Status change record: how a battery passport shows repair, reuse, repurposing and end of life

A status change is a dated event in which the recorded status of a battery changes from one state to another. Annex XIII point 4 contemplates status information for the individual battery, including changes that result from use, repair, preparation for re-use, repurposing and remanufacturing. A status change entry is not a measurement and not a model field. It is a record that something happened to this battery, on a stated date, carried out by a stated type of actor, with a stated result.

Without status entries, a passport shows what a battery was at placing on the market and never shows what the battery became.

Which statuses can a record show?

The Regulation uses several related terms, and the record must keep them apart. Preparation for re-use, preparation for repurposing, remanufacturing and recycling are distinct operations with distinct consequences for the battery and for responsibility. A battery prepared for re-use for the same purpose is not the same status as a battery repurposed for a different purpose. A repaired battery is not automatically a remanufactured battery. A battery sent for treatment as waste is not in the same status as a battery held for assessment. The record should use the terms as defined in Article 3 and as applied in the operation actually carried out, and should avoid umbrella terms such as second life where a precise status is available. Precision here protects the next reader, who may need to know whether safety testing, a new declaration or a new identifier is required before further use.

What must each status entry contain?

Each status entry contains five elements at minimum: the date of the change, the status before the change, the status after the change, the type of actor who carried out the operation, and a reference to the supporting record for the operation. A repair entry adds the nature of the repair and the parts replaced or the software changed. A repurposing entry adds the new intended application in general terms and any new safety or performance assessment relied on. A status entry without a prior status cannot be ordered in a sequence. A status entry without a date cannot be placed in time. A status entry without an actor type cannot be followed up. The entry should also state where supporting detail is held, without reproducing restricted detail in a tier where it does not belong. The discipline is deliberately narrow: date, before, after, actor, reference.

How is a sequence of statuses read?

A sequence is read in date order, from placing on the market to the latest entry. The reader checks that each new status follows plausibly from the previous status, that no status is skipped without explanation, and that the latest status is identified. A battery recorded as recycled should not later appear as in use without a correction entry explaining the sequence. A battery recorded as repurposed should show the assessment and operation that supported the new application. Gaps in a sequence are shown as gaps: a period with no status entry is a period with no recorded status change, not proof that nothing happened. The table below shows a plausible sequence in outline form. Illustrative labels mark positions, not events for a real battery.

What happens to the identifier when status changes?

The unique identifier persists across status changes in the ordinary case. The same battery keeps the same identifier through repair, re-use preparation and repurposing, so that history remains linked. A new identifier is a different event from a status change, and the record must not confuse the two. Where a battery is remanufactured and a new placing on the market occurs, the Regulation contemplates a new passport and a new identifier in defined circumstances, with the prior history linked or referenced as the applicable rules require. The record should state which position applies, the basis for it, and the link between the old and new identifiers where a link exists. An identifier that changes without explanation breaks the trace and forces a later reader to treat the battery as unknown.

What errors appear in status records?

Common errors include undated status entries, status labels copied from marketing language, repairs recorded without parts or actor information, and end of life entries recorded before treatment has occurred. A further error is the recording of an intended status as if it were an achieved status: a battery intended for repurposing is recorded as repurposed before assessment and operation. Intention and achievement must be kept apart, with intention shown as a plan or a holding status where the system provides for it. A status record that mixes intention with achievement misleads a buyer, a repairer and a recycler in different ways, and each of those readers may act on the error before it is corrected. Correction entries should supersede, not delete, the earlier entry.

What should a reader do with a status entry?

A reader should treat a status entry as a pointer to an operation, not as proof that the operation was performed correctly. The entry supports a decision to seek the supporting record, to inspect the battery, or to ask for testing, depending on the decision at hand. A reader should not rely on a status label alone to decide that a battery is safe for a new application, fit for resale, or ready for recycling. Safety, fitness and treatment decisions rest on the underlying assessment and documentation, of which the status entry is a summary. This guide gives general educational information only and does not give legal advice for a particular battery, operation or transaction.