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What documents do I need for the passport of an industrial battery?

For an industrial battery (above 2 kWh), the required documents often come from multiple parties at once. This article sets out which documents are usually needed and why the supply chain makes the difference here.

What documents do I need for the passport of an industrial battery?

For an industrial battery, meaning a battery above 2 kWh that is used in, for example, a machine, an energy storage system or a stationary installation, usually the same types of documents are required as for other battery types: technical specifications, information on the composition and origin of raw materials, data on performance and lifespan, and documentation on safety and conformity. The difference lies not so much in the list itself, but in who supplies those documents.

With industrial batteries, it is the case that the battery is produced by one party and installed by another party in a machine or installation that subsequently enters the market under its own name. This makes the collection of the correct documents more complex than with an off-the-shelf product such as an e-bike battery, where the manufacturer and seller are more often the same party or in any case form one clear supply chain.

The documents listed

The core usually consists of the technical documentation of the battery cell or pack: chemistry, capacity, voltage, expected number of charge cycles and warranty conditions. In addition, there must be information on the origin of critical raw materials such as cobalt, lithium and nickel, and on the proportion of recycled material. Data on the CO2 footprint of production also form part of the whole, as does the declaration of conformity demonstrating that the battery complies with current safety requirements. Finally, information is needed on disassembly and recycling at the end of the lifespan, so that a processor later knows how to safely disassemble the battery.

Which of these components are precisely mandatory and in what form is described in the official text of the regulation. For those who wish to check for themselves per obligation what applies, the knowledge base with obligations per situation provides a detailed overview per topic.

Why the supply chain makes the difference here

The detail that stands out most with industrial batteries is that the battery manufacturer is often not the same party as the one bringing the final product to market. A machinery manufacturer that purchases a battery pack and incorporates it into a drive system is, to the outside world, the party that supplies the product, while the technical and material information about the battery itself must come from the original manufacturer. Without agreements on this, there is a risk that no one feels responsible for keeping that data complete and up to date.

This is more pronounced the further a battery is processed or installed before it reaches the end user. With an off-the-shelf consumer battery, the chain is short; with an industrial battery in a machine there can be multiple links between manufacturer and end user, each with their own role and own information obligation.

What if you source the battery and machine from different parties

For machinery manufacturing companies, this concretely means that the collection of documents does not stop at your own purchasing department. It is necessary to clarify which party in the chain supplies which part of the information, and how that information is passed on at the moment a machine with an integrated battery is sold or delivered. You should ideally hold this discussion before a delivery takes place, not afterwards when the documentation is already needed for the passport.

Since industrial batteries may also fall under existing product safety regulations, for example through the Machinery Directive, it is common for part of the required technical documentation to already exist within the company's own quality processes. It is then primarily a matter of checking which documents already exist and which are still missing for the specific purpose of the battery passport.

Documenting who supplies what

Since multiple parties are involved, it is advisable to explicitly document agreements on the provision of documentation, for example in the supply contract with the battery supplier. Those who have not yet done so can use a brief scan to determine which information is relevant for their own situation. On the page where you can see in a few questions where you stand you will get a first indication, without this already constituting a legal judgment on your specific situation.

For those who want to know how batpas.eu processes the supplied documents into a complete passport, this is explained on the page on how data is processed into a product passport. For other questions about specific situations, for example when multiple manufacturers are involved in one end product, it is advisable to consult the official text of the regulation or involve a lawyer; this article describes the main points, not the judgment on an individual case.

Further reading

Are you in doubt about which documents you need in your own situation? Do the free quick-scan or browse through the topics in the collection of frequently asked questions about the battery passport to see which question is closest to your situation.

This article is general information and not legal advice.