Composition and materials fields: what a passport says about chemistry, materials and critical raw materials

Composition fields describe what a battery is made of, at two depths. The public tier in Annex XIII point 1 gives a summary: chemistry in general terms, together with information on materials and critical raw materials at the level the point requires. The authorised tier in point 2 gives detailed composition, including materials used in the cathode, anode and electrolyte. The two depths serve different readers. A member of the public needs to know the chemistry family and the presence of materials that affect handling and recycling.

A repairer or recycler needs the detail that determines dismantling, safety and material recovery. Both depths must be accurate, and neither depth may be quoted as if it were the other.

How is chemistry described?

Chemistry is described by the active materials and the cell chemistry family, in terms that a knowledgeable reader can recognise without proprietary detail in the public tier. Examples of chemistry families in general use include lithium iron phosphate and nickel manganese cobalt chemistries, described by cathode active material in the detailed tier. The public description should name the chemistry family and, where Annex XIII requires it, the cathode and anode active materials in summary form. The detailed description should name the chemical materials, with identifiers where the record system provides for them, so that a recycler can distinguish materials that look similar in a summary but behave differently in treatment. A chemistry description that uses a trade name alone, without the underlying chemistry family, fails the summary test. A chemistry description that invents a precise formula without evidence fails the accuracy test.

What does detailed composition add?

Detailed composition adds the materials used in each major part of the cell and pack: cathode active material, anode active material, electrolyte, and other materials that Annex XIII point 2 requires to be listed. It also adds the weight or share information where the record provides for it, with the basis stated: share by weight of the battery, of the active materials, or of a stated component. The basis matters because the same material can show a large share on one basis and a small share on another. Detailed composition supports dismantling, safety assessment and recycling planning. It must match the model revision, because a change in supplier or material that alters composition creates a new model version or a recorded variant. A recycler who relies on detailed composition for a different revision risks applying the wrong treatment route.

How are critical raw materials shown?

Critical raw materials in batteries include cobalt, lithium, nickel, natural graphite and manganese in battery grade forms, among the materials listed as strategic and critical under Regulation (EU) 2024/1252. The passport record shows the presence of critical raw materials above the thresholds and in the form that Annex XIII and the labelling rules require, including the indication on the battery label where a critical raw material is present above 0.1 percent by weight. The record must state the threshold, the basis and the date, because thresholds and lists change. A statement that a battery contains a critical raw material is a statement about presence above a stated threshold, not a statement about the quantity, the origin or the sustainability of sourcing. Quantity, origin and due diligence evidence are separate fields with separate evidence, and the record must keep them apart.

What does the composition table illustrate?

How are material changes recorded?

A material change, such as a change in cathode supplier that alters the detailed composition, is recorded as a model version change or a variant, with a date and a reference to the supporting documentation. Units produced before the change keep their link to the earlier composition. Units produced after the change link to the new composition. A record that updates composition for all units at once, without regard to production date, misstates the composition of earlier units. Where a material change is a correction, because the earlier entry was wrong, the correction is recorded as a correction with the prior value retained in version history. The distinction between a change and a correction is the same distinction that applies to identity fields: a change reflects a new fact, a correction reflects a better statement of an old fact.

What must composition fields never imply?

Composition fields must never imply origin, recycled content, safety or compliance. A material list does not prove where a material was mined or processed. A chemistry name does not prove a carbon figure. A detailed composition does not prove that dismantling is safe without the safety measures and the dismantling sequence. Each implication requires its own field and its own evidence. A reader who treats composition as a proxy for sustainability or safety overreads the record. This guide gives general educational information only and does not give legal advice for a particular battery or material.