What Would a Portable Record Contain If a Passport Applies?

A portable record, where a passport applies, is not a general portable record, because portable batteries are outside the passport duty. This guide describes the record anatomy that applies only where a battery first classified as portable is later treated as a passport battery through a life stage change, a reclassification, or a new placing that falls into a passport category. The anatomy is therefore conditional: it describes what the record must contain if and when the passport duty attaches, not a passport that every portable battery must carry.

The conditional framing prevents the most common portable record error, which is to build a passport for every portable battery and present it as a legal requirement. A voluntary product record for a portable battery is a different document, with different content and different access rules. The passport anatomy in this guide should be used only after a category reassessment has placed the battery inside Article 77, and the reassessment note should be filed before the passport is created.

When does a portable battery acquire a passport record?

A portable battery acquires a passport record when a reassessment places the resulting battery in a passport category and the battery is placed on the market or put into service in that category from 18 February 2027. Repurposing into an industrial application above 2 kWh, remanufacturing into a traction application, or a design change that moves the battery into the LMT or electric vehicle category are the routes by which the change occurs. The original portable placing does not create a passport, and the new placing creates the passport duty for the resulting battery.

A reassessment file should contain the original classification, the operation or change, the new characteristics, the new category result and the placing date for the new battery. A passport created without that file lacks the chain that explains why a battery that was once portable now carries a passport. A passport created before the reassessment, on the assumption that a category change will occur, creates a record for a battery that may never be placed in the new category.

What model data would the new record carry?

The new record would carry model data for the resulting battery, including manufacturer identity, model identification, chemistry, nominal capacity and voltage, and place and date of manufacture for the new life stage, as set out in Annex XIII. Model data for the original portable battery would remain in the original record history, linked to the new record where the Regulation requires linkage. The new model data must describe the resulting battery as placed on the market, not the original portable battery, and any change in chemistry, capacity or rated characteristics through the life stage operation must be reflected.

Worked check: a portable pack is repurposed into a stationary storage battery above 2 kWh. The new record carries the storage battery model data, the new unique identifier and the link to the original pack history. A system that copies the original portable model data into the new record without updating capacity, voltage and application would misdescribe the storage battery. A system that deletes the original history would break the chain that a recycler needs.

What individual data would the new record carry?

Individual data for the new record would include the unique identifier for the resulting battery, the manufacture or life stage operation date, and information resulting from use in the new stage, as set out in Annex XIII. Use history from the original portable stage would be available through the link, not by copying every original use event into the new record. The distinction keeps the new record current and readable, while preserving the original history for actors with the relevant access rights.

Individual data creation should be checked at the point of the new placing. A new identifier that duplicates an existing identifier, a new record that reuses the original identifier without linkage, or a new record with no link to the original history each create a chain error. The check should confirm identifier uniqueness, linkage and resolution through the data carrier, before the resulting battery is placed on the market. A check carried out after placing can detect the error, but it cannot prevent the period in which the battery was on the market with a broken chain.

How are access tiers applied to the new record?

Access tiers for the new record follow Annex XIII, with public information, legitimate interest information and authority information separated as for any passport battery. Information from the original portable stage that is not part of the passport tiers should not be copied into restricted tiers without a basis in Annex XIII. Conversely, information that Annex XIII requires for the new stage should not be withheld on the ground that the battery was once portable. The tier structure follows the new category, not the original category.

Tier design for a reclassified battery should be reviewed as a fresh design, not as an extension of a voluntary portable record. A voluntary record may have used broad access or a single tier, and carrying that design into a passport would breach the tier structure. A fresh tier map, listing each Annex XIII field, its tier and its source, should be prepared for the new record and reviewed before placing. The map is part of the passport evidence, and it should be dated.

What must not be copied from a voluntary portable record?

Voluntary product information, marketing claims, retail descriptions and service logs from the portable stage must not be copied into the passport as if they were Annex XIII data. Voluntary information may be useful as background evidence, but passport fields must be populated from verified model, test and manufacture data for the resulting battery. A marketing claim about capacity or life, copied into a passport field, becomes a passport claim with legal consequences, even when the original claim was a retail statement.

A data migration check should list each passport field, its source and its verification status, and should mark any field whose only source is voluntary or marketing material as unverified. Unverified fields must be verified from a proper source before placing, or the placing must pause. A migration that copies fields without a source check transfers the weakest evidence in the voluntary record into the legal record, where it is hardest to correct.

How is the conditional record evidenced?

The conditional record is evidenced by the reassessment note, the new category result, the tier map, the identifier and carrier checks, and the placing date. The evidence file should state clearly that the passport was created because the battery entered a passport category, with the operation and date named. As checked on 28 October 2026, the linkage and updating rules for such records depend in part on acts under Article 77, so the file should carry a review date. This guide gives general educational information only and is not individual legal advice. A reader with a specific battery or market decision should check the current Regulation text and any applicable delegated act, as checked on 28 October 2026, before acting.

This guide gives general educational information only and is not individual legal advice. A reader with a specific battery or market decision should check the current Regulation text and any applicable delegated act, as checked on 28 October 2026, before acting. The conditional passport should be built only after the reassessment is recorded, and the link to the original history should be preserved.