Manufacturer Implementation Checklist for the Battery Passport

A manufacturer implementation checklist for the battery passport organises preparation in the order in which decisions must be taken, starting with scope and category, moving through data collection and record design, and ending with a pilot record that is tested before the duty date. The checklist is a method for a manufacturer that places batteries on the EU market, and it covers the passport duty in Article 77 for electric vehicle batteries, light means of transport batteries and industrial batteries over 2 kWh from 18 February 2027. A checklist that starts with software selection, without first settling scope and category, will build a record system for batteries that may not need a passport, or for categories that the system does not model correctly.

The scope is manufacturer duties under Regulation (EU) 2023/1542, read as checked on 28 October 2026. The checklist states no software, platform or vendor recommendation, and no qualification claim.

What scope and category decisions come first?

Scope and category decisions come first, because they decide which batteries need a passport, which data each battery needs, and which access tier applies to each field. The manufacturer should list every battery model, classify each model under Article 3, record the capacity for industrial models, record the placing date pattern, and record the Article 1 scope reading for any specialist model, with the wording relied on. The list should be kept as a controlled register, with a named owner and a review date, because a model list that is not controlled will drift as new models are added and old models are changed. A controlled list lets the rest of the checklist be scoped model by model, rather than applied in general to the whole catalogue.

What data must be collected for Annex XIII?

Data for Annex XIII must be collected model by model and battery by battery, with model information collected once per model and individual information collected per battery, including information resulting from use. The collection should follow the Commission guidance on data points by category, which sets out the data points relevant to 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. A data collection template built from that guidance, with the legal source for each field, the supplier or system that supplies the field, and the quality check for the field, is the core implementation document, and it should be tested on one model before it is rolled out to every model.

How is the record system designed?

The record system is designed around unique identifiers, access tiers, data carriers and retention, with each design choice recorded and tested. Unique identifiers must distinguish model from individual battery, and must survive the life of the battery, including changes of holder and changes of status. Access tiers must separate public, legitimate interest and authority information as Annex XIII requires, with the access route for each tier tested. Data carriers must resolve to the individual record, and the resolution must be tested at manufacture, at handover and at collection. Retention must cover the life of the battery and the period that the Regulation requires after the battery ceases to exist as a battery, as the record system design states. Each design choice needs a test, not only a specification.

What does a manufacturer checklist table look like?

A manufacturer checklist table shows the stage, the output and the test that proves the stage is complete. The table below uses general stages, without naming any system or vendor.

What roles and ownership are needed?

Roles and ownership are needed for scope decisions, data collection, record creation, quality checking, carrier testing and later updates, with a named owner for each role and a deputy for each owner. The role map should state who decides a category, who supplies each data field, who checks the data, who creates the record, who tests the carrier and who updates the record after placing, because a record system without named owners will fail at the first handover. The role map is described in detail in the internal roles guide in this cluster, and the manufacturer checklist should cross refer to that map rather than duplicating it. Ownership without a deputy is a single point of failure, and the checklist should flag any role with no deputy.

How is the pilot record tested?

The pilot record is tested by creating a complete record for one model and one individual battery, and then having a reader who did not create the record read it in the identity first order, checking identifier match, tier access, carrier resolution, date sequence and field completeness. The test should include a scan of the carrier, a read of each tier by a reader entitled to that tier, and a check that the record describes the battery that was manufactured. Failures found in the pilot should be recorded, fixed and retested, rather than noted for later, because a pilot that is allowed to pass with known failures will set the standard for every later record. The pilot file, with its test results, is the evidence that the system works.

What limits apply to a manufacturer checklist?

The limits are that a checklist is a preparation method, not a conformity assessment, and it does not prove that any particular battery complies. This guide gives general educational information only and is not individual legal advice. A manufacturer with a specific model should check the Regulation text and the Commission guidance as checked on 28 October 2026 before acting.