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Readiness Test Plan for the Battery Passport

A readiness test proves that scope, data, system, carrier and roles are all ready, on the same date, before the duty applies.

GUIDE / IMPLEMENTATION & READINESSIDENTITY → INFORMATION → EVIDENCE

A readiness test plan proves that scope, data, system, carrier and roles are all ready, on the same date, before the passport duty applies, by testing the whole preparation together, rather than testing each element separately and assuming that the elements will work together. Readiness is a state of the whole preparation, not a property of one element, and an operator can have a ready system, ready data and ready roles, yet still be unready because the system cannot read the data, or the roles do not cover the carrier test. The readiness test therefore follows a battery from scope decision to record reading, through every element, and records the result for each element and for the whole chain, with a single readiness conclusion dated to the test.

The scope is readiness testing for Article 77, for electric vehicle batteries, light means of transport batteries and industrial batteries over 2 kWh from 18 February 2027, as checked on 28 October 2026.

What does readiness cover?

Readiness covers scope and category decisions, data collection, record creation, identifier and carrier links, registry readiness, access tiers, roles and deputies, supplier routes and later update arrangements, each tested as part of the whole chain. The coverage should be recorded as a readiness register, with each element, its owner, its test and its result, so that a gap in any element is visible in the register. An element that has not been tested should be recorded as untested, not as ready, because an untested element cannot be relied on, and a register that records untested elements as ready overstates readiness. The register is the readiness evidence, and it should be kept with the pilot and roll out files.

How is the readiness test run?

The readiness test is run as a timed exercise, following a representative battery through the whole chain, from scope decision to independent record reading, with the testers recording the time, the result and the evidence for each step. The exercise should include a difficult case, such as a missing field, a carrier failure or a status change, because a test that includes only the easy path proves little about readiness for real operation. The test should be run by the roles who will operate the chain, not by the designers alone, because readiness belongs to the operators, and a chain that only its designers can operate is not ready. The test record should name the operators, the battery and the dates.

What pass and fail criteria apply?

Pass and fail criteria apply element by element and to the whole chain, with an element passing only where its test is complete and evidenced, and the whole chain passing only where every element passes and the chain test passes. A single element failure should fail the readiness conclusion, with the failure recorded, the remedy decided and the test repeated, rather than being waived as minor, because a minor failure in one element can block the whole chain in production. The criteria should be written before the test, so that the test cannot be judged by criteria invented after the result is known. A readiness conclusion without written criteria is an opinion, not a test result.

What does a readiness test table look like?

A readiness test table shows the element, the test and the result, with a single conclusion row. The table below uses general elements.

ElementTestResult
Scope and categoryRegister complete for pilot modelsPass or fail with evidence
DataMandatory fields supplied and checkedPass or fail with evidence
System and carrierCarrier resolves, tiers correctPass or fail with evidence
RolesOwners and deputies in placePass or fail with evidence
Whole chainBattery followed end to endReady or not ready

How are readiness failures remedied?

Readiness failures are remedied by recording the failure, deciding whether the remedy is a method change, a data fix, a system change or a role change, applying the remedy, and repeating the affected test and the whole chain test, with each step dated. A remedy that fixes the element but is not retested in the whole chain may leave a new break elsewhere, and a remedy that is applied without recording the cause will recur. The remedy record should therefore show the cause, the remedy, the retest and the whole chain result, linked together. Readiness should be declared only after the retest passes, and the declaration should be dated to the retest, not to the first test.

When should readiness be retested?

Readiness should be retested after any change to scope, data, system, carrier, roles or Regulation guidance, and at regular intervals before the duty date, because readiness decays as the preparation changes. A readiness test passed months before the duty date, with no retest after intervening changes, is stale evidence, and a later reader should treat it as such. The retest schedule should be recorded in the readiness register, with the retest dates and the changes that trigger a retest stated, so that the register shows a living readiness state rather than a single historic pass. A living register is the practical outcome of the readiness plan.

What limits apply to a readiness test?

The limits are that a readiness test proves preparation, not compliance for every future 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 preparation should check the Regulation text as checked on 28 October 2026 before acting.

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.