How do I check if my supplier's data is correct?

The basics: checking data against the supplier's role

A supplier's data can be verified by comparing it with what the Battery Regulation requires of that specific link in the supply chain: a manufacturer has different obligations than an importer or distributor, and the supplied data should match accordingly. For a manufacturer, this includes the technical documentation that supports the EU declaration of conformity; for an importer or distributor, it is primarily a matter of checking whether those documents and the CE marking are present, not of reassessing their content. An importer or trader receiving data from a manufacturer therefore checks first and foremost whether the correct type of document is present, originating from the correct party, with a recognisable reference to the battery or battery model in question. If those references are missing, or if the model number differs from what appears on the battery itself, that is a concrete signal that the data should be examined more closely before being passed on.

Who this applies to, and what it does not

This check concerns everyone who acts as an economic operator within the meaning of the Regulation — manufacturer, authorised representative, importer or distributor — and covers the data they exchange or supply to each other, such as the EU declaration of conformity, the CE marking and the underlying technical documentation. It is not about a substantive reassessment of test results, chemical composition or lifetime data: an importer or distributor checks whether the documents are complete, consistent and from the correct party, not whether the laboratory work behind them is correct. That substantive examination is part of the conformity assessment that the manufacturer itself has carried out. Nor does it concern the content of the digital product passport itself; that is compiled from the data supplied by the manufacturer or importer, and the accuracy of those source data remains the responsibility of whoever supplies them, not of whoever processes or hosts them.

From when this becomes relevant

The obligation to maintain a digital product passport applies from 18 February 2027. Until that date, the obligations of economic operators under Articles 38 to 44 and the rules on conformity assessment, EU declaration of conformity and CE marking under Articles 17 to 20 already apply, irrespective of the passport: a battery placed on the market now should already be accompanied by an EU declaration of conformity and a CE marking. Checking supplier data is therefore not an issue that only arises from 2027 onwards; that check is already part of standard purchasing practice now. From that date, the product passport adds an additional layer to this: the same data must then also be available digitally, in structured form and via a QR data carrier.

How this is handled in practice

In practice, this begins with establishing your own role: whoever acts as an importer of e-bikes, scooters or industrial batteries above 2 kWh shall verify whether the manufacturer has issued an EU declaration of conformity that is specific to the battery model in question, and whether the CE marking has been affixed to the battery or packaging as described in Articles 17 to 20. Thereafter it is customary to check whether the data provided by the manufacturer — chemical composition, capacity, origin of raw materials and the other fields required for the product passport — are mutually consistent and correspond to what appears on the nameplate or in the accompanying documentation. Specific points of attention are a model number on the declaration that differs from the model number on the physical battery, missing signatures or dates, and documentation that refers to a different manufacturing process than the one supplied. Anyone in doubt as to whether the supplied data are complete may inquire about this with the manufacturer or original supplier: the regulation places responsibility for the accuracy of the data with that party, not with the person who receives and passes on the data.

Where this is based on: Articles 38-44 and 17-20

This follows from Articles 38 to 44 of Regulation (EU) 2023/1542, which describe the obligations of manufacturers, authorised representatives, importers and distributors separately, and from Articles 17 to 20, which concern conformity assessment, the EU declaration of conformity and CE marking. Together these articles determine who must compile, keep and pass on which data, and under what conditions a market participant may rely on the data of another link in the chain without having to reassess it substantively.

Whoever now receives supplier data for e-bike, scooter or industrial batteries can compare it against Articles 38 to 44 and 17 to 20 to verify whether their own role and the associated documents are correct. Batpas.eu subsequently processes that data into the digital product passport and hosts this for ten years with the associated QR data carrier, but the accuracy of the source data remains with whoever supplies it.