A completeness check is a structured pass over a battery passport, field by field, against Annex XIII, in tier order, with a recorded result for every applicable field. The check answers a narrow question: does the record contain every field that applies to this battery category, in the tier checked, with the qualifiers that make the field usable. The check does not answer whether the values are correct, whether testing was performed properly, or whether the battery is compliant.
Those questions require inspection of evidence, testing and authority assessment. A completeness check that claims more than completeness overstates its own result and misleads a reader who relies on it.
How is a check prepared?
Preparation means assembling the field list, the category, the tier to be checked, and the version of the record to be checked. The field list is Annex XIII, read with the category: EV, LMT, industrial above 2 kWh, or another category where the check is of a non passport record for comparison. The tier is stated before the check begins: public, authorised, or authority where the checker holds that access. The record version is identified by identifier, model version and date of viewing, so that a later reader can repeat the check on the same version. Preparation also means assembling the register, where one exists, and the evidence references that the record cites. A check begun without a field list drifts into impression: fields that look prominent are checked, fields that are absent are overlooked because absence is hard to see without a list.
How is the pass performed?
The pass works in point order: point 1, then point 2, then point 3 where accessible, then point 4. Within each point, fields are checked in the order they appear in Annex XIII. For each field, the checker records one of three results: present with qualifiers, gap, or not checked. Present with qualifiers means the value, scope, method and date are all shown where the field requires them. Gap means the field is missing, partly present or unverifiable, with the kind stated. Not checked means the checker could not inspect the field in the tier available, with the reason stated. The checker does not skip a field because it looks unimportant, and does not mark a field present on the basis of a display summary where the field requires detail. The pass is recorded in a check sheet that mirrors the field list, so that a reviewer can see every field and every result without re-performing the check.
What does a check sheet excerpt look like?
| Annex XIII field | Tier checked | Result | Note |
|---|---|---|---|
| Manufacturer name and address | Public, point 1 | Present with qualifiers | Matches marking |
| Model identifier | Public, point 1 | Present with qualifiers | Matches declaration reference |
| Rated capacity | Public, point 1 | Gap, partly present | Test conditions not stated |
| Detailed composition | Authorised, point 2 | Present with qualifiers | Matches model revision |
| Test report results | Authority, point 3 | Not checked | Authority tier not available to checker |
| State of health, latest entry | Authorised, point 4 | Gap, missing | No entry for current period |
How are results summarised without overstating them?
Results are summarised as counts by point and by kind: fields present, fields with gaps by kind, fields not checked. The summary states the tier, the category, the record version and the date of the check. It does not state a percentage completeness score as if it were a quality rating, because a record with 90 percent of fields present can still be unusable if the missing 10 percent includes identity or state of health. The summary should name the gaps that block a pending decision, and should separate gaps that are due to tier limits from gaps that are real absences. A summary that reports only a count hides the decision impact of the gaps. A summary that names the blocking gaps, with the evidence that would close each one, gives an operator a work list and a reader a basis for caution.
What happens after a check?
After a check, the check sheet is retained with the date, the checker role, and the record version. Gaps are passed to the field owners in the register, with the evidence that would close each gap. A re-check is scheduled or triggered by the arrival of the missing evidence, not by the passage of time alone. Where a gap is a timing gap, labelled expected, the re-check is triggered by the delegated act position settling, and the check sheet states that trigger. Where a gap is a tier gap, the re-check requires access to the higher tier and the check sheet states that requirement. A check without follow up is a snapshot that decays. A check with a work list and a trigger is a control.
What limits apply to a completeness check?
A completeness check is limited to presence and qualifiers. It does not verify accuracy, does not inspect test evidence in the authority tier unless the checker holds that access, and does not determine compliance. A record can pass a completeness check and still contain a wrong value, because presence is not correctness. The check sheet should carry that limit in words, so that a reader who sees a pass does not infer more than the check supports. This guide gives general educational information only and does not give legal advice for a particular battery or record.
Sources & further reading
- Regulation (EU) 2023/1542, consolidated text, Article 77 and Annex XIII ↗
- European Commission, Batteries ↗
- EU Battery Regulation 2023/1542: passport from 2027 ↗
Source links point to primary materials and further reading, including commercial implementation resources where cited. This introductory guide does not replace the legislation.