Missing data and gaps: stating what a passport does not yet show

Missing data in a battery passport is a fact about the record, not a fact about the battery. A missing field may mean the data was never collected, the data was collected but not entered, the data is held elsewhere, the duty has not yet applied, or the field is restricted in the tier being viewed. Each cause calls for a different response, and a record that treats every gap as the same kind of failure misleads the operator who must fix it.

The discipline in this guide is simple: state the gap, classify it, state the cause where known, and state the remedy. Never fill a gap by inference.

What are the main kinds of gap?

Missing means the field is absent from the record in the tier checked. Partly present means a value is shown without a required qualifier, such as a figure without scope, a date without a year, or a measurement without conditions. Unverifiable means a value is shown with a citation that cannot be inspected or does not match. Not yet due means the duty that requires the field has not yet applied for the category, or the method act has not yet entered into force, and the timing is labelled expected. Not applicable means the field does not apply to the category, with the reason stated. Tier restricted means the field exists in a higher tier and is correctly absent from the tier being viewed. Five kinds, plus not applicable, cover most gaps. A gap that does not fit one of the kinds should be described in words, with the facts stated, rather than forced into a kind that does not fit.

Why must gaps never be filled by inference?

Inference fills a gap with a value that looks plausible but is not evidence. Examples include carrying forward a previous state of health value as if it were current, copying a carbon figure from a similar model, inferring a manufacturing date from a batch code without a key, and inferring dismantling detail from a generic diagram for the chemistry family. Each inference creates a false record that is harder to detect than an honest gap, because the record appears complete. A reader who acts on an inferred value acts on a guess presented as a fact. The remedy for a gap is evidence, not plausibility. Where evidence cannot be obtained, the gap remains, and the record states the gap and the steps taken to obtain the evidence. That statement is more useful than a filled field, because it allows a later reader to decide whether to proceed without the evidence.

How is a gap statement written?

A gap statement is written in factual form: field name, kind, tier checked, cause where known, evidence that would close the gap, and the date of the statement. An example in neutral form reads: rated capacity, partly present, public tier, test conditions not stated, technical documentation with reference conditions would close the gap, statement dated on the date of checking. The statement does not assign blame, does not speculate about the reason for the gap beyond the facts known, and does not draw a legal conclusion. Gap statements are retained with the record check, so that a later check can tell whether a gap is new, continuing or closed. A gap that is closed should be marked closed with the date and the evidence that closed it, and the prior gap statement should be retained in the check history.

What does the gap table illustrate?

How are gaps prioritised?

Gaps are prioritised by decision impact, not by ease of filling. An identity gap blocks reliance on every other field and is prioritised first. A carbon or recycled content gap blocks a sustainability decision and is prioritised where such a decision depends on the record. A unit history gap blocks a repair or repurposing decision and is prioritised where that decision is pending. A gap in a field that no pending decision depends on is still recorded, but it does not block other work. Prioritisation should be stated in the gap record, so that a reader can see why one gap was pursued before another. A gap list ordered by field number alone, without decision impact, looks tidy and misleads an operator about where effort is needed.

What limits apply to gap reporting?

Gap reporting states findings about a record. It does not state that a battery is compliant or non compliant, that an operator has breached a duty, or that a gap will be filled by a stated date unless the operator has committed to that date. Future filling dates are commitments, not findings, and they should be labelled as such with the source of the commitment. This guide gives general educational information only and does not give legal advice for a particular battery or record.