A built-in battery fulfilment record is a handling record kept by a fulfilment provider for a product with a battery incorporated into the product at manufacture, where the battery is subject to a battery passport under Regulation (EU) 2023/1542. It traces warehousing, packaging and dispatch for the product as received, stored and sent on. It applies to a provider that stores, packs or dispatches such a product in a commercial activity without owning the product or placing the product on the market.
A built-in battery is a battery incorporated into an appliance or another product so that the battery forms part of that product, rather than a battery supplied on its own for insertion by a user. The record in this guide is the provider handling record for that incorporated case: the product identifier, the battery link, the storage location, the packing check and the dispatch handover, held together so a product can be traced to the stock from which it was picked. This guide does not cover the battery passport itself, the passport data held by the responsible operator, or the conformity assessment for the battery or the product.
What is a built-in battery in a fulfilment record?
A built-in battery changes the object of the fulfilment record. For a standalone battery, the record object is the battery. For a built-in battery, the record object is the product that contains the battery, and the battery enters the record through a link to that product. The battery link is an identifier link, not a restatement of passport data: the product identifier as marked on the product or its packaging, together with the battery identifier or batch reference as supplied. Where the identifier is not visible without opening the product, the record states that position plainly instead of recording a guessed identifier.
What does the fulfilment record contain?
The record is a set of linked entries for receipt, storage, packing and dispatch, held under the product identifier. Each entry names the role that made the entry, the object handled, the evidence checked and the date of the entry. A missing entry is a gap in the trace.
| Record entry | Content held | Check that closes the entry |
|---|---|---|
| Receipt | Product identifier, battery link as supplied, owner reference, date of receipt | Identifier matched to the delivery note and to the marking on the product |
| Storage | Warehouse location, storage condition note as stated for the product, product identifier, battery link | Location recorded at put-away and checked at pick |
| Packing | Product identifier, battery link, check for marking, data carrier readability and accompanying information | Carrier checked as readable before sealing, and information included where required |
| Dispatch | Product identifier, battery link, destination reference as supplied, carrier handover reference, date of dispatch | Parcel identifier matched to the picked product before handover |
| Return or hold | Product identifier, battery link, reason for return or hold, date, location of held stock | Returned product segregated from saleable stock under a hold note |
A record entry that records only that a parcel left a warehouse, with no product identifier and no battery link, does not trace a built-in battery.
How do warehousing records differ for a built-in battery?
Warehousing records track the product through storage, and the battery follows the product through that same location record. Storage conditions in the record are the conditions stated for the product, recorded as stated, rather than conditions invented for the battery alone. A location record that moves a product without moving its battery link creates a split record: the product can be found, but the battery inside it cannot be shown. The storage entry therefore carries the product identifier and the battery link together at put-away, at any internal move and at pick. A pick must be checked against the product identifier for the order, not against appearance alone, because products that look alike can contain different batteries.
What does a packaging record show for a built-in battery?
A packaging record shows that the product was packed without obscuring or damaging the route to the passport record. That route is normally a data carrier on the product or its packaging, and the packing check records whether the carrier was readable before sealing. Where the carrier sits on the product inside sealed packaging, the packing record states that position and records the carrier check on the outer packaging as supplied, rather than claiming a check that could not be made without opening the product. Where information is required to accompany the product, the packing entry records that the information was included in the parcel. Repackaging must preserve the product identifier, the battery link and the accompanying information together.
What does a dispatch record show for a built-in battery?
A dispatch record shows the handover of an identified product to a carrier, with the product identifier and the battery link carried into the dispatch entry. That entry must allow a dispatched product to be matched back to a receipt entry and a storage entry. A dispatch entry that matches a parcel identifier to an order reference, but not to a product identifier, cannot make that match. The carrier handover reference, the destination reference as supplied and the date of dispatch complete the entry, and each field is recorded as supplied or as observed at handover, not inferred after dispatch.
How does the provider record link to the placer record without replacing it?
The placer record and the provider record are different records with different owners. The placer is the operator that places the product on the market, and the placer holds responsibility for the battery passport and for passport accuracy. The provider record is a handling record: it shows where a product was stored, how it was packed and when it was dispatched, and it points to the placer record through the product identifier and the battery link. The provider record does not create passport data, does not correct passport data and does not stand in place of the placer record where a passport question arises. A fulfilment provider does not become the placer by storing, packing or dispatching a product with a built-in battery.
What happens on a return, damage or hold for a built-in battery?
A return of a product with a built-in battery is recorded as a product return, not as a battery return, because the battery remains incorporated in the product. The return entry records the product identifier, the battery link as recorded at dispatch, the reason for return as stated by the returner or the carrier, the date of return and the location of the returned product. A returned product is segregated from saleable stock under a hold note stating the reason, the date and the product identifier. A product with a damaged outer package, a damaged data carrier, missing accompanying information or signs of opening is held, not dispatched, and the hold entry records the observed condition as observed, without a diagnosis of the battery inside. A provider must not remove a built-in battery from a returned or damaged product to inspect it, repair it or make it saleable, because removal changes the product and breaks the incorporated link that the record traces.
What does a worked record look like?
The worked record below uses placeholder values labelled illustrative. The values are not measurements from a real product and not identifiers from a real battery.
| Entry | Illustrative value |
|---|---|
| Product identifier | ILLUSTRATIVE-PRODUCT-IDENTIFIER |
| Battery link as supplied | ILLUSTRATIVE-BATTERY-LINK |
| Receipt | Identifier matched to the delivery note, date recorded as ILLUSTRATIVE-DATE |
| Storage | Location recorded as ILLUSTRATIVE-LOCATION, identifier and battery link carried together |
| Packing | Carrier checked as readable before sealing, information included as supplied |
| Dispatch | Parcel matched to the picked product, handover recorded as ILLUSTRATIVE-HANDOVER |
| Return | Returned product segregated under a hold note, identifier and battery link carried from dispatch |
A record that changes the identifier between entries or drops the battery link at packing is not traceable, even where each entry looks complete on its own.
What gaps break the trace for a built-in battery?
A missing battery link at receipt leaves every later entry without a battery reference. A location move without a location record leaves the product findable only by searching the warehouse. A packing check claimed without a check leaves the carrier route unverified. A dispatch entry without a product identifier leaves a return unmatchable. A return mixed with saleable stock leaves a later dispatch unverifiable. The remedy for each gap is a correction at the point of failure, not a reconstruction after dispatch: a missing link is checked at receipt, a packing gap is resolved by a fresh check before sealing, and a dispatch gap is resolved by matching the parcel to the picked product before handover.
What limits apply to a built-in battery fulfilment record?
A fulfilment record states handling facts for a product with a built-in battery. It does not state conformity for the battery or the product, does not create or correct passport data, and does not make the provider the placer. This guide gives general educational information only, not individual legal advice, and the current Regulation text and any applicable delegated or implementing act should be checked before acting on a specific product, battery or transaction.
Sources & further reading
Source links point to primary materials and further reading, including commercial implementation resources where cited. This introductory guide does not replace the legislation.