Pilot Record Plan for the Battery Passport

A pilot record plan proves the whole passport method on one model and one individual battery, before the method is rolled out to every model and every battery, by creating a complete record, reading it independently, fixing the failures found, and recording the proof. The pilot is a method proof, not a production record, although the pilot record itself, if it is complete and accurate, can become a production record for that battery. The value of the pilot is that it tests scope, data, identifier, carrier, tiers and roles together, on a small scale, where failure is cheap and fixable, rather than testing each element separately and discovering at roll out that the elements do not work together. The passport duty in Article 77, from 18 February 2027, sets the date by which the pilot must have proved the method.

The scope is pilot planning for Article 77 records, as checked on 28 October 2026. The plan states no system, platform or vendor.

How is a pilot model chosen?

A pilot model is chosen to be representative, with a category that carries a passport duty, a supplier route that is typical, and a data set that includes a difficult field, so that the pilot tests the hard parts of the method as well as the easy parts. A model chosen because it is easy, with complete data and a simple supply chain, will prove little, while a model chosen because it is the hardest model will prove the method under stress but may take too long. The representative model sits between those extremes, with typical complexity and one difficult field, and the choice should be recorded with the reasons, so that a later reader can judge whether the pilot proved the method for the wider catalogue or only for an easy case.

What does a complete pilot record contain?

A complete pilot record contains the model information and the individual information for the pilot battery, as set out in Annex XIII, with the access tiers correctly applied, the unique identifier correctly linked, the data carrier resolving to the individual record, and the dates, sources and methods recorded for each entry. The record should be created through the intended production route, using the intended data template, identifier scheme, record system and carrier, rather than through a shortcut created only for the pilot, because a shortcut pilot proves the shortcut, not the production method. The pilot record file should be kept as the evidence of the pilot, with the test results attached.

How is the pilot record read independently?

The pilot record is read independently by a reader who did not create the record, in the identity first order, checking identifier match, model and category, tier access, carrier resolution, date sequence, field completeness and consistency with the specification and labelling. The independent reader should record each check with the date, the result and the evidence seen, and should raise failures as findings, with severity and remedy, rather than as general comments. A reading by the creator is not independent, because the creator knows what was intended and will read the record as intended rather than as written. Independence is the core of the pilot test, and the plan should protect it by naming the independent reader before the pilot begins.

What does a pilot plan table look like?

A pilot plan table shows the pilot stage, the output and the pass test, so that the pilot cannot be declared complete without evidence. The table below uses general stages.

How are pilot failures fixed?

Pilot failures are fixed by recording the finding, deciding the remedy, applying the remedy to the method as well as to the pilot record, and retesting the fixed method on the pilot record, with each step dated. A failure fixed only in the pilot record, without fixing the method that caused it, will recur in production, while a failure fixed in the method but not retested may not have been fixed at all. The fix record should therefore show the method change, the record change and the retest result, linked together. A pilot with no failures should be treated with care, because a pilot that finds nothing may have been read too lightly, and the independent reader should be asked to confirm that the reading was thorough.

When is a pilot ready for roll out?

A pilot is ready for roll out when the independent reading finds no open findings, when the method changes from the pilot are recorded, and when the roles, data routes and system arrangements that the pilot used are in place for the wider catalogue. Roll out should then proceed model by model, with the first production records read independently as a check that the pilot method transfers, rather than proceeding all at once. A roll out that proceeds all at once, without a check on the first production records, risks applying a pilot method that worked once to a catalogue where it fails. The roll out plan should state the model order, the check for each model, and the pause point where roll out stops if a model fails.

What limits apply to a pilot plan?

The limits are that a pilot proves a method, not compliance for every battery, and each production record still needs its own checks. This guide gives general educational information only and is not individual legal advice. An operator with a specific model should check the Regulation text as checked on 28 October 2026 before acting.