in what format must I submit the battery data for the passport

What you need to do concretely

What is expected of you

The Battery Regulation does not prescribe a file format. Nowhere in Article 77 or Annex XIII does it state that data must be supplied as a CSV, XML, JSON or Excel file. What the regulation does prescribe is which data must appear in the battery passport and that that data must be accessible via a QR code. The format in which a company internally maintains that data or sends it to a service provider is thereby a practical matter, not a legal one.

For a company with 10 to 100 employees, this is not a licence to handle it arbitrarily. The obligation that is concrete is that the content is correct and complete according to Annex XIII. The format is subordinate to it: a spreadsheet, a PDF with technical specifications, or an export from an ERP system all comply, as long as the data they contain aligns with what Annex XIII requires.

Ensuring that content aligns with Annex XIII

Annex XIII lists categories such as general battery information, performance, durability and material composition. For an importer or trader, this means that supplied documentation — in whatever form — must cover those categories. A technical datasheet from the manufacturer is often a good starting point, but does not always cover all the fields that Annex XIII requires. Which data is needed exactly and from whom it is requested is described on the page on which data you request from your battery supplier.

Ensuring that data is transferable

A second practical point is that data, in whatever format it arrives, must be reusable for drawing up the passport. A photo of a type plate or a scanned declaration is often not enough to fill in all fields from Annex XIII; a structured file — even if it is "just" an Excel sheet — is usually more practical than loose documents. For companies that have a battery passport drawn up by a third party, the question is then not "what format does the regulation want", but "what format can the party drawing up the passport process".

Ensuring that data from different sources comes together

With composite products, such as an e-bike with a battery from one manufacturer and cells from another, data often comes from multiple sources and thus in multiple formats. This is not a problem in itself, but it requires a way to combine that data into one complete picture per battery. What to do if the same battery arrives through different suppliers is explained on the page on what you do if the same battery comes from different suppliers.

Where things go wrong in practice

An importer receives from the factory in Shenzhen a PDF with a product photo and a brief specification table, and assumes this is sufficient basis for the passport. Upon closer examination, data on material composition and durability performance that Annex XIII requires are missing. The format was not the problem; the content was.

Another company receives data in different files per supplier: one sends a Word document, another an Excel file, a third only a link to a product page. No one within the company has been assigned the task of combining these sources into one overview per battery type, so when the passport is actually created, no one remembers which version of which file was the correct one.

A third situation: a trader takes the manufacturer's technical specifications literally, without checking whether the units and definitions match what Annex XIII requires. A capacity value defined differently in the manufacturer's datasheet than in the regulation then leads to a passport with a figure that looks correct but is not. How to check this is addressed on the page on how you verify your supplier's data for accuracy.

A fourth situation occurs with companies that themselves convert or repair batteries, for example when replacing a battery pack in a light commercial vehicle. The original data were received in a particular format at the time of initial import, but after the repair it was not recorded whether and how the passport data needed to be updated. This relates to the question of whether the passport must be updated when a battery is replaced, explained on the page on whether the passport must be updated in case of repair or conversion.

A fifth situation: a company assumes that because the manufacturer has sent "all documentation", the data are complete. Upon inquiry it turns out that the manufacturer only shared general product information and not the specific data on raw materials relevant to the due diligence obligation. What that obligation entails is described on the page on what the due diligence obligation for batteries entails.

What you can record

• An overview per battery type of which data have already been received, in which file, and which are still missing compared to Annex XIII.
• A fixed contact person at each supplier for the provision and, where necessary, supplementation of data.
• An agreement on the submission format in the supply contract, so that not every supplier sends a different file type without coordination. How this can be recorded is on the page on recording agreements on passport data in the supply contract.
• A file per battery type with the original source documents from the manufacturer, so that in case of questions or inspections it can be traced where a value in the passport comes from.
• A fixed procedure for what to do if a supplier provides no or incomplete data, with an escalation step. Starting points for this are on the page on what to do if a supplier does not supply the data.
• A separate note for batteries where cells and pack come from different parties, stating which party supplied which part of the data from Annex XIII. See also the page on which data are requested from a cell supplier for the passport.