CE marking and the battery passport

CE marking and the battery passport are separate duties that must agree, and neither duty replaces the other. CE marking is the marking by which the manufacturer indicates conformity with the applicable Union harmonisation legislation, including Regulation (EU) 2023/1542, following the conformity assessment procedure for the battery. The battery passport is an electronic record for an individual battery under Article 77, accessible through a QR code. A battery can carry a CE mark and still lack a compliant passport, and a passport entry does not prove that CE marking was correctly affixed. The record must show the conformity basis, the marking, and the passport status as three linked checks.

CE marking means the marking affixed to a battery to indicate conformity, in the form and under the rules set out in the Regulation and in Regulation (EC) No 765/2008. The battery passport means the electronic record under Article 77 for EV, LMT, and industrial batteries over 2 kWh from 18 February 2027.

What is the legal frame for this marking?

CE marking and the battery passport is a physical marking duty and a record duty at the same time. A manufacturer affixing CE marking to an industrial battery pack should work from the current consolidated text and check whether an implementing act on harmonised label specifications has entered into force, since Article 13 sets some dates by reference to that act. An industrial pack that passes conformity assessment should show the CE mark on the pack, a declaration that names the pack model, and a passport entry that names the same model and identifier, with matching versions.

How are content, placement, and legibility checked?

Content asks whether every required element for CE marking and the battery passport is present and correct for the battery category. The declaration of conformity, technical documentation, and passport status record should include a photograph or a retained sample label, the artwork version, and the approval date, tied to the battery model. The obligation to affix CE marking applies from 18 August 2024 under the application provisions in Article 96, while the passport duty applies from 18 February 2027, and the record should keep the two dates separate.

How does category decide content?

Category decides content. For CE marking and the battery passport, the record should state the category as defined in Article 3, list the label elements that apply to that category, and list the elements that do not apply, with the reason. A manufacturer affixing CE marking to an industrial battery pack should be careful where a battery could fall into more than one description, and should record the reasoning for the category chosen. An industrial pack that passes conformity assessment should show the CE mark on the pack, a declaration that names the pack model, and a passport entry that names the same model and identifier, with matching versions.

How are measurement and wording recorded?

For CE marking and the battery passport, a capacity value, a chemistry statement, or a duration value should name the test method, the conditions, and the unit, so the same battery tested again gives a comparable result. The declaration of conformity, technical documentation, and passport status record should include the test report or the calculation sheet, the date, and the person or function that approved the value. The obligation to affix CE marking applies from 18 August 2024 under the application provisions in Article 96, while the passport duty applies from 18 February 2027, and the record should keep the two dates separate.

What sits behind the marking in the documentation?

For CE marking and the battery passport, the declaration should identify the battery, the Regulation, and the conformity assessment procedure followed, and the technical documentation should support each marked claim. A manufacturer affixing CE marking to an industrial battery pack should check that the declaration date, the battery model, and the marking version are consistent, and that a change to the battery that affects conformity leads to a review of the documentation. An industrial pack that passes conformity assessment should show the CE mark on the pack, a declaration that names the pack model, and a passport entry that names the same model and identifier, with matching versions.

How is a marking checked line by line?

For CE marking and the battery passport, a checker should compare the physical marking, the QR code destination, the passport entry where a passport applies, the declaration of conformity, and the technical documentation, line by line, and record each comparison with a pass, a fail, or a query. The declaration of conformity, technical documentation, and passport status record for the check should include the date, the sample identifier, and the version of each document compared. A manufacturer affixing CE marking to an industrial battery pack should keep failed checks on file with the corrective action, the new artwork or record version, and the recheck date. The obligation to affix CE marking applies from 18 August 2024 under the application provisions in Article 96, while the passport duty applies from 18 February 2027, and the record should keep the two dates separate.

How is CE marking checked against the passport for one model?

Checking one model starts with the physical pack: the CE mark is photographed, its placement and form are noted, and the model name on the pack is recorded. The declaration is then read for the same model, the same manufacturer, and the same conformity procedure, and the technical documentation index is checked for the test reports that support the mark. The passport is then opened through the QR code, and the model, manufacturer, and identifier are compared with the pack and the declaration. A worked check sheet shows three columns, pack, declaration, and passport, with a pass for each matching line and a query for any difference in model name, version, or date. A difference in version is a query, not a pass, until the version history explains it.

The mark, the declaration, and the passport answer different questions, and a file that answers only one of them leaves the other two unchecked.