What evidence the battery passport really requires
“There are hundreds of certificates - which ones do I actually need?” The question comes up in almost every first conversation. The answer is shorter than expected: three documents are passport content. Everything else you collect is evidence behind a value - important for market surveillance, but not a passport entry of its own.
- Only three documents are passport content. The EU declaration of conformity (data point 42), the disassembly information (data point 48) and the results of the test reports (data point 50). The rest is evidence.
- A value arrives by exactly three routes. You type it yourself, it is written in a document, or it comes from your supplier. The decision does not depend on the field but on who creates the information.
- Four titles are enough for your supplier. Cell data sheet, UN 38.3 test summary, safety data sheet and the material composition. A blanket request gets you a marketing brochure.
- The hard topics are not live yet. Carbon footprint, recycled content and due diligence are not to be filled in at the February 2027 start. That relieves pressure - but postpones nothing, because the many small fields apply immediately.
Passport content or evidence - that is the whole trick
The confusion arises because two entirely different things are called a “certificate”. Separating them already answers the question about certificates.
The regulation names it
A document that Annex XIII itself lists as content of the battery passport. There are exactly three. They appear in the passport - partly as a statement, partly as a document for authorised professional users.
It sits behind a value
A document a numeric value comes from. It is not in the passport but behind it: during a market surveillance check it shows where the nominal voltage, the weight or the cell chemistry came from.
It rests until its date
Carbon footprint, recycled content and due diligence stay empty at the February 2027 start. The field does not disappear, it is simply not to be filled in.
The one-liner
The passport shows values, not your filing cabinet. You still collect the documents - so that behind every value there is a page with a line number when market surveillance asks.
The seven evidence types at a glance
Sorted by role: first the three genuine passport contents, then the evidence, and last the two topics that are not to be filled in at all today.
| Evidence type | What it contains | Who issues it | EU data point | Role |
|---|---|---|---|---|
| EU declaration of conformity | The statement that the battery complies with the regulation. The basis of CE marking. | You, as the manufacturer | #42 Art. 18 · Annex IX | Passport content |
| Test report (third party) | Reports from the conformity assessment procedure, typically to EN IEC 62619 or EN IEC 63056. The passport carries the results, not the full report. | Accredited laboratory or notified body | #50 Annex VIII · XIII 3 | Passport content |
| Disassembly and maintenance instructions | Exploded view with cell positions, disassembly sequence, fastening techniques, required tools, warnings, number and arrangement of cells. | Your own engineering or service department | #48 Annex XIII 2(c) | Passport content |
| REACH / hazardous substances | Substances of very high concern and critical raw materials above 0.1 percent by weight. In practice this comes from the safety data sheet. | Cell or material supplier | #13, #15 Annex VI A(8), A(10) | Evidence |
| Material composition proof | Detailed composition including cathode, anode and electrolyte. | Cell or material supplier | #45 Annex XIII 2(a) | Evidence |
| Cobalt due diligence | Report on responsible sourcing of cobalt, graphite, lithium and nickel. | Your compliance function plus upstream audits | #19 Annex XIII 1(d) | from 18 Aug 2027 |
| Carbon footprint declaration | Carbon footprint declaration and performance class. Based on a life-cycle assessment across the entire upstream chain. | LCA verifier | #17, #18 Annex XIII 1(c) | not to be filled yet |
The UN 38.3 test summary is deliberately absent from this list: it is transport law, not passport content. For the passport it is still one of the most valuable documents, because it is highly standardised and cleanly contains weight, capacity, chemistry and nominal voltage.
When do I type a value myself, when does it come from a document?
There are exactly three routes by which a value reaches the passport. The decision does not depend on the field but on a single question: who creates the information?
- 1
From you
You are the source. Nobody else knows the value.
Manufacturer and address·Model code and batch·Plant and date of manufacture·Part numbers and spare-part sources·Safety measures·Warranty period
- 2
From a document
The value is already written down in a piece of evidence.
