For the digital passport of an e-bike or scooter battery, you essentially need three types of documents: data on the cells from which the pack is built, data on the assembly of the pack, and data on yourself as the party placing the product on the European market. For an LMT battery, the designation used by the regulation for batteries in light means of transport such as e-bikes and kickboards, the complication almost always lies in the first part: the cells usually come from a different manufacturer than the pack, and these two links must connect to each other in the passport.
Specifically, the following documents are involved. From the cell manufacturer you need the technical datasheet with chemistry, capacity and safety characteristics, and preferably also a declaration on the origin of raw materials such as cobalt, lithium and nickel. From the party that assembles the cells into a pack comes the specification of the pack itself: the Battery Management System, the housing, the connections and the test results proving that the pack is safe. In addition, there is the declaration of conformity that goes with CE marking, the nameplate with model number and production date, and information on repair, disassembly and recycling that often must come from the importer itself because the manufacturer in Asia does not routinely supply this data.
Why cell origin is the most missing document
With many other products, the documentation chain is short: one manufacturer, one file. With an e-bike battery, this is rarely the case. The cells are often purchased from a specialized cell producer, while another company builds the cells into a complete pack with housing and electronics. Both links have their own documentation, and as an importer or brand holder you must bring this documentation together before a passport can be created. In practice, this turns out to be the step where most delays occur: not because the documentation is lacking, but because the cell manufacturer is not accustomed to providing this data in a form that is directly usable.
It is therefore advisable to ask this question early from your supplier, sooner rather than just before the obligation comes into effect. Specifically ask for the technical datasheet per cell type, for a declaration on raw material origin, and for evidence of the test standards used. Suppliers who work frequently with European customers usually have these documents already prepared; with smaller or new suppliers you may have to actively request them.
What you supply yourself as an importer or brand holder
In addition to the technical documents from the suppliers, there is a part that belongs with you as the responsible party. This includes, among other things, your name and address details as they should appear on the product, data on the expected service life and warranty period, and instructions for disassembly or recycling at the end of the service life. These documents are often forgotten because they do not come from a manufacturer, but must be recorded from within your own company.
To determine the exact role you play in this chain, and which documents go with it, it is useful to first be clear on whether you act as a manufacturer, importer or distributor. The knowledge base sets this out per situation, with the corresponding document list per role looked up in the knowledge base per role which documents belong to your situation. Those who prefer to get an impression first without immediately collecting all the documentation can also start with a short scan that shows where attention should go first in a few questions see which documents are missing for your battery.
Collecting documents is not a one-time job
The documents listed above form the starting point, but a complete file is usually the result of several rounds of coordination with suppliers. Cells sometimes change manufacturer without the appearance of the pack changing, and then the documentation must change accordingly. It is therefore advisable to clarify in advance where the submitted data comes from and how it is maintained, especially if you work with multiple sub-suppliers at the same time. How that data origin is recorded and verified is explained on the page that explains where the information in a passport comes from on the page that shows where the data in a passport comes from.
Frequently asked questions about specific documents, such as what to do if a supplier cannot provide a technical data sheet, are collected on the frequently asked questions page the frequently asked questions page about documents and submission. For your own situation, for example when a supplier refuses to share data or there is uncertainty about who fulfils which role, it is advisable to consult a lawyer or the competent supervisory authority.
If you want to first see which documents for your assortment are already available and which are still missing, do the free quick-scan or browse through the topics in the knowledge bank. That takes half an hour and gives you an immediate indication of where you stand.