Gaps in a Used Battery Record and How to Read Them

A gap in a used battery record means that for a dated period there is no passport entry describing the battery, even though time passed and the battery may have been used, stored, repaired or transferred. A gap is not the same as a low value, a poor result or a missing field, and treating every gap as evidence of a problem overreads the record just as surely as ignoring every gap underreads it. The useful question is what kind of gap is present, when it starts and ends, and what other evidence covers the same period, because those three facts decide whether the gap is a minor silence or a material break.

The scope is the individual record for batteries within Article 77, read under Annex XIII, where later use information is expected to accumulate under one identifier. A gap can occur before the passport duty applies, during a change of record system, during a period of storage, or around a transfer that was documented elsewhere but not entered in the passport. The position is stated as checked on 28 October 2026, and the guide states no conclusion about any particular battery.

What kinds of gap occur in a used record?

Gaps divide into identity gaps, time gaps, status gaps and evidence gaps. An identity gap occurs when the link between battery and identifier is broken or duplicated. A time gap occurs when dated entries stop and later resume without explanation for the interval. A status gap occurs when a change of status, such as preparation for reuse or repurposing, is not shown in sequence. An evidence gap occurs when an entry exists but the supporting evaluation or document behind it is not available. Each kind needs a different follow up, because an identity gap needs an identity resolution, a time gap needs documents for the interval, a status gap needs a status clarification, and an evidence gap needs the underlying evaluation. Naming the kind of gap is the first step in closing it.

How is a time gap dated and measured?

A time gap is dated by the last entry before the gap and the first entry after the gap, and measured by the interval between those two dates. The measurement should be recorded in the reading note, together with what is known about the battery during the interval from other sources, such as invoices, service logs or transfer documents. A short gap during documented storage raises a different question from a long gap during active use, and a gap that spans a transfer raises a different question again. The reader should not assume that nothing happened during a gap, and should not assume that something adverse happened either. The gap is a period of unknown record, and the reading note should say so in those terms.

What other evidence can cover a gap?

Other evidence that can cover a gap includes sale and transfer invoices and contracts, state of health evaluations, repair and refurbishment records, storage records and test reports held outside the passport. Article 73 shows the same pairing for waste batteries prepared for reuse or repurposing, where state of health evidence and an invoice or contract document further use. Other evidence does not rewrite the passport, and it should be kept alongside the passport rather than treated as a substitute entry, because a later reader needs to see both the gap in the passport and the separate evidence that covers it. The distinction preserves the honesty of the record while still allowing a decision to be made on the full file.

What does a gap classification table look like?

A classification table helps a reader sort gaps quickly and choose the right follow up. The table below uses general gap states and pairs each with the follow up that fits that kind of gap. The table is a reading aid, not a claim that every gap of a given kind has the same cause, and each row still needs the facts of the particular record.

When does a gap block reliance on the record?

A gap blocks reliance when it covers the period or the fact that the decision depends on, such as a gap that spans the most recent use, a gap that hides a status change, or an identity gap that leaves the battery unidentified. A gap does not block reliance when it covers a period that is irrelevant to the decision and is covered by other evidence, such as a short storage gap with storage records. The test is decision specific, and a reader should state the decision, the gap and the reason why the gap does or does not block reliance, rather than applying a general rule that any gap invalidates a record. A record with a stated, bounded gap is more reliable as a reading than a record whose gaps have never been examined.

How should gaps be recorded in a reading note?

Gaps should be recorded with start date, end date, kind, other evidence consulted and conclusion, so that a later reader can see the gap work without repeating it. The note should quote the entry dates rather than paraphrasing them, and should distinguish between a gap that was closed by other evidence and a gap that remains open. A note that records only that the record is incomplete, without dates or kinds, gives a later reader no way to judge whether the incompleteness matters. A note that records the gap work precisely lets a later reader rely on the reading, challenge it or update it when new evidence arrives.

What limits apply to reading gaps?

The limits are that a gap reading cannot create evidence that does not exist, and cannot turn silence into a favourable or unfavourable conclusion. This guide gives general educational information only and is not individual legal advice. A reader with a specific record should check the Regulation text and any applicable national rules as checked on 28 October 2026 before acting.