What If Supplier Data Is Missing for a Battery Passport

Missing supplier data for a battery passport means that a field required by Annex XIII for the battery category cannot be completed from the information held, and the correct response is to pause record creation for that battery, track the gap, and seek the data, rather than to invent the field, copy it from another model, or leave it blank without a record. The passport is an accurate record, and an invented field is worse than a missing field, because an invented field misleads every later reader, while a missing field, tracked openly, tells every later reader that the record is incomplete and why. The gap discipline is therefore a core part of passport preparation, not an administrative extra, and the gap register is a controlled document that should be reviewed until every mandatory gap is closed by evidence.

The scope is missing supplier data for Annex XIII fields, as checked on 28 October 2026. The guide states no conclusion about any particular supplier or field.

Why does supplier data go missing?

Supplier data goes missing for several reasons, including a supplier who does not hold the field, a supplier who holds the field in a different format, a supplier who has changed a material or a process without updating the data, a data route that has not been agreed, or a field that is conditional and whose condition has not been assessed. Each cause needs a different remedy, from a new data request, to a format conversion, to a fresh risk assessment, to a route agreement, to a condition assessment, and a gap record that states only that data is missing, without the cause, gives the next reader no way to choose the remedy. The cause should be established by asking the supplier, by checking the route and by checking the field list, in that order, and the cause should be recorded with the gap.

Which missing fields block a record?

Missing fields block a record where the field is mandatory for the battery category as of the duty date, under the Commission data points guidance, because a record without a mandatory field is incomplete and cannot be relied on as a complete passport. A missing optional field does not block a record, but it should still be recorded as missing, with the reason, so that a later reader does not assume that the field was checked and found not applicable. A missing conditional field blocks a record only where the condition is met, and the condition assessment should be recorded, so that a later reader can see why the field was treated as required or not required. The blocking test is therefore field by field, category by category, not a general rule that any missing field blocks every record.

How is a gap tracked?

A gap is tracked in a gap register, with the field, the battery or model, the supplier, the date the gap was found, the request made, the response received, the follow up date and the closure evidence, so that the gap can be followed from discovery to closure without relying on memory. The register should be reviewed at regular intervals, with overdue gaps escalated to a named manager, and with gaps closed only by evidence, not by the passage of time or by a promise to supply. A gap register that is reviewed and acted on is a strength, because it shows that incompleteness is managed, while a gap register that is created and never reviewed is a document that hides the gaps it was meant to expose. The register should be kept with the data plan.

What does a gap handling table look like?

A gap handling table pairs the gap state with the action that fits it, so that a gap is not treated as a single kind of problem. The table below uses general gap states.

What should not be done with a missing field?

A missing field should not be invented, copied from another model, estimated from a general value, or left blank without a gap record, because each of those actions creates a false record that a later reader will trust. An invented field is a fabrication, a copied field misdescribes the battery, an estimated field presents a guess as a fact, and a blank field without a gap record presents incompleteness as if it were completeness. The only correct actions are to seek the data, to record the gap, to pause the record where the field is mandatory, and to close the gap by evidence. A record that is paused for a missing mandatory field is a stronger record than a record that is completed with an invented field.

How does missing data affect placing?

Missing data affects placing because a battery that falls within Article 77 should not be placed on the market without a complete and accurate passport, and a missing mandatory field means that the passport cannot be complete. Placing with a known gap creates a market surveillance risk and a later correction burden, because the battery is already in the hands of holders who will read the incomplete record. The placing decision should therefore wait for the gap to close, or, where the field is confirmed as not required for the category, for the condition assessment to be recorded. A placing date that is missed because a gap was managed is a better outcome than a placing date that is met with an incomplete record.

What limits apply to gap handling?

The limits are that gap handling is a method, and it does not create data that does not exist. This guide gives general educational information only and is not individual legal advice. An operator with a specific gap should check the Regulation text and the Commission guidance as checked on 28 October 2026 before acting.