SME Implementation Sequence for the Battery Passport

A small and medium sized enterprise, shortened to SME in this guide, implements the battery passport in small, dated steps, with scope and category decisions first, a single pilot record second, and system and supplier decisions only after the pilot proves the method. The sequence is proportionate because an SME cannot staff a large programme, and a sequence that starts with a system purchase will consume the budget before the scope question is answered. The SME sequence in this guide therefore treats time, money and attention as limited resources, and spends them in the order that reduces risk most, namely scope, data, pilot, then system. The passport duty is the same for an SME as for a large operator where Article 77 applies, and proportionate preparation does not mean a lighter duty.

The scope is SME preparation 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. The guide states no funding, grant or support scheme, and no vendor recommendation.

What is the first step for an SME?

The first step for an SME is a scope and category list, covering every battery model placed on the EU market, with the Article 3 category, the capacity for industrial models, the placing pattern and the Article 1 scope reading recorded for each model. The list can be a simple controlled document, kept by one named owner, with a review date, and it does not need a system to be useful. The value of the list is that it decides, model by model, whether a passport is needed, and it prevents the SME from preparing for every model as if every model needed the same record. A list that is completed and reviewed is a stronger foundation than a system that is bought before the list exists.

What data can an SME collect first?

An SME can collect first the model data that the SME already holds, namely manufacturer identity, model identifier, category, chemistry, capacity and related model facts, together with the supplier data that the SME can obtain by asking suppliers for the Annex XIII fields by category. The collection should use a simple template based on the Commission data points guidance, with the field, the source and the status recorded for each model, and with missing fields flagged as gaps rather than filled by assumption. An SME should ask suppliers early, because supplier data takes time, and should record the request, the response and the follow up date for each supplier, so that a missing field is a tracked gap, not a forgotten question.

How does an SME run a pilot record?

An SME runs a pilot record by creating a complete record for one model and one battery, using the template, the identifier scheme and the carrier arrangement that the SME intends to use, and then having a reader who did not create the record read it in the identity first order. The pilot should be small, dated and documented, with the failures recorded and fixed before the method is rolled out. A pilot that succeeds on one model proves the method, while a pilot that fails on one model reveals the failure cheaply, before the method is applied to every model. The pilot file, with its test results, is the evidence that the SME method works, and it is also the training material for the staff who will operate the method.

What does an SME sequence table look like?

An SME sequence table shows the step, the output and the time order, so that the SME can see the whole sequence on one page. The table below uses general steps, without stating durations, because durations turn on the number of models and suppliers.

When should an SME choose a system?

An SME should choose a system only after the pilot, when the data template, the identifier scheme, the tier arrangements and the carrier arrangement are known, because a system chosen before those decisions will be chosen on general claims rather than on the SME needs. The system choice should be tested against the pilot record, by asking whether the system can create, store, update and resolve the pilot record, with the correct tiers, and whether it can do so for the number of models and batteries that the SME handles. A system that cannot reproduce the pilot record is the wrong system, however strong its general claims, and a system that can reproduce the pilot record should then be tested on a second model before purchase. The pilot is the selection test.

What help should an SME seek, and when?

An SME should seek help early for scope and category questions, for data template design and for record system testing, rather than seeking help only when a deadline is near, because early help shapes the method while late help can only review a method that is already built. Help can come from a trade body, a consultant, a notified body or a competent authority guidance document, and the SME should record the help sought, the advice received and the action taken, so that the file shows the reasoning. Seeking help is not a sign that the SME cannot comply, and a file that records help sought and acted on is stronger than a file that shows no help and no reasoning. The guide states no specific help provider and makes no recommendation.

What limits apply to an SME sequence?

The limits are that a proportionate sequence does not reduce the legal duty, and an SME that falls within Article 77 must meet the same passport duty as a larger operator. This guide gives general educational information only and is not individual legal advice. An SME with a specific model should check the Regulation text as checked on 28 October 2026 before acting.