A supplier onboarding plan for battery passport data works field by field, with a written data route for each supplier, a pilot supply that tests the route, and a gap register that tracks missing fields until they are supplied with evidence. The plan is needed because passport data comes from several suppliers, each holding different fields, in different formats, on different timetables, and a record system that waits for data without a route will receive data late, in the wrong format or not at all. Onboarding is therefore a data discipline, not a purchasing exercise, and the plan should be owned by the data owner, not only by the purchasing function. The passport duty in Article 77, from 18 February 2027, sets the deadline that the onboarding plan must meet, model by model.
The scope is supplier data for Annex XIII, as checked on 28 October 2026. The plan states no supplier ranking, no vendor recommendation and no commercial terms.
How are suppliers mapped to fields?
Suppliers are mapped to fields by taking the category field lists from the data collection plan and assigning each field to the supplier or internal system that holds it, with the field, the supplier, the format and the supply timing recorded in a mapping document. A field with no assigned supplier is an unowned field, and a supplier with no assigned fields is an unmapped supplier, and both should be flagged in the mapping review. The mapping should be reviewed when a model changes, when a supplier changes or when a field list changes, because a mapping that is not reviewed will drift, and drift will appear as a missing field at record creation. The mapping document is a controlled document, with a named owner and a review date.
What does a written data route contain?
A written data route contains the field list, the format for each field, the unit for each measured field, the supply timing relative to manufacture or shipment, the quality check for each field, the contact for queries, and the remedy where data is missing, late or wrong. The route should be agreed in writing, with the supplier accepting the route or stating the fields that cannot be supplied, so that gaps are known before production rather than discovered at record creation. A route that states only that the supplier will supply passport data, without field names, formats or timing, is not a route, and it should not be treated as one. The written route is the evidence that onboarding happened, and it should be kept with the supplier file.
How is a pilot supply tested?
A pilot supply is tested by asking the supplier to supply the full field set for one model, in the agreed format, by the agreed date, and then checking the supply field by field against the route, recording the result for each field. The pilot should include a deliberately difficult field, such as a field that needs a test method or a unit conversion, because an easy pilot proves little. Failures in the pilot should be recorded, fixed and retested, with the fix recorded, rather than being noted for later, because a pilot that passes with known failures sets a weak standard for production supply. The pilot file, with its field by field results, is the proof that the supplier route works.
What does a supplier onboarding table look like?
A supplier onboarding table shows the supplier, the fields, the route status and the gap status, so that onboarding progress can be read at a glance. The table below uses general states, without naming any supplier.
| Supplier | Fields assigned | Route status | Gap status |
|---|---|---|---|
| Supplier A | Composition fields | Agreed in writing | No gaps |
| Supplier B | Performance fields | Agreed in writing | One gap tracked |
| Supplier C | Safety fields | Route not yet agreed | Onboarding incomplete |
How are gaps tracked and escalated?
Gaps are tracked in a gap register, with the field, the supplier, the date the gap was found, the request made, the response received and the follow up date, and gaps are escalated when the follow up date passes without supply, or when the same field is missing from the same supplier repeatedly. Escalation means raising the gap to a named manager, reviewing the route, and deciding whether to pause the affected model, seek an alternative source, or accept a documented delay with a dated plan. A gap that is tracked and escalated is a managed gap, while a gap that is known but not tracked is an unmanaged risk. The register should be reviewed at regular intervals, with closed gaps closed only by evidence.
How is supplier data quality checked over time?
Supplier data quality is checked over time by rechecking a sample of supplied fields against independent evidence, such as test reports, specifications or labelling, at regular intervals, and by recording the recheck results. A supplier whose data passes the pilot but drifts over time, through a change of process, a change of material or a change of staff, will be found by rechecking, while a supplier whose data is never rechecked will drift unnoticed. The recheck should be proportionate to the risk of the field, with safety and performance fields rechecked more often than stable identity fields. The recheck results should be recorded with the supplier file, so that a later reader can see the quality history, not only the latest supply.
What limits apply to supplier onboarding?
The limits are that onboarding is a preparation method, and it does not prove that any particular supplier data is accurate. This guide gives general educational information only and is not individual legal advice. An operator with a specific supplier should check the Regulation text and the Commission guidance as checked on 28 October 2026 before acting.
Sources & further reading
- Regulation (EU) 2023/1542 EUR-Lex summary record ↗
- Commission guidelines on removability and replaceability of batteries, Official Journal C 2025/214 ↗
- OECD introduction to due diligence guidance for upstream actors ↗
Source links point to primary materials and further reading, including commercial implementation resources where cited. This introductory guide does not replace the legislation.