What a record must never claim: limits that keep a battery passport honest

A battery passport is a record, not a promise. The record earns trust by stating what is known, with scope, date and source, and by refusing to state what is not known. Certain claims must never appear in a record entry, because the entry cannot support them, because the Regulation does not authorise them, or because a related consumer protection rule prohibits the underlying claim in a commercial context. The catalogue below is not a list of drafting preferences. Each item marks a boundary between a record and an overclaim, and crossing the boundary misleads a reader who may act on the entry.

Why must a record never claim that a battery is safe?

Safety is a conclusion from design, testing, installation, use and maintenance, not a property that a passport entry can confer. A record can state that safety testing was performed, that safety measures are described in the authorised tier, and that a battery management system provides stated functions. A record must never state, in the entry itself, that the battery is safe, safe for a stated new use, or safe to open, dismantle or repair without the precautions in the safety information. Those statements require the underlying assessment for the specific use and the specific condition of the unit. A unit that was safe when placed on the market may not be safe after damage, repair or repurposing, and a record that carries a blanket safety claim forward across those events hides the change. Safety language in a record should be limited to references to safety information and test evidence, with dates and scope.

Why must a record never claim remaining life or future performance?

Remaining life and future performance are projections, not measurements. A record can state a measured state of health value on a stated date under stated conditions, a cycle life test result, and an expected lifetime figure from the technical documentation where Annex XIII requires it, with the basis stated. A record must never convert those inputs into a claim that the battery will last a stated period, will retain a stated capacity, or will perform in a new application. Projections require assumptions about future use, temperature, duty cycle and maintenance, and those assumptions belong in an assessment, not in a passport entry presented as fact. A record that states a future outcome as if it were recorded history confuses the direction of time and removes the reader’s ability to test the assumption.

Which sustainability claims must a record never make?

A record must never claim that a battery is sustainable, green, carbon neutral, climate positive, fully recyclable, or made from recycled materials in general terms. Each of those phrases requires substantiation of a specific scope, and several are treated as unfair commercial practices without substantiation under Directive (EU) 2024/825 as it applies from 27 September 2026. The record can state a carbon footprint figure with scope and method, a recycled content share for a stated material with a stated calculation method, and a statement about substances of concern within the limits of Article 6 and Annex I. The record must not present a model level figure as a unit measurement, a recycled share for one material as a share for the whole battery, or a carbon figure without a method as a comparison with another battery. Sustainability claims are treated in detail in the sustainability cluster, and the record discipline here is the same: figure, scope, method, date, or no claim.

What compliance claims must a record never make?

A record must never state that a battery is compliant, certified, approved or authorised by the record itself. Compliance is a conclusion drawn by the responsible operator, a notified body or a market surveillance authority on the full evidence, including technical documentation, conformity assessment and test reports. A record can reference the EU declaration of conformity, the conformity assessment procedure applied, and the notified body identification number where applicable. A record must not present the existence of a passport entry as proof of compliance, because the passport is one information duty among many, and a complete passport can accompany a battery that fails another duty. A record must also never claim that the site or system hosting the record awards a qualification, builds or hosts passports as a service claim, or sells or recommends a platform. Those are claims about a service, not facts about a battery, and they have no place in a record entry.

What does the prohibited claims table summarise?

How should an overclaim be corrected?

An overclaim is corrected by a version entry that removes the claim, states the correction, and retains the prior wording in the version history where the system provides for it. Silent deletion hides the fact that readers may have relied on the claim. The correction should state the date, the field corrected, and the evidence based wording that replaces the claim. Where a claim has been published in a public tier, the correction should be visible in the public tier as well, so that a reader who saw the original claim can see that it no longer stands. Correction is a record act, not an apology, and the wording should stay factual throughout. This guide gives general educational information only and does not give legal advice for a particular battery, record or claim.