Which data must I request from my battery supplier?

What you need to do concretely

What is expected of you

If you import or trade batteries, you do not compile all the underlying data yourself — it comes from the manufacturer, the cell supplier, or the factory that assembles the battery. Regulation (EU) 2023/1542 (Battery Regulation), Annex XIII, sets out which data must appear in the battery passport, and Articles 38 to 44 divide the responsibilities between manufacturer, importer and distributor. For an importer or trader, this means: retrieving data, checking it, and supplementing it if necessary before the passport can be released.

Know exactly which data is needed

Annex XIII describes categories such as composition, source of raw materials, performance, lifespan and information for disassembly and recycling. For a company with 10 to 100 employees, this usually means that one person or a small team places the list from Annex XIII alongside the supplier's documentation and checks what is already coming in and what is structurally missing. This is not a one-time exercise: with each new model or each new supplier, that comparison must be made again.

Request data from the source

The party that places the battery on the EU market is accountable for the completeness of the passport — even if the actual data comes from a sub-supplier. This makes requesting data not a matter of asking and waiting, but of documenting what arrives and when. For composite products, such as an e-bike with a separately purchased battery, it is common for data about the cells themselves to lie with a different party than data about the assembly. Which data that is exactly and who holds it is described on the page on which data you request from your cell supplier for the passport.

Check before the passport is published

Receiving data is not the same as approving data. An importer who passes on data without reviewing it runs the risk that errors in the passport end up linked to their own name. In practical terms, for a mid-sized company this means building in a fixed control point — often on receipt of a new batch or new model — before the data is released for the passport. How that check works in practice is set out on the page on how you check whether your supplier's data is correct.

Document what has been agreed and received

Because the obligation to provide a passport lies with the market participant themselves, it is advisable that agreements with suppliers about delivery, format and timing of data are not kept to verbal agreements only. For companies working with multiple suppliers, or that change suppliers regularly, this is a recurring point of attention with each new purchasing relationship.

Where things go wrong in practice

A number of situations come up repeatedly in practice.

The supplier sends only a product sheet. That is useful for marketing, but often lacks the specific data that Annex XIII requires, such as exact composition or data on raw material sourcing. The product sheet is then taken to be "the data", while the passport cannot be completed with that information.

The factory supplies in a format that does not fit. Data arrives as a PDF, as a separate Excel file, or sometimes as a photo of a table. That is workable, but takes time and leads to errors in transcription. What a workable format is and how it can be supplied is described on the page on the format in which battery data is supplied for the passport.

The same battery comes from different factories. With growth or supply problems, the same model is sometimes purchased from a second supplier. The data from both sources are rarely identical, even though it is the "same" battery on paper. What that means for the passport is explained on the page on what to do if the same battery comes from different suppliers.

The supplier does not respond, or responds too late. Especially with factories outside the EU, requesting additional data sometimes takes weeks, while the importer already has obligations towards the market. See the page on what to do if the supplier does not provide the data.

Raw material data is systematically missing. Information on cobalt, lithium or graphite and their origin is often not provided as standard by suppliers, even though this is part of the broader due diligence obligation regarding batteries. What this obligation entails is set out on the page on the due diligence obligation for batteries, and the sensitivity of specific raw materials is explained on the page on cobalt, lithium and graphite from areas of concern.

What you can record

A number of documents and agreements make requesting and managing supplier data manageable:

• A supplier overview per battery model: which party supplies which part of the data, and since when.
• A fixed dataset per model, based on the categories in Annex XIII, so that it is clear what is complete and what is still missing.
• Contractual agreements on the supply of data, including format and time of delivery — detailed on the page on how to record the supply of product passport data in your purchasing contract.
• A checklist which is gone through with every new delivery, including who has checked the data and on which date.
• A file per batch or model with the received source documents, so that in case of questions afterwards it can be traced where which information came from.
• Agreements on updates, for example when a battery is later repaired or rebuilt — see the page on updating data when a battery is replaced.

For companies working with factories outside the EU, particularly in China, it is often more difficult to establish these agreements clearly in the first purchasing negotiation. Practical points of attention for this are on the page on how to obtain the correct product passport data from a manufacturer in China.