How Should an Operator Respond to a Surveillance Request?

A surveillance request response is the operator reply to a market surveillance authority request for information, documentation, samples or passport access, and the quality of the response determines how quickly the authority can complete its check. A complete, indexed, timely response allows the check to proceed on evidence, while a partial, late or unindexed response delays the check and creates an impression of non-cooperation, even when the underlying battery is compliant. Response discipline is therefore a conformity discipline, and it should be prepared before a request arrives, with roles, indexes and templates ready to use.

The response process is a controlled process, not an ad hoc search. A request arrives with a scope, a battery identification, a document list and a period, and the response must match that scope, with no missing documents, no extra documents that confuse the scope, and no contradictions between documents. A response assembled by several people without a coordinator, an index and a completeness check will miss documents and contradict itself. A coordinated response, with a single coordinator and a checked index, will match the scope and will be producible within the period.

What should happen when a request arrives?

When a request arrives, the operator should log the request, record the authority, the scope, the battery identification, the documents requested and the period set, and assign a single response coordinator. The coordinator should acknowledge the request, confirm the scope and period, and, where the scope is unclear, seek clarification promptly rather than guessing the scope. The request log should be retained with the conformity file, and the coordinator should be the single contact for the authority for that request, so that the authority receives consistent communication.

A request log without a coordinator, or with several contacts, will produce inconsistent communication and duplicated work. A log with a coordinator, a scope summary and a timetable allows the response to be planned, with document collection, review and submission steps scheduled within the period. The timetable should include a completeness check before submission, with time reserved for correction, so that a missing document found at the check stage can still be obtained within the period.

How is the response file assembled?

The response file is assembled from the conformity evidence index, with each requested document located, checked for currency and version, and listed in a response index that mirrors the request. Documents should be provided in the language required, in a legible form, with the version and date stated. Passport access should be provided under the authority tier, with the access route tested before submission. Samples, where requested, should be identified by battery identifier and batch, with the sample identity recorded in the index, so that the authority can link the sample to the file.

Worked check: an authority requests the declaration, technical documentation and passport access for a model. The coordinator assembles the declaration, the documentation contents list, the test reports and the passport access test result, with an index mirroring the request. The authority check proceeds without a further request. A second operator provides the declaration and a partial documentation file, without an index, and the authority must request the missing test reports and the passport access, delaying the check by weeks. The first response is complete on first submission; the second is not.

How are gaps and uncertainties handled in a response?

Gaps and uncertainties in a response should be disclosed explicitly, with the gap stated, the reason given, the document or information that will close the gap, and the date by which it will be provided. A gap disclosed with a plan is a manageable gap, and an authority can plan around it. A gap hidden by providing a similar but different document, or by omitting the item without explanation, will be discovered as a gap, and the discovery will damage the credibility of the whole response. Uncertainty about a requirement or a scope point should be raised as a clarification question, with the operator interpretation stated, rather than answered by assumption.

Gap handling should be recorded in the response index, with each gap numbered, dated and tracked to closure. A gap list that is not tracked will be forgotten after submission, and the authority will need to chase the missing item. A tracked gap list, with a closure date and a follow up submission, shows control and cooperation. The gap list should be retained with the response file, so that a later query about the response can be answered from the list.

What communication discipline applies during a check?

Communication during a check should be through the coordinator, in writing, with each communication dated and filed, and with no informal commitments made by other roles. The coordinator should confirm receipt of authority communications, confirm the action taken, and confirm submission dates, so that the authority has a clear record of the interaction. Oral discussions should be followed by a written confirmation, with the points agreed recorded. A communication record that relies on memory, or that is spread across inboxes, cannot be reconstructed if a later dispute arises about what was agreed.

Communication files should be kept with the response file, with the authority, the date, the subject and the outcome recorded per communication. A file without a communication log will be difficult to review, and a reviewer will need to search inboxes to reconstruct the interaction. A log with dates and outcomes allows the interaction to be followed in minutes, and it allows a new coordinator to take over the request without loss of context. The log should be updated after each communication, not at the end of the check.

What happens after the authority decision?

After the authority decision, the operator should record the decision, the findings, the measures required and the period set, and should implement the measures under the corrective action procedure, with progress reported as the authority requires. A decision that requires no action should be filed as a closure, with the decision and the response file retained. A decision that requires corrective action, withdrawal or recall should trigger the relevant procedure, with the decision referenced in the procedure file, so that the measure can be traced to the authority requirement that prompted it.

Decision handling should include a review of the findings from the check, with the root cause of any finding recorded, the process change implemented, and the check that the process change has been applied across models. A decision filed without a findings review will allow the same finding to recur on another model. A decision with a findings review, a process change and a cross model check shows that the check produced improvement, not only a response. The review should be dated and filed.

How should response readiness be maintained?

Response readiness should be maintained by keeping the conformity evidence index current, by testing passport access for the authority tier periodically, and by carrying out mock requests, with the mock result and corrections filed. As checked on 28 October 2026, readiness is a continuing state, not a project that ends when a file is created, and the readiness review should be scheduled annually or after any change to the evidence system, the passport system or the operator structure. 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. A complete response on first submission is the fastest route through a check, and readiness should be maintained by mock requests.