what data about the materials in a battery do I need to provide exactly

What you need to do concretely

What is expected of you

Material composition is one of the core data in the battery passport. Annex XIII of Regulation (EU) 2023/1542 (Battery Regulation) specifies which data on the materials in a battery belong in the passport. For a company that imports or assembles batteries, this typically breaks down into a few separate obligations.

Recording the chemical composition of the battery

The passport requires you to identify the battery chemistry: what cell type and which active materials are in the battery. This is not free text but a standardised designation. For an importer of e-bike batteries, this means that the specification from the cell manufacturer or battery pack supplier must be adopted and checked for consistency with what is actually in the product — not just what was ordered at some point. How this chemistry is precisely recorded is described in how I record the battery chemistry in the battery passport.

Reporting the presence of critical and hazardous substances

Material composition is not only about cell chemistry, but also about which substances it contains that must be reported separately — think of lead, cadmium or mercury, and substances that are classified as hazardous under other EU legislation. For a company of any size, this means that there must be a fixed procedure to check for each new battery variant whether such substances are present, and not to rely on a one-off assessment at first delivery. Which substances this precisely concerns and how they are reported is explained in which hazardous substances in the battery must be reported.

Including the share of recycled material

For cobalt, lead, lithium and nickel, the passport requires the share of recycled material. For many importers, this is the most difficult part, because this information is usually not provided as standard by a cell manufacturer and sometimes must be actively requested. A company that sources batteries from multiple manufacturers is well advised to make fixed agreements about this in the supply chain, rather than having to sort this out again for each shipment. The way in which this share is demonstrated is described in how the share of recycled cobalt, lithium, nickel and lead is demonstrated.

Aligning labelling with the passport data

Article 13 of Regulation (EU) 2023/1542 (Battery Regulation), article 77 describes what must appear on the label of the battery itself, including indications about the composition. In practice, this means that the data on the label and the data in the digital product passport must match each other. A company that has the label printed by the factory in the country of origin and has the product passport compiled separately runs the risk that these two sources diverge if a change in composition is implemented.

Where things go wrong in practice

A number of situations come up regularly with companies that must specify the material composition for the first time.

The supplier provides only a general cell specification, no product passport data. Many cell manufacturers outside the EU have a product datasheet, but it is not written with Annex XIII in mind. Information about the recycled content or about specific substances that must be reported separately is often missing.

Different batches, same product passport text. When a product change occurs at the factory — a different cell supplier, modified cell chemistry — the product passport is not always updated. The result is a product passport that shows a different composition than what is actually in the battery.

The label and the product passport contradict each other. Because labelling and product passport are often completed by different parties in the process — the factory prints the label, the importer compiles the product passport — discrepancies slip in, for example in the designation of the chemistry.

The recycled content is estimated rather than substantiated. In the absence of hard figures from the raw material chain, a percentage is sometimes entered based on an assumption or an industry average, without this being traceable anywhere.

Hazardous substances are only reported if they "stand out". Small quantities of a substance that falls under the reporting obligation are sometimes overlooked because the supplier does not explicitly mention them in the standard documentation.

What you can record

• A supplier declaration per battery type that includes the cell chemistry, the recycled content of cobalt, lead, lithium and nickel, and the presence of reported substances.
• An internal overview per product variant that links which cell supplier, which chemistry and which documentation belong to which battery.
• A fixed procedure for when a change in composition — new supplier, different cell — leads to an update of the product passport and the label.
• A control agreement between the party having the label printed and the party compiling the product passport, so that both sources show the same data.
• A reference to the broader list of required data, to be found at which data must be included in the battery passport, so that the material composition is entered in the correct context alongside the other mandatory components.