Getting the data from your supplier

Why you need it

The company that places the battery on the market must make sure its passport is accurate, complete and up to date (Article 77(4)). For most brands and importers, the composition, performance values, test reports and serial numbers come from a pack or cell maker, often outside the EU.

Article 39 obliges suppliers of cells and modules to give a battery manufacturer the information and documentation it needs to comply, free of charge. For a complete pack built for you, what you get depends on your contract, so put the data in it.

Per battery model

Most of the passport describes the model and is the same for every battery of that model:

• Chemistry, rated capacity, minimum, nominal and maximum voltage, weight and power capability

• The performance and durability values of Annex IV: capacity fade, power fade, internal resistance and its increase, round-trip efficiency where it applies, and expected lifetime in cycles and calendar years, with how they were measured

• Material composition, including the materials of the cathode, anode and electrolyte

• Hazardous substances, and critical raw materials above 0.1% by weight

• The usable extinguishing agent and the temperature range the battery withstands

• Dismantling information: exploded diagrams, disassembly steps, fastenings, tools, and the number and layout of cells

• Safety measures, and the part numbers and sources of spare parts

• The test reports that prove compliance, which only authorities see

For the detailed composition, the Commission’s FAQ considers a threshold of 1%, as in DIN DKE SPEC 99100, or 0.1%, as in a draft CEN specification, potentially reasonable, as long as the result says more than a chemistry such as “LFP”.

Per battery

• The serial number, or other identification, of each battery

• Place and date (month and year) of manufacture

• The performance values of that battery when it is placed on the market

• How its battery management system stores state-of-health data, and how you and repairers can read it

Since 18 August 2024, the battery management system of an LMT battery has had to hold up-to-date data such as the remaining capacity, the evolution of self-discharge, energy and capacity throughput, harmful events like deep discharges and time spent in extreme temperatures, and the number of full equivalent cycles (Article 14 and Annex VII). That data feeds the state of health in the passport.

According to the Commission’s FAQ, fields that come from use, such as charge cycles or accidents, can stay empty when a new battery is placed on the market. The status and the performance values can’t.

Ask for it in a usable format

• One sheet per model and one row per battery, with the serial numbers before each shipment

• The data points of the Commission’s guidance, or the attributes of DIN DKE SPEC 99100, so nothing gets lost in translation

• Units with every value, and the standard or method behind each measured value

• New data whenever the design, the cells or the cell supplier change

A battery model is a version whose units share the same technical characteristics and model identifier. When your supplier changes the cells, the model data you have may no longer be right.

Plan for what comes later

The carbon footprint, from 18 August 2028 at the earliest for LMT batteries, and recycled content documentation, from 18 August 2033, need data from further up the supply chain. Ask now whether your supplier will be able to provide it.

If the supplier manages the passports

You can give your supplier, or any other operator, written authorisation to create and update the passports for you. The Commission’s FAQ confirms that this doesn’t make the supplier the manufacturer or importer: you stay responsible for the data, and the passports are registered in the EU registry by the company that places the batteries on the market.