Due diligence vs passport data distinction

Due diligence data and passport data overlap, but the two records are not identical and must not be merged without care. Due diligence data describes the policy, the management system, the risks found, the actions taken, and the verification arranged for covered raw materials. Passport data describes a specific battery, including its identity, composition, carbon footprint, recycled content, performance, and end of life information, under Annex XIII. Some due diligence information enters the passport, but the passport does not contain the full due diligence file, and the due diligence report does not contain the full passport. Each record must state its scope, period, and access level.

Due diligence data means the records behind Chapter VII, including policy, risk, mitigation, and verification records. Passport data means the electronic record for an individual battery under Article 77. The distinction is one of purpose, granularity, and audience, not only of format.

What is the legal frame for this record?

The distinction between due diligence data and passport data sits inside that sequence, so a record that shows only one step leaves the chain of reasoning incomplete. A record keeper aligning a due diligence report with a passport entry for one model therefore needs a file that shows the policy, the owner of the policy, the date of adoption, and the review cycle. A due diligence report might cover a full year of cobalt sourcing, while a passport entry for one battery covers the material in that battery, and the two quantities must not be presented as the same figure.

How is the chain mapped?

The map should name each tier that handles the distinction between due diligence data and passport data, record the function of each actor, and note where material changes form, such as refining, precursor production, cathode production, cell production, and pack assembly. The due diligence report, the passport entry, and a cross reference index should be tied to a named tier, a named site where that information is known, and a date. A record keeper aligning a due diligence report with a passport entry for one model should record gaps on the map itself, with the reason for each gap and the next step planned. Terms, supplier names, material names, and periods should match across the two records where they describe the same fact, and any difference in scope should be stated in both records so a reader does not compare unlike figures.

How is evidence judged?

A supplier statement, a contract clause, a third party audit summary, a mass balance record, and a chain of custody document do not carry equal weight, and the record should say which type supports each claim about the distinction between due diligence data and passport data. The due diligence report, the passport entry, and a cross reference index needs a source name, a collection date, a coverage period, and a statement of what was actually checked. A record keeper aligning a due diligence report with a passport entry for one model should separate facts received from conclusions drawn, so a later reviewer can test the conclusion. A due diligence report might cover a full year of cobalt sourcing, while a passport entry for one battery covers the material in that battery, and the two quantities must not be presented as the same figure.

How is risk identified and assessed?

A red flag can be a place of origin, a processing route, a supplier practice, a change of ownership, or a gap in records for the distinction between due diligence data and passport data. Terms, supplier names, material names, and periods should match across the two records where they describe the same fact, and any difference in scope should be stated in both records so a reader does not compare unlike figures. A record keeper aligning a due diligence report with a passport entry for one model should date each assessment and name the person or function responsible for the next review.

How is mitigation planned and followed up?

For the distinction between due diligence data and passport data, the plan should state the risk addressed, the action chosen, the supplier or site involved, the support offered, and the evidence that will show whether the action worked. The due diligence report, the passport entry, and a cross reference index collected after the action should be compared with the position before the action, using the same measure where possible. A due diligence report might cover a full year of cobalt sourcing, while a passport entry for one battery covers the material in that battery, and the two quantities must not be presented as the same figure.

How is reporting checked?

The due diligence report should summarise the policy, the management system, the risks found, the actions taken, and the verification arranged for the distinction between due diligence data and passport data, without disclosing confidential commercial detail that the Regulation does not require to be published. A record keeper aligning a due diligence report with a passport entry for one model should check that every public claim can be traced to an internal record, and that the report date, coverage period, and scope match the internal file. Terms, supplier names, material names, and periods should match across the two records where they describe the same fact, and any difference in scope should be stated in both records so a reader does not compare unlike figures.

How is one material followed through both records?

Follow one material, such as natural graphite for one model, through both records. In the due diligence file, the material appears as a chain: mine, processor, anode producer, with risk entries and a report sentence for the year. In the passport, the material appears as a composition entry for the model, and, where required, as due diligence information linked to the battery. A cross reference index lists the due diligence report page, the passport field, the supplier, the quantity, and the period, for the same material. A worked check compares the supplier name, the material name, and the period in both records. Any difference in spelling, scope, or period is corrected in both records, so a reader comparing them sees one fact, not two.

Separation with cross references keeps both records testable, and a merged record that hides the scope of each claim helps neither reader.