Who is responsible for passport accuracy: the operator who places the battery on the market

Passport accuracy has a single responsibility point: the economic operator who places the battery on the market or puts it into service. That operator must ensure that the battery passport is accurate, complete and current, as Article 77 requires the passport to contain the information in Annex XIII and to be accessible through the data carrier. Other actors contribute data, hold evidence, maintain systems and append history, but contribution is not responsibility.

A supplier who provides a composition statement contributes. A system provider who hosts the record contributes. A repairer who appends a repair entry contributes. Responsibility for the accuracy of the record as a whole rests with the placing operator, who must obtain, check and maintain the data, and who cannot delegate responsibility away by contract, by mandate or by system outsourcing.

Why is responsibility placed on the placing operator?

Responsibility follows the act of placing, because placing is the act that introduces the battery to the Union market and that triggers the passport duty. The placing operator is the actor who decides that the battery is ready for the market, who holds the declaration of conformity, and who can be identified and held to account by a market surveillance authority. A system that placed responsibility on a supplier outside the Union, on a software provider, or on a downstream actor would leave the authority without a Union actor to address, and would leave a reader without a person to approach for correction. The placing operator may be the manufacturer, where the manufacturer places directly, or the importer, where the battery is imported, or another operator who places a remanufactured or modified battery. The identity of the placing operator depends on the chain, and the record should allow a reader to identify that operator from the manufacturer and importer information, without needing to reconstruct the whole chain.

What does accuracy mean for a passport record?

Accuracy means that each field states the correct value, with the correct scope, method and date, for the correct battery model and unit, in the correct tier, at the version current for that unit. Accuracy is not a general impression that the record looks right. It is a field by field property, tested by the evidence trace and the completeness check. A record can be accurate in identity and inaccurate in carbon data, accurate in model data and inaccurate in unit history, accurate in the public tier and inaccurate in the authorised tier. Responsibility covers all of those dimensions, because the placing operator must ensure the record as a whole, not only the fields the operator originated. Where a field is supplied by another actor, the placing operator must check the field to the extent the operator can, and must not place the battery where a material field is missing, mismatched or unverifiable.

How is accuracy maintained over time?

Accuracy is maintained through version control, correction discipline, and history appending. Version control ensures that model revisions are recorded with effective dates and that units link to the correct version. Correction discipline ensures that a wrong value is corrected as a version event, with the prior value retained in history, rather than silently overwritten. History appending ensures that unit events, repairs, status changes and measurements are added in date order, with sources, so that the record stays current as the battery is used. The placing operator must ensure that the systems and contracts that support those processes are in place: supplier evidence agreements, system provider arrangements, and repairer and service routes for history appending. A placing operator who has no route for history appending cannot maintain accuracy over life, because the record will freeze at placing while the battery continues to change.

What happens when data is supplied by another actor?

Data supplied by another actor, such as a cell supplier, a material supplier, a test laboratory or a system provider, must be checked for match: same model, same plant where relevant, same period, same method. The placing operator should record the source of each field in the register, so that a later check can trace the field to its source. Where supplied data is found to be wrong, the placing operator must correct the record, inform affected downstream actors where required, and address the supplier cause. A contract term that states that the supplier warrants the data does not remove the placing operator’s responsibility to the market and to authorities, although it may give the operator a contractual remedy against the supplier. The reader of a passport should not need to know the contract position. The reader needs to know that the placing operator stands behind the record.

What does the responsibility table summarise?

What limits apply to responsibility claims?

A statement that an operator is responsible for passport accuracy does not state that the operator performed every measurement, that every supplier was audited, or that the battery is compliant. Responsibility is a duty to ensure accuracy, not a guarantee that no error will ever occur. Errors are corrected through the version and correction discipline described in the requirements cluster. This guide gives general educational information only and does not give legal advice for a particular operator, battery or transaction.