Identity fields answer three questions about a battery: who made it, which model it belongs to, and which individual battery it is. In Annex XIII point 1, identity includes the manufacturer name and address, the battery model identifier, and the battery category, together with general characteristics that identify the model. The unique identifier for the individual battery is the link that ties the unit record to the model record. Identity fields are checked first in any record review, because every other field is meaningful only when it is attached to the right battery.
A correct carbon figure for the wrong model is not a correct record.
What does the manufacturer field require?
The manufacturer field records the legal name and address of the manufacturer, as stated in the technical documentation and the declaration of conformity. Trade names and trade marks may appear alongside the legal name, but they do not replace it. The address is the postal address at which the manufacturer can be contacted, together with a single contact point where the Regulation requires one on the battery or in accompanying information. A manufacturer field that shows only a brand name, a website, or a distributor address fails the identity test, because a reader cannot establish the legal person responsible for the model. Where the manufacturer has changed name or address, the record should show the position at placing on the market, with a version note for any later change, rather than silently updating history. Identity is a historical fact as well as a current fact.
What is a battery model identifier?
A battery model identifier is a code or reference that identifies one battery model, distinct from every other model from the same manufacturer. It is stable across all units of the model and changes when the model changes in a material respect, such as chemistry, rated capacity or construction. The model identifier appears on the battery marking, in the technical documentation, in the declaration of conformity and in the passport record, and the four appearances must match. A model identifier that is reused for a revised model, or that differs between marking and record by a single character, breaks the link between the physical battery and the record. Model identifiers are not serial numbers and not batch codes. A batch code identifies a production run. A serial number identifies a unit. A model identifier identifies the design. Keeping those three levels apart is the core of identity discipline.
What is a unique identifier?
A unique identifier identifies one individual battery and no other battery. It is assigned at production, marked or linked to the battery through the data carrier, and never reused. Uniqueness is absolute within the system that issues it: two batteries must never share one identifier, and one battery must not acquire a second identifier without a recorded linkage event. The unique identifier is the key that joins the public model view to the unit history in point 4. Without it, state of health entries, repairs and status changes cannot be attributed to a battery with confidence. With it, a reader can follow one battery through repair, repurposing and treatment. The identifier itself carries no meaning about the battery. Meaning comes from the record it points to, and the identifier must therefore resolve to the correct record on every scan.
How are the three identifiers checked together?
The three identifiers are checked as a set. The marking on the battery is read first: manufacturer name, model identifier, serial or unit number, and the data carrier. The record reached through the data carrier is read second: manufacturer field, model identifier, unique identifier. The declaration of conformity is read third where available: manufacturer, model identifier and declaration reference. All three sources must agree on manufacturer and model. The unique identifier in the record must match the identifier encoded in the data carrier. A mismatch at any step stops reliance. The reader should not proceed to performance, carbon or safety fields until identity is settled, because those fields may describe a different battery. The table below shows the check in compact form.
| Source checked | Manufacturer | Model identifier | Unit link |
|---|---|---|---|
| Battery marking | Legal name as marked | Model identifier as marked | Serial number and data carrier |
| Passport record | Manufacturer name and address | Model identifier in point 1 | Unique identifier |
| Declaration of conformity | Manufacturer as declarant | Model identifier in declaration | Declaration reference in record |
What happens when identity fields change?
Identity fields change rarely, and each change is a version event. A manufacturer name change, a model revision, or a correction to an identifier must be recorded with a date, a reason in neutral terms, and a link between the old and new values. A correction to a misprinted model identifier is not a new model. A revision to chemistry or capacity that creates a new model version is not a correction. The distinction matters because a correction preserves the history of existing units, while a new model version starts a new model layer for units placed after the revision. Systems that overwrite identity fields without version history destroy the ability to check older units against the record that was current when they were placed on the market. Version history is part of identity, not an optional extra.
What limits apply to identity claims?
An identity field states who made a battery and which model and unit it is. It does not state that the battery is compliant, that the manufacturer remains in business, or that the model is still in production. Those are separate facts requiring separate evidence. A reader should not infer current availability of spare parts from a manufacturer field, or current production status from a model identifier. Identity is the foundation for further checks, not a substitute for them. This guide gives general educational information only and does not give legal advice for a particular battery, manufacturer or transaction.
Sources & further reading
- Regulation (EU) 2023/1542, consolidated text, Article 77 and Annex XIII ↗
- European Commission, Batteries ↗
- EU Battery Regulation: labelling and QR code requirements ↗
Source links point to primary materials and further reading, including commercial implementation resources where cited. This introductory guide does not replace the legislation.