No published comprehensive list identifies which raw material suppliers share full composition statements, and a passport record cannot be completed from such a list because no such list exists. A composition statement is a supplier document that states the materials in a supplied raw material or component, with scope, basis and date, for use as evidence behind a battery passport record under Regulation (EU) 2023/1542. The governing condition is the evidence held for the specific material and model revision.
A full composition statement means a supplier document that covers the whole supplied material or component within a stated scope, names each material in that scope, states the basis for any share, and carries a date and version. This guide covers the contents of such a statement, the form of a request for one, and the method for recording a complete, partial, refused or unverified response. It does not cover supplier choice, supply terms, or a decision about a specific battery, and it does not repeat passport composition field definitions, which belong in the companion guide on composition and materials fields.
What does a full composition statement contain?
A full statement is recognised by completeness within a stated scope, not by length. A long document that omits a material, leaves the basis unstated, or covers a different grade is not a full statement for that supply. A short document that covers the whole stated scope, with basis and date, can be a full statement for that scope.
| Element | Record shows |
|---|---|
| Identity | Name and supplier identifier |
| Scope | Component, grade, period |
| Material list | Each material in scope |
| Basis | Basis for any share |
| Date and version | Date and reference |
| Completeness | Whole scope, or exclusion named |
A statement that withholds part of its content for confidentiality reasons is recorded as partial for the withheld part, with the category withheld noted where the supplier states it.
What does sharing mean in a passport record?
Sharing means the provision of a document that can be filed, checked and traced. It does not mean a general assurance, a marketing claim about transparency, or a verbal confirmation that composition information exists somewhere. A record that states that a supplier shares information, without a document reference, a date and a scope, carries no checkable evidence.
Sharing varies by material, component and request. A supplier that provides a full statement for one material may provide only a summary for another, or may refuse a statement for a material subject to a confidentiality restriction. Each response is therefore recorded separately, for its own material and period.
Why is there no published list of sharing suppliers?
There is no published comprehensive list because no provision in Regulation (EU) 2023/1542 creates a register of suppliers by disclosure practice, and no official publication was found that lists suppliers as sharing or not sharing full composition statements. Disclosure practice is not a fixed attribute of a supplier. It changes with the material, the customer relationship, the confidentiality terms for a particular formulation, and the date of the request.
A list would also go out of date, and absence from a list would not prove refusal. The record must therefore rely on the response to a specific request, for a specific material, in a specific period.
What should a request to a supplier ask for?
A request names the material, component, grade and supply period, and asks for a document that covers that scope in full. A request covers these points:
- Identity: name and identifier already held.
- Grade and form: grade, form or specification.
- Supply period: period, batch range or delivery reference.
- Material list: each material in scope, with identifiers where provided.
- Basis: basis for any share, in words.
- Completeness: whole scope covered, or exclusion named.
- Date and version: statement date and reference.
- Change notice: notice when composition in scope changes.
The request states the purpose in neutral terms: the document is needed as evidence behind a passport record for the material and period named. Where a supplier states a confidentiality limit, the request asks for the category withheld and for any non confidential summary the supplier can provide.
How are complete, partial, refused and unverified responses recorded?
Each response is recorded as a single traceable entry that points to the filed document, with the document reference, the date received, the scope, the basis and the completeness note visible in the entry. Completeness and verification are kept separate.
| Response | Entry records |
|---|---|
| Complete | Full for stated scope; identity, scope, basis and date checked |
| Partial | Received part checked for its scope; missing part named as a gap |
| Refused | Refusal date, scope refused, reason as stated; gap for refused scope only |
| Unverified | Filed but unused as confirmed evidence until checks pass; failed check named |
A partial response is never completed by assumption, by copying a material list from a different material, grade or period, or by treating a summary as if it covered the whole scope. A refusal entry does not infer a motive, a policy or a future position, and it does not record the supplier as non sharing in general terms, because a single refusal is evidence about a single request.
What does a gap in composition evidence mean for the record?
A gap means that composition evidence is missing, partial, refused or unverified for a material, component or period, and that the passport record cannot state composition for that scope on the basis of supplier evidence alone. A gap does not prove that a material is absent, that a material is present in a particular share, or that a battery fails a requirement. A gap proves only that the evidence for that scope is not held in a checked form.
A gap entry states the material and scope affected, the type of gap, the date the gap was identified, and the date of any follow up request. A gap stays open until checked evidence covers the missing scope, or until the record scope changes with a recorded reason. A gap is not closed by copying evidence from a different material or period.
What does an illustrative record entry look like?
The following entry uses placeholder values only. Every value is illustrative, and none of the values describes a real supplier, a real material or a real battery. The entry shows a partial record, which shows both the evidence held and the gap that remains.
| Field | Illustrative entry |
|---|---|
| Supplier | PLACEHOLDER-A (illustrative, not a real supplier) |
| Material and scope | Illustrative material, grade, period (placeholders) |
| Document | Illustrative reference (placeholder) |
| Date received | Illustrative date (placeholder) |
| Basis | Share by weight of supplied material (illustrative, not measured) |
| Completeness | Partial: part of scope listed, one category withheld (illustrative) |
| Missing scope | Illustrative category withheld (placeholder) |
| Gap status | Open, follow up date recorded (illustrative) |
A real entry replaces each placeholder with the actual reference, date, scope and basis from the document received, and with the actual check result and check date.
What checks apply before a statement is used in a passport record?
A statement is used as checked evidence only after it passes a set of named checks, each recorded with a date. A statement passing some checks only is unverified for the failed part.
- Identity: material, component and grade match the supplier file.
- Scope: scope covers the material and period needed.
- Basis: basis for any share is stated.
- Date and version: date and version match the supply period; earlier versions retained.
- Completeness: whole scope covered, or exclusion named as partial scope.
- Trace: entry reference points to the filed document.
- Change: replacement recorded with date; earlier periods keep the earlier version.
Where a check fails, the entry records the failed check in its own terms and the follow up request asks for the specific correction needed. Where all checks pass, the status changes from received to checked, for that scope and period only.
This guide gives general educational information only, and it does not give individual legal advice for a specific battery, supplier or supply arrangement. Before acting on a specific battery or decision, check the current text of Regulation (EU) 2023/1542 and any applicable delegated or implementing act, and check the current version of any supplier document relied upon, because Regulation text, delegated acts and supplier documents change, and a record that was accurate for an earlier period may not describe a later period.
Sources & further reading
Source links point to primary materials and further reading, including commercial implementation resources where cited. This introductory guide does not replace the legislation.