how do I check if my battery passport works correctly before I go live

Testing is possible, and advisable, before going live

A battery passport check before it becomes publicly accessible amounts to verifying three things: the QR code is on the battery and leads to the correct page, all mandatory information from Annex XIII is present and materially correct, and the page remains accessible in a manner consistent with what Article 77 of Regulation (EU) 2023/1542 (Battery Regulation) requires. This is not a legally prescribed test procedure — it is not described anywhere — but a practical check that prevents an error from only becoming apparent after the first batteries have already left the premises.

Testing itself is therefore not an obligation in its own right, but a logical step in the process that ends with a passport that meets legal requirements. Whoever tackles the battery passport step by step, will naturally reach the point where the information is complete and testing can take place before the QR code is applied to the first battery.

Which batteries this is relevant for, and which it is not

This check is relevant for every battery that falls under the obligation of Article 77: EV batteries, batteries for light means of transport such as e-bikes and scooters, and industrial batteries above 2 kWh. For batteries that do not fall into these categories — small consumer batteries, for example — the passport obligation does not apply, and a test in this form is therefore not required. Anyone unsure whether a particular product falls under the obligation will find the delimitation set out in the explanation about whether the battery passport applies to a specific battery.

It is also important to distinguish between testing before going live and the obligations that apply thereafter. Testing before going live is a one-time event, at the start of a product line or model. The obligations of the market participant under Articles 38 to 44 of the Battery Regulation — such as ensuring that information remains up to date — continue for as long as the battery is on the market. A test at going live therefore says nothing about whether the passport is still correct a year later; that is a separate, ongoing responsibility.

For batteries already in stock before the mandatory date, there is a separate consideration that is separate from this test question; this is set out in the section on what to do with batteries already in stock.

What is already established now, and what still needs to happen

The obligation to have a battery passport applies from 18 February 2027. Until that date, there is no legal obligation to already demonstrate a working passport, but that does not mean there is nothing to do. The period until the mandatory date is precisely the time to prepare the passport, fill it with the information from Annex XIII, and test whether everything is correct before the deadline becomes an issue. Whoever waits to test until shortly before the date risks that an error in the QR code, missing information, or an incorrect link between battery and passport only comes to light at a time when there is no room to correct it properly.

How much time that preparation — including testing — requires in practice depends on how many product types and data there are; an indication of this can be found in the overview on how long it takes to get in order.

What the check looks like in practice

The order in which a test is usually conducted begins with the QR code itself: scan with an ordinary phone and check whether the link works, without login or additional steps that a supervisory authority or consumer could not take. This is followed by a check of the content against Annex XIII: are all mandatory fields present, are chemical composition, capacity, origin and other information correctly taken from the documentation of the manufacturer or importer, and is there no information confused with another (think of a mix-up between batch number and model number).

Next, it is advisable to verify that the page aligns with what is stated in the EU declaration of conformity and the CE marking, as referred to in Articles 17 to 20 of the Battery Regulation — not because the passport follows the same procedure, but because conflicting data between the passport and conformity documentation is a signal that something is not right in the underlying process. After that, testing the durability of the link is relevant: once the QR code is affixed to the battery, does it continue to point to the same page, even after updates to the passport itself. For batteries that later receive a second life or are refurbished, it is moreover good to test in advance whether the passport is prepared for this; this aligns with the points of attention in the documents on second-hand and refurbished batteries and on giving a battery a second life.

Anyone who completes these steps before the first battery leaves the factory has a good indication of whether the passport does what it should do at the moment a competent authority asks about it; what can be checked in detail is described in the overview of what a supervisory authority requests during an inspection on batteries.

Where this is based on: Article 77 and Annex XIII

The substantive requirements for the battery passport derive from Article 77 and Annex XIII of Regulation (EU) 2023/1542. Annex XIII determines which data must be included; Article 77 describes the format and accessibility, including the link via a data carrier such as the QR code. The ongoing responsibility to keep data correct and up-to-date follows from Articles 38 to 44, which govern the obligations of economic operators. The relationship between the passport and the conformity assessment, including the EU declaration of conformity and the CE marking, is set out in Articles 17 to 20. A specific test procedure is not described in any of these articles; the check described here is a practical implementation to comply with these provisions, not a legally prescribed step.

If you have reached the point where testing can be carried out, you can place your own data collection alongside Annex XIII and have the QR code scanned on a test battery by a colleague who does not know the background — this often quickly shows whether the page also seems logical and complete to an outsider.