Material origin information: what a passport can and cannot say about where materials came from

Material origin information states where the materials in a battery came from, at a stated level of granularity: country of origin, region, facility, or chain of custody route. The Battery Regulation requires due diligence information and responsible sourcing information in the passport, linked to the due diligence system in Chapter VII and Annex X. Origin information in the record must be limited to what that system supports. A record that states a country of origin for a material without chain of custody evidence, or that states a facility without a custody link to the battery model, overstates knowledge.

Origin is a supply chain fact, and supply chains for cobalt, lithium, nickel and natural graphite are long, multi stage and mixed, so origin statements require care about granularity and about mixing.

What granularity can origin information take?

Origin information can be stated at country level, at facility level, or at chain level. Country level states the country or countries from which a material was sourced, for the model and period, as the due diligence system records it. Facility level states the smelter, refiner or processor, where the chain of custody identifies it. Chain level states the route from extraction through processing to battery production, with the actors and transfers identified. Each level requires different evidence. Country level requires origin records for the material inputs. Facility level requires custody records that link the material to the facility. Chain level requires the full custody sequence. A record should state the granularity it uses, so that a reader does not mistake a country level statement for a facility level trace, or a chain level statement for a guarantee that every atom followed the stated route. Granularity is part of the claim, and the record must state it.

How does mixing affect origin statements?

Mixing occurs where materials from different origins are combined in processing, refining or manufacturing, and the output cannot be attributed to a single origin on a physical basis. Mixing is normal in mineral supply chains, and the record must handle it honestly. Where mixing occurs, origin can be stated as a mass balance origin, a proportion of inputs from each origin in the defined period and system, or as a statement that origin is mixed and cannot be attributed to a single source for the unit. A record that states a single country of origin for a mixed material, without stating the mixing and the basis, misleads a reader about traceability. A record that states mixed origin, with the proportions and the period, is honest about the limits of physical tracing and allows a reader to judge the due diligence position. Mass balance origin, like mass balance recycled content, is an accounting statement, and the record should label it as such.

What does due diligence add to origin?

Due diligence adds risk assessment, risk management and verification to origin information. The due diligence system identifies risks in the supply chain, including human rights, labour, environmental and conflict related risks, assesses them, manages them through prevention, mitigation and remediation, and reports on the system and its findings. Origin information without due diligence is a geography statement. Origin information with due diligence is a geography statement plus a risk statement: where the material came from, what risks were identified, what was done about them, and what verification found. The passport record points to the due diligence policy, report and verification, and shows origin at the granularity the system supports. The record does not reproduce the full risk assessment, and a reader who needs the full assessment should follow the pointer to the report. Origin and risk are separate fields that belong together in the reading, not merged into one claim.

What does the origin table illustrate?

How are origin claims checked?

Origin claims are checked by tracing the custody records for the model and period, by checking that the granularity stated matches the evidence, and by checking that mixing is stated where it occurs. A check that accepts a country statement on the basis of a supplier summary, without custody records, is a weak check. A check that requires facility level tracing where the system only supports country level granularity asks for more than the system can provide, and the check should record the granularity limit instead. Origin checking is therefore a granularity check first, and an accuracy check second: does the statement match the level of evidence the system holds, and does the evidence support the statement at that level. A statement that matches its evidence level is accurate at that level, even when a higher level of tracing would be desirable.

What must origin fields never claim?

Origin fields must never claim that a material is conflict free, responsibly sourced in general terms, or traceable to a single mine or facility, without the custody and due diligence evidence to support the claim at the stated granularity. Origin is a fact about source. Responsibility is a judgement about risk management. Traceability is a property of the custody system. Each requires its own evidence. This guide gives general educational information only and does not give legal advice for a particular battery, material or supply chain.