How Do Withdrawal and Recall Interact With the Passport?

Withdrawal and recall interaction covers how a battery is removed from the distribution chain, how end users are reached where a recall is required, and how the passport record is treated when a battery is withdrawn or recalled. Withdrawal and recall are distinct measures with distinct audiences: withdrawal addresses distributors and the supply chain, recall addresses end users who already hold the battery. The passport record must reflect the measure, so that a withdrawn or recalled battery is not presented as available, and so that a battery returned through recall is routed to the correct treatment or correction route.

Interaction planning matters because a withdrawal that does not reach the passport, or a recall that does not reach the collection route, leaves a gap in which a battery can be resold, reused or disposed of through the wrong stream. A withdrawn battery with a live passport that shows no status change can be sold again by a distributor who did not receive the withdrawal notice. A recalled battery handed to a collection point without a recall identifier can be treated as ordinary waste, without the correction or treatment that the recall requires. The record and the physical measure must move together.

What is withdrawal?

Withdrawal is a measure aimed at preventing a battery in the supply chain from being made available on the market, by removing it from distributors, retailers and warehouses. Withdrawal is ordered or undertaken where a battery is non-compliant or presents a risk, and where the battery has not yet reached, or can still be intercepted before reaching, end users in significant numbers. The operator must inform distributors, provide instructions for holding, returning or correcting the battery, and verify that the withdrawal has been carried out. The authority verifies the withdrawal through distributor checks and, where needed, sample checks.

A withdrawal file should list the battery models, batches and identifiers affected, the distributors notified, the instructions given, the quantities held and returned, and the verification result. A file that lists only the instruction, without distributor responses and quantities, cannot show that the withdrawal was carried out. A file with distributor responses and quantities, reconciled against the quantities placed, shows the scope of the withdrawal and any gap that remains.

What is recall?

Recall is a measure aimed at achieving the return of a battery that has already been made available to end users, where the battery presents a risk or where withdrawal alone does not address the risk. Recall requires communication to end users, a return route, handling and storage arrangements for returned batteries, and a treatment or correction route for the returned units. End user communication must be clear, accessible and actionable, stating the risk, the action to take, the return route and the contact point, without minimising the risk or overstating the action required.

Worked check: a battery with a safety nonconformity has reached end users through retail. Withdrawal alone, directed at retailers, would leave the end user batteries in use. Recall is required, with end user communication, a return route through retailers and collection points, and a handling procedure for damaged or at risk batteries. A second battery with a labelling error, held mainly in warehouses, can be addressed by withdrawal and correction, without a recall, because end user exposure is limited and the risk does not require return. The distribution stage and the risk decide the measure.

How does the passport record change on withdrawal or recall?

On withdrawal or recall, the passport record should reflect the status change in the fields available to the relevant tiers, so that a later actor does not treat the battery as available for sale or use. The status change should state the measure, the date, the scope and the handling instruction, with the original passport history preserved. A passport that continues to show a withdrawn battery as available, or a recalled battery as in normal use, misleads a distributor, repairer or buyer who checks the record after the measure. The update should be carried out under the updating rules, with the authority measure referenced where the measure was required by an authority.

Status updating should be tested by scanning the carrier for a sample withdrawn battery and confirming that the returned status shows the measure. A test carried out only in the internal system, without a carrier scan, does not prove that an external actor will see the status change. The test result should be filed with the withdrawal or recall file, with the sample identifiers and the scan result recorded. A status change that is recorded internally but not visible externally has not achieved its purpose.

How are distributors and end users informed?

Distributors are informed through a withdrawal or recall notice that states the battery identification, the reason, the risk where applicable, the action required, the timetable and the contact point, with a confirmation of receipt and action required from each distributor. End users are informed through communication channels that reach the holders of the battery, including retailer notices, direct communication where the holder is known, and public notices where the holder base is dispersed. Communication must be in a language and form that the audience can understand and act on, and must not require the holder to carry out a technical assessment to understand the action.

Communication records should include the notice text, the channels used, the dates, the distributor confirmations and the end user response rate where measurable. A communication file with only the notice text cannot show reach. A file with channels, dates and responses shows whether the message reached the audience, and where a gap remains. A gap in reach should trigger a further communication round, with a different channel, rather than being treated as a completed measure.

What happens to returned batteries?

Returned batteries are handled under the safety and treatment procedures that apply to the battery condition, with damaged or at risk batteries stored and transported separately, and with the return route recorded by identifier. Returned batteries that can be corrected are corrected under the corrective action plan, with retest and reissue where required. Returned batteries that cannot be corrected are treated as waste batteries and routed to permitted treatment and recycling, with the consignment and treatment records filed. A returned battery must not be resold, reused or repurposed without a new assessment and a new life stage record where the Regulation requires it.

Return handling should be recorded per identifier, with the return date, the condition on return, the route taken and the outcome. A return record that lists only total quantities cannot show whether a specific battery was corrected, treated or lost in the return chain. A per identifier record allows the withdrawal or recall file to be reconciled: quantities placed, quantities returned, quantities corrected, quantities treated, and quantities still outstanding. The reconciliation is the closure evidence for the measure.

How is a withdrawal or recall closed?

A withdrawal or recall is closed when the quantities have been reconciled, the passport status has been updated and verified, the corrective or treatment route has been completed, and the authority has verified the measure where the authority required it. Closure should be recorded as a closure pack, with the measure, the scope, the reconciliation, the status verification and the authority result. As checked on 28 October 2026, closure without authority verification, where the authority set the measure, is incomplete, and the file should remain open until that verification is recorded. 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 physical measure and the passport status should move together, and closure should be evidenced by reconciliation.