How Do Conformity and Passport Accuracy Differ?

Conformity and passport accuracy are related but distinct duties, and confusing them creates two errors: treating a correct passport as proof of conformity, and treating a conformity certificate as proof of passport accuracy. Conformity is the assessment that a battery meets the sustainability, safety, labelling and information requirements, evidenced by technical documentation, testing, declaration and CE marking. Passport accuracy is the duty that the passport record correctly and currently states the Annex XIII information for the individual battery, under the access tiers and updating rules. A battery can be conforming with an inaccurate passport, and a battery can carry an accurate passport while failing a conformity requirement.

The distinction matters at every check. A market surveillance authority checks both conformity and passport accuracy, and a finding on one does not automatically prove a finding on the other. An operator who corrects a passport field without checking the conformity file, or who corrects a conformity file without updating the passport, leaves one duty unaddressed. The two duties should be checked together, with a cross check that compares the conformity file and the passport record for the same battery, before placing and after any change.

What does conformity prove?

Conformity proves, through assessment, documentation, testing and declaration, that a battery model meets the requirements in the articles that apply to it, for the module and procedure followed. Conformity is assessed at model and production level, with the declaration covering the battery model as placed on the market. Conformity evidence includes test reports, quality system records and notified body certificates where the module requires them, and the evidence must cover the battery model and variant as placed. A conformity finding for one model does not prove conformity for a different model, even when the models share components.

A conformity check should map each requirement to a test, a report and a declaration statement, with the mapping filed as a test matrix. A matrix that lists tests without requirements, or requirements without tests, leaves a gap that a reviewer must fill by inference. A complete matrix allows a reviewer to check, requirement by requirement, that assessment was carried out. The matrix should be updated when a requirement, a test method or a model variant changes.

What does passport accuracy require?

Passport accuracy requires that each Annex XIII field for the individual battery is correct, current and complete for the access tier, that the identifier resolves to the correct battery, that the carrier links to the correct record, and that updates are carried out under the updating rules. Accuracy is judged at individual battery level, not only at model level, because individual data, use history and status changes differ between batteries of the same model. A passport that correctly states model data but incorrectly states individual data, or that states outdated status after a repair or life stage change, is inaccurate for that battery.

Worked check: two batteries of the same model are placed on the market. Both share the same conformity file and declaration. One battery carries a passport with the correct unique identifier and current status, the other carries a passport with a duplicated identifier from the first battery. The conformity position is the same for both; the passport accuracy position differs, and the second battery fails the passport duty. A check that examines only the conformity file would miss the passport failure, because the failure is at individual record level.

How are the two duties checked together?

The two duties are checked together through a cross check that compares the conformity file and the passport record for the same battery, covering manufacturer, model, identifier, chemistry, capacity, notified body information, declaration reference and status. The cross check should be carried out before placing, after any design, supplier or passport update, and on a sample basis during surveillance readiness reviews. A cross check that compares only the model name, without identifier and status, misses the individual level errors that passport accuracy is designed to catch.

Cross check evidence should be filed as a dated check sheet, with the battery identifier, the fields compared, the result per field and the checker named. A check sheet without a checker or a date cannot be audited, and a check sheet without per field results cannot show which field was checked. The sheet should be retained with the conformity and passport evidence, so that an authority can see that the two duties were checked together, not in isolation.

What happens when the two records disagree?

When the conformity file and the passport record disagree, the disagreement should be treated as a record incident, with placing held until the disagreement is resolved and the correct record identified. The incident file should state the fields in disagreement, the source evidence for each record, the resolution, and the correction carried out in the incorrect record. A disagreement resolved by editing one record to match the other, without checking the source evidence, can perpetuate an error from the incorrect record into the correct one. The resolution must be based on source evidence, such as test reports, manufacturing records or supplier declarations, not on matching for its own sake.

Incident handling should include a root cause check, to determine whether the disagreement arose from a data entry error, a mapping error, a version error or a process gap. A root cause check that finds a mapping error, for example, should lead to a mapping correction and a check across all records that used the mapping. A correction without a root cause check will recur when the same mapping is used again. The incident file should record the cause and the process change, with dates.

Who is responsible for each duty?

Responsibility for conformity sits with the manufacturer, with notified body involvement where the module requires it, and with importer and distributor duties for checking and cooperation. Responsibility for passport accuracy sits with the economic operator who places the battery on the market or puts it into service, under Article 77, with authorised operators acting on behalf of that operator under the limits in Article 78. The two responsibilities can sit with the same operator, but they are distinct duties, and a contract with a vendor or a supplier does not transfer either responsibility. An operator who delegates passport hosting to a vendor remains responsible for passport accuracy, and an operator who delegates testing to a laboratory remains responsible for conformity.

Responsibility mapping should list each duty, the responsible operator, any authorised actor, and the evidence that the responsible operator holds. A mapping that lists only the vendor or laboratory, without the responsible operator, misstates responsibility. A mapping with the responsible operator and the authorised actor, with the authorisation and its limits, shows the correct allocation and allows an authority to direct a request to the responsible operator.

How are both duties maintained through life?

Both duties are maintained through life by change control that updates the conformity file and the passport record together, with a change event triggering a review of both records. A design change, a supplier change, a repair, a life stage change or a delegated act change can affect one or both records, and the change procedure should require a check of both. As checked on 28 October 2026, the updating rules for passports depend in part on acts under Article 77, so the change procedure should carry a review date tied to those acts. 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. The two duties should be cross checked together, and a disagreement should be resolved from source evidence, not by matching records.