Incomplete record diagnosis: finding what is missing in a battery passport without guessing

An incomplete record is a record in which a required field is absent, partly present or present but unverifiable. Diagnosis means identifying the missing or weak field, classifying the defect, and stating what evidence would close it. Diagnosis does not mean filling the gap by inference. A missing manufacturing date cannot be inferred from a batch code without a key. A missing carbon figure cannot be inferred from a figure for a similar model. A missing dismantling entry cannot be inferred from a generic diagram. The diagnostic record is valuable precisely because it leaves gaps visible and names the evidence that would fill them.

How is a diagnosis started?

Diagnosis starts with the applicable field list. For a passport record, the field list is Annex XIII, read with the battery category and the access tier. The diagnostician lists every field that applies to the category, marks the tier for each field, and then checks the record field by field. Fields that do not apply to the category are marked not applicable with the reason, not left blank. A field for EV batteries that is not required for the category in front of the reader is not a gap. A field that applies but is absent is a gap. Starting from the field list prevents two errors: treating a non applicable field as missing, and overlooking an applicable field because the display does not show it. The field list should be dated, because Annex XIII requirements and delegated acts change over time, and a diagnosis made against an old list misstates the position as checked on 28 October 2026.

What classes of defect are used?

Three classes keep findings precise. 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 status without an actor type. Unverifiable means a value is shown with a citation that cannot be inspected, does not match, or covers a different model, plant or period. The classes matter because the remedy differs. A missing field needs the underlying data. A partly present field needs the qualifier. An unverifiable field needs inspection of the cited evidence or a corrected citation. A diagnosis that calls every defect missing hides the remedy and makes the record harder to fix. Each finding should carry the field name, the class, the tier checked and the evidence that would close it.

What does a diagnostic table look like?

How are tier effects separated from real gaps?

A field that is absent from the public view may be present in the authorised view. That is not a gap. It is a tier effect. Diagnosis must therefore state the tier checked for each finding. A public tier diagnosis that reports authorised fields as missing misleads the operator and the reader. Conversely, a field absent from the authorised view is a gap even when the public view looks complete, because the authorised detail is part of the record. The diagnostician checks the highest tier available for the purpose of the diagnosis, and labels findings that could not be checked in a lower tier as not checked in that tier, rather than as missing. Tier discipline is part of accuracy, not an administrative detail.

How are version and timing effects handled?

A field may be absent because the duty that requires it has not yet applied, or because the delegated act that sets its method has not yet entered into force. Carbon footprint and recycled content timing is the clearest example. A diagnosis must separate a field that is not yet due from a field that is due and missing. The separation is made by stating the applicable date, the delegated act position as checked on 28 October 2026, and whether the timing is fixed or expected. A field labelled expected must not be reported as a breach of a fixed duty. A field that is due and missing must not be excused by a general statement that secondary legislation is pending, unless the pending act is the one that sets the method for that field. Timing analysis belongs in the diagnosis, in writing, for each timed field.

What should a diagnostic report avoid?

A diagnostic report should avoid filling gaps, ranking operators, and drawing legal conclusions about compliance. The report states findings, classes and remedies. It does not state that a battery is compliant or non compliant, because compliance is determined by the responsible operator, a notified body or a market surveillance authority on the full evidence, not by a record check alone. The report should avoid language that implies fault where the cause is unknown: a missing field may reflect a system error, a timing position, a tier limit or an operator omission, and the report should say which explanations were excluded and which remain open. This guide gives general educational information only and does not give legal advice for a particular battery or record.