how do I get the correct passport data from a manufacturer in China

As an importer, you are the point of contact, not the factory

Whoever places batteries or products containing batteries from China (or any other country outside the EU) on the European market is the one who must provide the passport data — not the factory in Shenzhen or Ningbo. The manufacturer in Asia has the technical data, but falls outside the scope of the European regulation. This makes the importer the party that must request these data, verify them and pass them on to a platform such as batpas.eu. This follows from the division of roles that the Battery Regulation maintains: whoever places a battery on the EU market for the first time bears the obligations that come with it, even if that battery was made elsewhere.

For whom this applies, and who is not affected

This applies to every importer who purchases batteries — loose, in e-bikes, in scooters, or as part of machinery — directly from a factory outside the EU. If you buy from a European distributor or wholesaler instead, you then have exactly a party within the EU who can act as a point of contact and who must have already requested data from their own source. The distinction is therefore not "Chinese factory versus European factory", but "importing directly versus purchasing from a link already within the EU". Some factories in Asia work with an authorised representative in the EU; that representative has their own obligations and can in practice become the point of contact for data, but this does not change the position of the importer themselves.

No fixed entry date for these arrangements yet, but a point at which the passport becomes mandatory

There is no separate moment at which the obligation to request data from a factory takes effect — that obligation is linked to the moment at which the battery passport itself becomes mandatory, and that is set for 18 February 2027. Until that date, there is room to set up the data flow with a factory, to secure it contractually and to test it, without a missing piece of data immediately becoming a problem. After that date, the information must be available when the battery is placed on the market. The sooner the conversation with the factory begins, the more time there is to discover which data are and are not standard available.

How this is handled in practice

The first step is to gain clarity on which data are needed — that overview is described on the page on which data you request from your battery supplier, and forms the starting point for any conversation with a factory, regardless of where it is located. After that, it is a matter of making this concrete towards the factory: do not ask for "documentation", but for specific fields such as chemical composition, origin of raw materials, capacity and CO2 footprint, preferably in a fixed format so that the factory knows what is meant.

Factories in Asia often work with their own templates or export documentation that does not align one-to-one with what the passport requires. It is therefore practical to determine in advance in what form the data will be provided — a spreadsheet, a PDF datasheet, or a direct link — and to record this as described under the format of supplied data. For repeat orders or ongoing relationships, it is worthwhile not to leave this arrangement hanging in email correspondence, but to include it in the purchasing contract, as set out on the page on recording agreements in your purchasing contract — this prevents a factory from having to be explained all over again what is needed when placing the next order.

When the data has been received, verification of its accuracy is a separate step, especially with a factory with which no long-term relationship yet exists: figures that do not match what is on the nameplate or in previous documentation are a signal to ask further questions before the data ends up in a passport. If a factory structurally fails to provide data or provides insufficient data, that is not a dead end — that situation, with the possible follow-up steps, is described on the page about what to do if a supplier does not supply the data, For raw materials such as cobalt, lithium and graphite there is an additional layer: the origin of these materials falls under a separate due diligence obligation, which is explained separately on the page about raw materials from risk zones.

The obligations of market participants and authorised representatives in the Regulation

The division of roles between manufacturer, importer and any authorised representative is described in Articles 38 to 44 of Regulation (EU) 2023/1542 (Battery Regulation), which regulate the obligations of market participants. Article 40 specifically addresses the obligations of an authorised representative, relevant to the situation where a factory outside the EU works with such a representative. The obligation to make passport data available is set out in Article 77 of the same regulation.

What to do now

A good first step is to place the overview of required data alongside the factory's existing documentation to see which fields are missing, and to make that conversation — including the desired format — a fixed part of every new order or contract renewal.