How often must I update the data in the battery passport?

What you need to do concretely

What is expected of you

Article 77 of Regulation (EU) 2023/1542 (battery regulation) stipulates that the battery passport must be accessible via the QR data carrier, linked to a unique identification code, and that the data contained therein must be correct throughout its term. What the regulation does not do is prescribe a fixed schedule for reviewing each data source. This does not mean that updating is optional — it means that the frequency is linked to the nature of the data itself.

Record static data correctly once

Part of the data in the passport is fixed as soon as the battery leaves the factory: the battery chemistry, the material composition, the CO2 footprint during production, the proportion of recycled material. For a company with 10 to 100 employees, this means above all that this data must be carefully transferred from the manufacturer's documentation when the passport is first created. How battery chemistry is recorded in the passport and how the proportion of recycled cobalt, lithium, nickel and lead is demonstrated, is work that is done thoroughly once and then rarely changes — unless the manufacturer itself makes a product modification.

Dynamic data that moves with use

Another part of the passport describes precisely the condition of the battery during the use phase. Article 14 mentions information about the condition and expected lifetime, which in practice amounts to data that changes as the battery ages and undergoes more charge cycles. For an importer or trader, this means that the passport cannot be treated as a form that is filled in once: where in the product the measurement data originate (for example via a battery management system) and how that data finds its way to the passport is a question that must be answered per product line. What the state of health of a battery precisely means and why that data must be included, also determines how often an update makes sense.

Implement changes in the supply chain

A third category concerns data that changes because something in the supply chain or in the company's own operations changes: a new supplier of cells, a modified recycling trajectory at the end of the product life, or a change in the party responsible for the passport. This affects, among other things, the data on collection and recycling and the question of which party is allowed to modify which data. For a company of average size, this means that someone inside the company must be designated to identify this type of change, because such changes rarely reach the passport automatically.

Where things go wrong in practice

A first situation that often occurs: the passport is neatly filled in when a product line is launched, but no one within the company is assigned to maintain it once the first batteries enter the use phase. The data on condition and lifetime then remain at the starting value, while the battery is meanwhile in use for years.

A second situation: an importer switches cell suppliers without the change in material composition or chemistry being carried through in existing passports of previously supplied batteries. The passport of a new batch is correct, but older passports still refer to the old specification while the product model bears the same name.

A third situation arises in companies that have the passport hosted by a third party, but do not themselves record who submitted which change and when. If a supervisor asks how a particular piece of data came about, there is then no trace to be found.

A fourth situation: the end-of-life trajectory changes — a new recycling partner, a different collection point — but this change does not reach the party managing the passport, because the operations department and the party responsible for product compliance do not communicate with each other.

A fifth situation arises with companies that believe the product passport is "complete" once delivered, whereas in fact the data falling under Article 14 is by definition a snapshot that becomes outdated as soon as the battery is used.

What you can record

• An overview of which data in the product passport are static (chemistry, material composition, CO2 footprint at production) and which are dynamic (condition, expected lifetime), so that it is clear which data needs to be reviewed and for what reason.
• An internal designation of the person or department responsible for flagging changes in the supply chain, such as a different cell supplier or a modified recycling process.
• A file per product line documenting the source of each piece of data in the product passport — manufacturer specification, own measurement, or third party — so that in case of a later query it can be traced how the data originated.
• Agreements with the party hosting the product passport (for example batpas.eu) on who may make a change and within what timeframe a submitted change is processed.
• A fixed procedure for when a product modification takes place — new cell, different material, different supplier — so that it is immediately clear which product passports need to be updated and which do not.
• An overview of who may view and modify which data, which aligns with the question who may view which data from the battery passport, and on the consideration of whether certain data are commercially sensitive and thus should not be made public without further ado, as described in protecting commercially sensitive data.