The mistake: one passport for multiple variants
The most common mistake we see among companies setting up a digital battery passport is that one passport is linked to multiple variants of a battery at the same time. This happens, for example, when an importer runs three capacity variants of the same e-bike battery under one QR code, or when a new supplier uses the same cell chemistry but with a slightly different composition. The QR code is then simply reused, while the underlying data no longer match the battery that the customer actually has in hand.
This usually does not arise from reluctance, but from convenience. Having one sticker printed for an entire batch is practical, and as long as batteries are technically similar, it does not feel like a problem. Yet the regulation makes a distinction precisely on this point: the passport is intended to belong to a specific model, and within that model to the battery that was actually produced, with the data that belongs to it. Whoever decouples that displays a passport that no longer corresponds to the product behind it.
Why this goes wrong more often than you would think
The problem usually only arises after the setup, not during it. In the first version of a passport, the link is usually still correct: one model, one dataset. It goes wrong as soon as the assortment changes. A supplier modifies a cell type, an importer adds a variant with higher capacity, or a batch is produced at a different time with a modified BMS. If this change does not automatically lead to a new or updated passport registration, the old QR code simply remains on the new battery.
This is more pronounced among companies that manage the passport manually via a separate file or spreadsheet, separate from the procurement process. Once procurement and passport management are not aligned, there is no automatic signal that a new or modified battery also needs a new or updated registration. At the knowledge base about the passport in daily practice you can read how other companies have organized this process, even if you do not have a separate IT department.
How to identify this in your own situation
A practical way to check whether this applies to you is to reason backwards from the QR code. Scan a number of codes from different batches of the same model and compare the underlying data with the batch that was actually received: does the serial number match, does the cell chemistry match, is the supplier still the same? If this differs, then a link has somewhere come loose between what was purchased and what is in the passport.
The core of the risk does not lie in the mistake itself, but in traceability. Supervisory authorities look at a digital passport to determine whether the data displayed correspond to the battery that the customer or technician actually has. A passport that no longer corresponds to the physical product undermines precisely the purpose it is intended for: traceable information on composition, origin and lifespan.
How to prevent it
The most workable solution is not technically complicated, but organizational: link the moment when a new battery variant or batch is purchased to a standard checkpoint for the passport. This can be a fixed question in the procurement process, or a fixed point in the conversation with your software provider about how changes are implemented. Explicitly ask how variants are distinguished from each other within the system, and who is responsible for updating the link when a supplier makes a change.
At batpas.eu, this linkage is secured by having each product passport connect to the specific data that you or your supplier provide, with a fixed procedure for what happens when a model changes. How that process works in detail is explained on the page on how data is processed into a product passport. If you are uncertain whether this is already properly set up for your range, the quick-scan with a few short questions provides an initial indication, without requiring you to register anything.
This explanation is descriptive and general; it does not address your specific situation. For an assessment of your own range and the way you have set it up now, a lawyer or the competent supervisory authority is the right point of contact.
Further reading
Do you need more background before discussing this internally? See the most frequently asked questions about the digital battery product passport or do the free quick-scan first to see where your situation stands at this moment.