Which performance and sustainability data belong in the passport?

What you need to do concretely

What is expected of you

Performance and sustainability data form one of the core components of the battery passport. These are figures that indicate how well a battery performs, how long it lasts and how burdensome it is for the environment. Articles 9 and 10 of Regulation (EU) 2023/1542 (Battery Regulation) describe which performance and sustainability requirements apply, and Annex XIII of the same regulation sets out which data from these concretely end up in the passport.

Recording capacity and energy content

The nominal capacity and energy content of a battery are among the basic data that appear in the passport. For an importer of e-bikes or scooters, this means that these values must be known for each battery type or model, usually sourced from the manufacturer's technical documentation. For a company with between 10 and 100 employees, this is often not a problem if procurement takes place directly from a single producer, but it becomes more difficult with a wider range from varying suppliers, where this data is not always provided in the same way.

Reporting expected service life and cycle durability

In addition to capacity, information about the expected service life and the number of charging cycles a battery can withstand is also part of the performance data. This is more than a marketing figure: it is data that has been determined according to established test methods and that must remain traceable throughout the battery's service life. For companies that assemble batteries themselves from cells of different suppliers, this means that the test results of the underlying cells must be retained and assigned to the end product.

Including CO2 footprint

For certain battery categories, the carbon footprint is part of the sustainability data in the passport. This figure is not simply estimated, but follows from an established calculation method that includes the entire life cycle from raw material to production. For the way in which this footprint is built up and what data is needed for it, there is a detailed explanation of how the CO2 footprint of a battery is determined. For a machine builder incorporating battery packs into their own equipment, this is often the data that requires the most coordination with the cell supplier, because the footprint is built up further back in the chain than their own production step.

Tracking state of health throughout service life

Part of the performance data is not static, but changes during the use of the battery. The state of health — an indication of how much capacity a battery still has compared to new — is the clearest example of this. What this precisely means and why this data must be tracked in the passport is described in the state of health of the battery. For battery traders dealing in second-hand or reconditioned industrial batteries, this is often the data that requires the most maintenance, because it is not set once but changes over time.

Including sustainability data on material origin

In addition to performance in the narrow sense, data on the origin and composition of materials are also part of the sustainability information. Think of the share of recycled material in certain metals. How this share is demonstrated and substantiated is explained in the share of recycled cobalt, lithium, nickel and lead. For companies that import batteries without themselves being part of the production chain, this means above all that this data must be requested from the manufacturer and cannot be determined in-house.

Where things go wrong in practice

A first common situation is that performance data appears on the packaging or in a product sheet, but is not substantiated with the test method required for the passport. A marketing figure on service life is then not automatically suitable for adoption.

A second situation arises when a company assembles battery packs from cells of different manufacturers and the performance data of the individual cells have not been consistently passed on to the end product. The battery passport asks for data at the level of the delivered battery, not for an average or estimate.

A third situation is that the CO2 footprint is taken from a general sector study instead of a calculation specific to the delivered battery model. This difference is not cosmetic: the footprint should be a figure that can be traced back to the actual production chain of the battery in question.

A fourth situation occurs with second-hand or refurbished batteries, where the original performance data are adopted without taking into account the changed state of health after use. As a result, the battery passport no longer matches the actual condition of the battery at the time of resale.

A fifth situation is that the share of recycled material is stated as a fixed percentage for an entire product line, whereas this can vary per batch or supplier. Without substantiation per batch, a figure emerges that does not reflect the actual composition of the delivered battery.

What you can record

• Test reports from the manufacturer on capacity, energy content and cycle durability, per battery type or model
• Documentation of the calculation method used for the CO2 footprint, including the source of the underlying data
• An overview of how and when the state of health is measured and updated during the lifespan of the battery
• Supplier declarations on the share of recycled material per raw material and per batch
• An internal overview of which performance data per battery model are already available and which still need to be requested from the manufacturer or cell supplier, as a supplement to the broader overview of which data must be included in the battery passport
• Agreements with suppliers on keeping this data up to date, including a reference to how frequently this type of data is updated