Battery passport data: what pack makers will be asked for

The EU Battery Regulation applies the passport to electric vehicle batteries, industrial batteries above a stated capacity and light means of transport batteries. A stationary storage pack of that size falls inside. A small consumer cell does not.

Check your own product list against the regulation text, not a customer’s email. Models sold under a buyer’s brand still need the data, and you are often the only one who holds it. Ask which of your models each buyer resells. Add every variant to a single list with capacity, chemistry and intended use, because the passport duty follows the product and not the order.

Every pack needs a unique identifier that survives for years. The passport links that identifier to the manufacturer, the plant, the date of manufacture and the model. A label printed at end of line is the usual carrier.

One serial, one record. If serials live in a spreadsheet beside the packing list, a reprint or a rework can break the link. Cell lot numbers and module serials must hang under the pack serial. Do it at the end-of-line station, where a scanner reads the printed code and writes the pack record in one step. Print once, never reissue.

The regulation asks for chemistry, the share of recycled cobalt, lead, lithium and nickel in active materials, and hazardous substance content. Your cell supplier supplies most of it, but only if you ask for it per cell lot and keep the reply.

A carbon footprint declaration sits on top. It needs the energy used at your own plant and the declared footprint of each bought-in cell. Collect supplier declarations on receipt, not when a buyer asks.

Missing paperwork is the usual gap. A cell lot arrives, goes into a module, and the declaration never reaches the file. Ask each cell supplier for a declaration format now. A PDF attached to one email thread is not a record you can export later.

Expect rated capacity, voltage limits, expected cycle life, power limits and state of health data. Some of it comes from type testing. Some comes from end-of-line tests on each pack, such as capacity check, insulation resistance and BMS firmware version.

Store the test result against the pack serial at the moment of the test. A tester that writes only to a CSV on the line PC loses the trail when the PC is replaced.

Warranty claims draw on the same records. Field returns point to the failed cell lot, but only when the link between pack serial and cell lot exists. Without it you replace packs blindly.

Build one record per pack: serial, model, bill of materials revision, cell lots, module serials, test results, firmware and dispatch date. Each production step adds to it. At the end, the passport export is a view of that record, not a fresh data hunt.

Start with ten recent packs. Trace each one back to its cell lot and supplier paper by hand. Whatever you cannot find shows which fields your process fails to capture. Count how many fields needed a phone call to a supplier. That count is your real workload once buyers start asking for passports on every shipment.