Capacity, voltages and power·Weight and chemistry·Cycle life including reference test·Temperature ranges·Hazardous substances from the safety data sheet
- 3
From your supplier
The information is created before your factory gate - the most demanding route organisationally, and the one that has to start earliest.
Detailed composition·Recycled content·Origin of raw materials·Upstream emissions
And the operating data?
The dynamic fields - capacity fade, internal resistance increase, state of charge, condition data - come from none of these three routes. They originate in the battery management system or the manufacturer cloud and arrive continuously through an interface. That is a technical integration, not an organisational procurement task, and typically the second project after building the passport. More in the guide on BMS telemetry.
What to request from your supplier
Not “all documentation”, but four named documents. A blanket request gets you a marketing brochure. Naming these four titles usually gets you what you need on the first attempt.
| Request | Covers these passport fields | EU data points | Practical note |
|---|---|---|---|
| Cell data sheet cell specification sheet | Capacity, chemistry, voltages (min/nominal/max), power, cycle life including reference test, temperature ranges, internal resistance, C-rate | #11, #12, #26-#32, #34, #36, #38, #39 | Highest yield. Almost always available immediately. |
| UN 38.3 test summary mandatory since 2020 | Weight, capacity, chemistry, nominal voltage, watt-hour rating | #10, #11, #12, #27 | Every cell supplier must have one, otherwise they cannot ship. |
| Safety data sheet SDS under REACH, 16 sections | Hazardous substances, critical raw materials, parts of the material composition | #13, #15, #45 in part | Often gives ranges rather than values. Worth following up. |
| Material composition cathode, anode, electrolyte | The detailed composition as a distinct, defensible statement | #45 | The hardest item. It belongs in the purchasing contract, not in an email. |
The sentence that shortens the negotiation
“From 18 February 2027 I may no longer place this battery on the market without these details. So I do not need them for a form, I need them for market access.” That is why the four titles belong in the supplier specification, not in a polite request.
What of your evidence becomes public
This is the question that surprises people most often in conversation - and the answer usually reassures.
Never the file itself. Only metadata of an accepted document becomes visible - typically name, issuer, type and validity date. That publicly proves the evidence exists and is valid.
Recyclers and second-life operators receive the disassembly information after signing in - and nothing else. Every retrieval is logged.
Market surveillance and the Commission see the full scope, including the stored documents and the provenance of every single value.
A practical consequence for everyday work: name your evidence so that the name may appear in public. A file name such as “price-list-supplier-final-negotiation.pdf” is a poor choice.
What is not mandatory yet
Precisely the three topics manufacturers respect most are not to be filled in at the start.
| Date | What applies then | Status today |
|---|---|---|
| 18 Feb 2027 | The passport must exist, be filled in and registered as soon as the battery is placed on the EU market. | binding |
| 18 Aug 2027 | Due diligence obligations under Article 48 start. The responsible sourcing report becomes passport content after that. | postponed by 2 years |
| 18 Aug 2028 | The documentation obligation for recycled content takes effect. The calculation methodology is still pending. | fields stay empty |
| open | Carbon footprint declaration and carbon footprint label. Format and timing are to be set by an implementing act. | no date |
Why this does not mean starting later
The fields that go live on 18 February 2027 are not the hard sustainability topics but the many small ones - composition, electrical characteristics, disassembly information. Those sit in documents spread across three suppliers and two departments. That is what takes months: not the filling in, but the collecting.
Frequent questions on battery passport evidence
Which certificates does the battery passport strictly require?
Is the UN 38.3 test summary part of the battery passport?
Who issues the EU declaration of conformity for a battery?
Do uploaded certificates become publicly visible in the battery passport?
Must the carbon footprint appear in the passport from February 2027?
When do due diligence obligations for battery raw materials apply?
Sources & further reading
Related guides
Which data goes into the battery passport? maps the data points to the three access levels. Creating a battery passport describes the path from model to QR code. The carbon footprint of a battery explains why that field stays empty today. The EU Batteries Regulation gives the overall picture.
See in 90 seconds which evidence applies to your product
The eligibility check shows which category and mandatory fields apply to your battery - and therefore which evidence you actually need to collect.