Data Collection Implementation Plan for the Battery Passport

A data collection implementation plan for the battery passport works field by field, with the legal source, the supplier or system that supplies the field, the format, the quality check and the gap handling stated for each Annex XIII field by category. The plan is the bridge between the Regulation and the record, because a record system without a field plan will collect data in general terms and will fail on the specific fields that the Commission guidance marks as mandatory for a given category. The plan should be built from the Commission guidance on data points by category, which sets out the data points for electric vehicle, light means of transport and industrial batteries, and states for each point whether it is mandatory, optional, conditional or not required as of 18 February 2027.

The scope is data collection for Annex XIII, as checked on 28 October 2026. The plan states no system, platform or vendor, and no claim about the completeness of the Commission guidance for any particular model.

How are fields listed by category?

Fields are listed by category by taking the Commission data points guidance and creating a separate field list for electric vehicle batteries, for light means of transport batteries and for industrial batteries over 2 kWh, with each field marked mandatory, optional, conditional or not required for that category as of the duty date. A single field list for all categories will overcollect for some categories and undercollect for others, because the guidance marks fields differently by category, and the plan should reflect those differences. Each field list should state the legal source for the field, so that a later reader can see why the field is collected, and should be reviewed when the guidance or the Regulation changes. The category lists are the controlled documents that the rest of the plan serves.

What source is recorded for each field?

The source recorded for each field is the supplier, the internal system or the test that supplies the field, named specifically, with the contact or system owner and the supply timing stated. A field whose source is recorded only as supplier, without naming the supplier, is an unsourced field, and a field whose source is recorded only as internal, without naming the system, is equally unsourced. The source record should also state the format in which the field arrives, because a field that arrives as a free text note cannot be checked in the same way as a field that arrives as a structured value with a unit. Source and format together decide whether the field can be quality checked, and a field without a source and format record should be flagged as a gap.

What quality check applies to each field?

The quality check for each field is the test that proves the field is present, in the correct format, in the correct unit, within the expected range and consistent with related fields, with the checker and the date recorded. A capacity field, for example in general terms, should be checked for unit, for consistency with the model specification and for consistency with the labelling, while a date field should be checked for format and for sequence with other dates. Quality checks should be run on every record, not on a sample, where the number of records allows it, and on a defined sample with a defined method where the number does not. A quality check that is not recorded is a check that cannot be relied on later.

What does a data plan table look like?

A data plan table shows the field, the source, the format and the check in one row, so that a missing element is visible at a glance. The table below uses illustrative field types, without listing the full Annex XIII field set.

How are gaps and missing fields handled?

Gaps and missing fields are handled by recording the gap, naming the field, the battery and the source, requesting the data, recording the response and the follow up date, and pausing record creation for that battery until the mandatory field is supplied or the field is confirmed as not required for that category. A gap that is filled by assumption, by copying a value from another model or by leaving the field blank without a gap record, creates a record error that a later check will find. The gap register is a controlled document, reviewed at regular intervals, with gaps closed only by evidence, not by the passage of time. A gap register that is reviewed and acted on is a strength of the data plan, not a weakness.

How is data updated over life?

Data is updated over life by adding later use information under the same identifier, preserving earlier entries, dating each update, and recording the source and method for each update, so that the record reads as a dated sequence rather than as a single current statement. Updates include state of health entries, status changes, repair and refurbishment entries and transfer entries, each with its own date and source. An update that overwrites an earlier entry without preserving it breaks the history, and an update without a date cannot be placed in sequence. The update discipline is the same as the collection discipline, applied over time, and the data plan should state who may update, what evidence an update needs and how the update is checked.

What limits apply to a data collection plan?

The limits are that a data plan is a preparation method, and it does not prove that any particular record is complete or accurate. This guide gives general educational information only and is not individual legal advice. An operator with a specific model should check the Regulation text and the Commission guidance as checked on 28 October 2026 before acting.