Which hazardous substances must I report in the battery passport?

What you need to do concretely

What is expected of you

Documenting which hazardous substances are present in the battery

The battery passport contains data on substances that fall under the restrictions of Article 6 and Annex I of Regulation (EU) 2023/1542. This is not a complete chemical analysis of the battery, but rather the substances for which the regulation sets a limit value or a ban — mercury, cadmium and lead are the most well-known examples, with the caveat that Annex I more precisely specifies for which battery type and which application a limit value applies. For a company with 10 to 100 employees, this means in practice that a list must be drawn up of the regulated substances present in the supplied battery type, with the associated concentration or a statement that the substance is not present above the threshold. This data usually comes from the cell manufacturer or the supplier further down the chain; anyone who imports or assembles is dependent on this information being passed on.

Linking the information recognisably to the battery model

Annex XIII of the regulation describes which data must be included in the passport, and the information on hazardous substances must be traceable in it to the specific battery model or specific batch. This means that a general statement from the manufacturer ("our batteries contain no cadmium") is not sufficient in itself if that statement is not linked to the model that is actually described in the passport. For a range with multiple battery types — which is more the rule than the exception for importers of e-bikes and scooters — this quickly becomes unmanageable if the documentation varies by supplier in form and level of detail.

Making a distinction between substance information and material composition

The data on hazardous substances are separate from the broader question of which materials are in the battery. The latter is a separate obligation with its own level of detail; those who wonder what data about the materials in a battery do I need to provide exactly note that the scope is broader than regulated substances alone. For the passport, it is practical to document these two categories separately, even though they often come from the same technical source at the manufacturer.

Updating when composition changes

A cell supplier that changes composition — for example a different alloy or a modified cell design — may thereby also change the presence or concentration of regulated substances. This touches on the question how often must I update the data in the battery passport; for substance information, in practice a change at the source must be reflected in the passport as soon as possible, because this data directly affects compliance with the restrictions themselves and not just information provision.

Where things go wrong in practice

An importer of e-bike batteries receives a general certificate of conformity from the Asian cell manufacturer stating that "all EU restrictions are respected", without mentioning concentrations or substance names. That document cannot be translated into the specific fields that Annex XIII requests, and the importer is left with a passport that is effectively empty on this point.

When changing assortment, a new battery cell is purchased from a different supplier, but the existing passport template of the previous model is reused without rechecking the substance data. The two cell types differ in composition, but this is not noticed because no one makes the comparison.

A trading company receives loose safety data sheets (SDS) from the manufacturer and assumes that these are sufficient as a basis for the passport. An SDS is prepared for a different purpose — chemical safety during handling — and does not automatically cover the specific reporting obligation of Article 6 and Annex I; what an SDS contains about hazardous properties overlaps but does not answer the same question as what safety information must be included in the battery passport.

For a machine manufacturer assembling industrial battery packs above 2 kWh from purchased modules, the substance information of each module is recorded separately, but no one checks whether the assembled pack as a whole still matches what is specified for the final product. The sum of correct components does not automatically result in a correct passport at pack level.

A supplier sends an update of substance data by email to an individual employee who goes on holiday before the change is implemented in the passport. Without a fixed reception point for this type of documentation, the risk is real that a change in the cell does not reach the published data in time.

What you can record

• A documentation overview per battery model with the source of the substance information: name of the supplier, date of the document, and which substances with which concentration are specified.
• A fixed template request to each new supplier at the start of the business relationship: an explicit request for the concentrations of the substances mentioned in Annex I, not just a general declaration of conformity.
• An internal checklist that, with each assortment change or supplier change, enforces that substance data is requested again and compared with the previous model, instead of copying the existing passport.
• A designated reception point (function, not person) for supplier updates on composition changes, so that a change does not remain with one employee.
• A documented link between the substance data and the specific battery model or batch, so that during an inspection it is clear which document belongs to which product — this is in line with the broader question which data must be in the battery passport.
• For assembled packs: an overview at pack level that adds up or summarizes the substance data of the individual modules, so that consistency between component and final product is verifiable.