EU battery passport Evidence workflow

Start with a battery-level scope record. Article 77 applies the passport duty to LMT batteries, industrial batteries with capacity greater than 2 kWh, and electric vehicle batteries that are placed on the market or put into service.

The evidence owner should be the economic operator placing the battery on the market, because Article 77 makes that operator responsible for keeping passport information accurate, complete, and up to date. If another operator maintains the passport data, keep the written authorisation and the service boundary in the evidence file.

Do not treat the passport as one undifferentiated dataset. Annex XIII and Article 77 separate public model information, restricted point 2 model information accessible to notified bodies, market surveillance authorities, the Commission and persons with a legitimate interest, point 3 test-report information reserved for notified bodies, market surveillance authorities and the Commission, and individual-battery information for legitimate-interest users. Article 77(9) requires an implementing act to specify legitimate-interest persons, their fields, and their download, sharing, publication, and re-use rights, so keep those permissions configurable until the applicable act is in force.

For each field, record the source system, data steward, evidence artifact, access class, update trigger, and validation rule. This prevents public-facing passport data from exposing restricted dismantling, test-report, or individual-battery data.

Article 77 requires passport access through the Article 13 QR code, linked to a unique identifier attributed by the economic operator placing the battery on the market. Annex VI adds the practical QR-code evidence requirement: high contrast, readable size, and readability by commonly available QR readers.

Provenance evidence should show how each passport field moves from source system to published record. Article 77 and Article 78 require open standards, interoperability, machine-readable structured searchable data, authentication, reliability, integrity, security, privacy, and fraud avoidance.

The passport evidence workflow should connect published passport claims to the conformity file. Annex XIII includes the EU declaration of conformity in the public passport dataset and reserves test-report results proving compliance for notified bodies, market surveillance authorities and the Commission.

Keep the conformity evidence specific to the battery model or individual battery being passported. Annex VIII requires technical documentation that allows assessment of conformity and includes risk analysis, and it requires the EU declaration of conformity to identify the relevant battery model or battery.

First publication does not finish the passport work. Article 77 requires accurate, complete and up-to-date information, and Annex XIII requires individual-battery values at market placement and when status changes.

When a battery is prepared for re-use, prepared for repurposing, repurposed, or remanufactured, Article 77 transfers responsibility to the economic operator that places that battery on the market or puts it into service. The new passport must be linked to the original passport or passports. Annex XIII separately uses 're-used' as one possible individual-battery status; that status label does not expand the transfer trigger in Article 77(7). When the battery becomes waste, responsibility transfers to the producer, appointed producer responsibility organisation, or selected waste management operator. The passport ceases to exist after recycling.