What Is the Readiness Sequence for 2027?

The 2027 readiness sequence is the ordered programme that leads an operator from classification and data collection to a tested passport system ready for placing on the market from 18 February 2027. The sequence runs from classification, through supplier data, identifier and carrier design, access tier design, hosting and registry interaction, testing, and placing, with each step gated on the previous step. A sequence that skips a step, or that carries out steps in parallel without gates, will place batteries on a system that has not been tested as a whole, and the failure will be discovered at placing, at customs or on authority request.

Readiness is evidenced step by step, not by a single statement. A readiness claim that states only that the operator is ready for 2027, without step evidence, cannot be audited. A readiness file that shows step evidence, open items, test results and review dates can be audited, and it allows a delay in one step to be managed without claiming that the whole programme is complete. The sequence in this guide is the control for that evidence, and it should be used as a checklist, not as a narrative.

What is the first readiness step?

The first readiness step is classification of every battery model, with a classification note per model stating the category, the weight and sealing evidence, the design purpose and the vehicle category where relevant, and the resulting duty map. Classification comes first because data templates, carbon duties, performance duties and passport duties all follow the category. A programme that starts with software selection, before classification, will build a system for the wrong duty set, and will need rework when classification is completed. Classification evidence should be complete and dated before the next step is signed off.

Classification sign off should be recorded per model, with the checker named and the date stated. A sign off that covers a whole range in one line, without per model notes, hides a boundary model that was not checked. A per model sign off allows a boundary model to be identified and reviewed separately. The sign off file should be retained with the conformity evidence, so that a later authority query about a category can be answered from the sign off, not from a reconstruction.

What follows classification in the sequence?

What follows classification is supplier data collection, using templates tied to the field catalogue for the category, with field level tracking, verification and escalation. Supplier data take the longest time to obtain and verify, so collection should start immediately after classification, in parallel with identifier and carrier design where the design does not depend on supplier data. A programme that leaves supplier collection to the end will compress verification into the period before placing, when correction takes longest. Supplier collection evidence should show, per model and per supplier, which fields are complete, verified and outstanding.

Worked check: a programme collects supplier data for three models in parallel, with field tracking showing one model complete, one model with two fields outstanding, and one model with a supplier change pending. The programme holds the two incomplete models at the data gate, while the complete model proceeds to identifier and carrier testing. A programme without gates would proceed with all three models, and the incomplete models would fail at passport creation, when the missing fields are discovered. Gates prevent late discovery by holding incomplete work at the step where it belongs.

How are identifier, carrier and access designed?

Identifier, carrier and access design follow the data structure, because the identifier must resolve to the passport, the carrier must encode the identifier, and access tiers must control the fields in the data structure. Identifier design covers formation, allocation control and registry interaction. Carrier design covers printing, placement, durability and scan testing. Access design covers the tier map, interest verification, update rights and continuity arrangements. Each design should be documented, with the standard, vocabulary and rule relied on, and each design should be tested before placing.

Design testing should include a scan test with a standard device, a registry interaction test where the registry route is available, an access test for each actor type, and a continuity test for the hosting arrangement. A design tested only in the vendor system, without external scan and access tests, has not been tested as a whole. The combined test, carried out on sample batteries, is the readiness evidence for the design step, and the test result should be filed with the design documents.

How is the system tested as a whole?

The system is tested as a whole through an end to end test that follows a sample battery from classification, through data collection, identifier allocation, passport creation, carrier printing, registry interaction, placing, repair update and authority access, with each step recorded and each handover checked. The end to end test proves that the steps work together, not only that each step works alone. A programme with strong individual steps but weak handovers will fail the end to end test at a handover point, such as the handover from supplier data to passport creation, or from passport creation to carrier printing.

End to end testing should use real model data, real supplier data in the operator format, and real actor roles, with the test batteries identified and the test results filed. A test with vendor sample data will pass on sample data and fail on operator data. A test with operator data will reveal the format, vocabulary and access issues that sample data hide. The test should be repeated after any change to the data structure, the identifier system or the access design, with the repeat test dated.

What is the placing gate?

The placing gate is the final check before a battery is placed on the market, covering classification, data completeness, identifier resolution, carrier scan, access tier correctness, declaration and CE marking, and registry confirmation where the registry route applies. The gate should be a checklist, with each item evidenced and signed off, and with a hold where any item is open. A placing without a gate, or with a gate that can be bypassed, will place batteries with open items, and the open items will be discovered by a customer, a repairer or an authority, rather than by the operator.

Gate evidence should be filed per placing batch, with the batch identifiers, the checklist, the checker and the date. A batch file without identifiers cannot show which batteries passed the gate, and a batch file without a checker cannot show who approved the placing. The gate file should be retained with the conformity evidence, so that a later query about a placing can be answered from the gate file. The gate should be reviewed after the first placings, with the review dated, so that the gate itself improves with experience.

How is readiness maintained after the milestone?

Readiness after the milestone is maintained by change control, periodic access and resolution testing, supplier data review, and delegated act and guidance review, with the readiness file updated after each change. As checked on 28 October 2026, readiness is a continuing state, not a project that ends on the milestone date, and the sequence should be reused for each new model, each new supplier and each new life stage, with the same gates and the same evidence discipline. This guide gives general educational information only and is not individual legal advice. A reader with a specific battery or market decision should check the current Regulation text and any applicable delegated act, as checked on 28 October 2026, before acting.

This guide gives general educational information only and is not individual legal advice. A reader with a specific battery or market decision should check the current Regulation text and any applicable delegated act, as checked on 28 October 2026, before acting. Readiness is evidenced step by step, and the placing gate should hold any battery with an open item.