What safety information must be in the battery passport?

What you need to do concretely

What is expected of you

The battery passport contains not only technical specifications and origin data, but also information relevant to battery safety. Annex XIII of Regulation (EU) 2023/1542 identifies this as part of the data that the passport must disclose. For companies that import, assemble or process batteries in end products, this means that safety information cannot remain as a separate attachment or loose product sheet, but must be given a findable place in the dataset behind the QR code.

Identifying and collecting safety information

For an importer of e-bike batteries or a machine builder incorporating industrial batteries, this first means an inventory: what safety data actually exists, and who holds it? Often it is the cell manufacturer, sometimes the pack assembler, sometimes a testing institute that has performed certification. In a company with 10 to 100 employees, that knowledge is usually scattered across procurement, quality and engineering. Bringing that information together in one overview is a practical first step, and overlaps with the broader question of which data must be in the battery passport.

Linking safety information to the correct battery

Safety information is not generic: it is linked to the specific cell chemistry, the configuration of the pack and the intended use. A company that carries multiple battery variants — for example different capacities within the same scooter line — does well to check for each variant whether the safety data matches the actual composition. This aligns with recording the battery chemistry in the battery passport, because an incorrect link between chemistry and safety data is one of the most common errors in files compiled from multiple sources.

Aligning with requirements for stationary energy storage systems

Article 12 of Regulation (EU) 2023/1542 sets specific safety requirements for stationary battery systems for energy storage. For companies that market stationary storage systems alongside light-vehicle batteries, this means that the safety information in the passport aligns with the requirements applicable to that product segment. It is practical for a technical team to distinguish which safety documentation is generic (for example, related to cell chemistry) and which is specific to the system application, because this affects who within the organisation is responsible for keeping it current.

Keeping safety information current

Safety data are not static: a test report may be revised, a certification may expire or a product change may affect previously established safety characteristics. For an organisation that works daily with suppliers and customers, it is practical to determine who signals when safety data become outdated, and how this is incorporated into the passport. This subject is closely linked to the question how often the data in the battery passport must be updated, and deserves a fixed place in the maintenance process of the passport, not only at the initial setup.

Where things go wrong in practice

A common situation is that safety information does exist — in a test report, a declaration of conformity, a supplier document — but has never been converted to the format that must come in the passport. The document lies in an archive, not in the system that feeds the QR data carrier.

A second situation arises when a company carries multiple battery variants under one product name, and the safety data of the first variant are copied to later variants without checking whether the cell chemistry or cell supplier has changed. This produces a passport that in fact no longer corresponds to the product.

A third situation is that safety information is confused with data on hazardous substances. Both belong in the battery passport, but they are different data categories with a different origin and a different purpose; whoever combines them in one section risks that the data set does not align with what Annex XIII requires. For those substances, there is a separate category, see which hazardous substances must be reported in the battery passport.

A fourth, frequently occurring situation with machinery manufacturers: the safety information of the individual battery is taken over, but not reviewed at system level after the battery is installed in a larger storage system. As a result, the battery passport lacks information that is relevant for the assembled system, while Article 12 specifically addresses this.

A fifth situation is that no one in the organisation is responsible for maintaining safety data. Engineering thinks quality maintains it, quality thinks it is up to procurement — and no one updates the battery passport when a supplier provides a revised test report.

What you can record

• An overview per battery variant of the source of the safety information: cell manufacturer, pack assembler, or external testing body.
• An internal process that defines who is responsible for flagging changes in safety documentation (new test reports, changed certification).
• A link between the safety information and the recorded battery chemistry, so that if one changes, the other is automatically checked to ensure it is still correct.
• For stationary energy storage systems: a separate file in which system safety according to Article 12 is distinguished from cell safety.
• A revision log that records when safety data in the battery passport was last checked and by whom.
• A designated person within the organisation responsible for maintaining safety data, with clear handover between procurement, quality and engineering.

Whoever combines this documentation with the broader data structure of the battery passport, including the material composition of the battery, prevents safety information from remaining an isolated document alongside a battery passport that stands alone.