checking plausibility

• Cross-check energy: nominal voltage times capacity in Ah gives watt-hours. If the stated kWh figure differs clearly, ask.
• Compare the model identifier in the declaration of conformity, test report, data sheet and label.
• Only accept cycle life together with the test conditions, i.e. C-rate, temperature and end-of-life criterion.
• Plant and place of manufacture must be a real production site, not a trading address.
• An empty list of critical raw materials is hardly plausible for lithium-ion batteries.
• You have had to state the performance values in the documentation since 18 Aug 2024 (Art. 10). They should match the new information.

If no answer comes

• Follow up, with a clear deadline and the note that without a passport the goods may no longer be placed on the market from 18 Feb 2027 (Art. 77(1)).
• Escalate through purchasing. The data delivery is part of the goods.
• Have missing performance values measured yourself, for example by a test lab.
• As a last resort, change supplier or take the model out of your EU range.

The responsibility stays with you

Even if the supplier enters the values, you are liable for the content. In Germany, failing to ensure that the information in the battery passport is accurate, complete and up to date is an administrative offence (Section 60(2) no. 29 BattDG). Keep the answers in a traceable way. In Batterypass Online, every published version gets a SHA-256 checksum chained to the previous version.