Passport Data You Can Declare Yourself vs Data Only Your Supplier Has

When importers first open the Annex XIII data set, the reaction is usually the same: this is a lot, and most of it is about how the battery was made. That reaction is correct, and it points at the most useful way to organise the work. Split the fields into what you can complete yourself and what only your manufacturer can supply. The first list you can close this week. The second list is the one with the lead time.

What is genuinely yours

A smaller set of information comes from your side of the transaction rather than the factory:

• Your identity as the operator. As importer you must put your name, registered trade name or trade mark, and a postal address on the battery as a single contact point (Art. 41 of Regulation (EU) 2023/1542). That is your data, not the manufacturer's.
• The commercial warranty you offer on the battery's calendar life. This is a term you set.
• Waste handling and end-user information for the markets you sell into, which sits with you as the party putting the product into those markets.
• The hosting arrangement. Where the passport lives and stays reachable is your decision and your ongoing duty. See how long a battery passport must stay online.
• Whether the model is in scope and when, which follows from what you place on the market and the date you do it. See when a battery counts as placed on the EU market.

Notice what these have in common. They are facts about your business and your commercial terms. None of them is a claim about the battery's physical make-up.

What only the manufacturer can give you

Nearly everything describing the battery itself originates upstream:

• Chemistry and material composition, including substances of concern and any critical raw materials present.
• Detailed composition of the cathode, anode and electrolyte, which sits in the restricted tier rather than the public one.
• Carbon footprint, which is a declared figure produced to a defined method, not an estimate. See the carbon footprint declaration.
• Recycled content in cobalt, lead, lithium and nickel, again method-based. See recycled content declaration.
• Performance and durability: rated capacity, voltage range, power capability, expected lifetime in cycles with the reference test, round-trip energy efficiency, internal resistance, temperature ranges.
• Dismantling and safety information: how the pack comes apart, the tools and fastenings, warnings, the cell layout, and the safety measures.
• Conformity evidence, meaning the test reports behind the declaration of conformity.

The grey zone, and how to handle it

A few fields feel like yours but are not quite. Model identifiers and part numbers are a good example: you may assign your own internal codes, but the passport is describing the battery the factory built, so the identifiers have to tie back to the real product. If you rebrand a pack under your own name, the identifiers still have to point at something traceable.

The same applies to anything you are tempted to copy across from a similar model. Two packs from the same supplier with the same nominal capacity can differ in cell supplier, chemistry or construction. Reusing one model's figures for another is the most common way inaccurate data gets into a passport.

Why you cannot fill the gaps yourself

This is the line that matters. You are the economic operator answerable for the passport, and the data in it is declared on your responsibility. A passport tool can check that a record is complete and correctly structured. It cannot make a number true, and neither can a plausible guess.

So when a supplier will not provide a figure, the answer is not to approximate it. The answer is to escalate, and if escalation fails, to treat that as a sourcing decision. See what your supplier must send you for the request itself, and who is responsible for the battery passport for why the duty stays with you.

A practical way to run it

Take your field list and put a letter beside every row: Y for yours, S for supplier, G for grey. Then:

1. Close every Y row now. It needs no one else and it is quick.
2. Send every S row as one request per supplier, per model, with a deadline.
3. Resolve the G rows explicitly rather than assuming, especially identifiers.

The Y list being short is not a problem. It is the point: it tells you that your real job is not data entry, it is getting a manufacturer to answer properly and early.

In short

Your own fields are your operator identity and contact details, your warranty terms, end-user and waste information, hosting, and the scope decision. Everything describing the battery itself, chemistry, composition, carbon footprint, recycled content, performance, dismantling and test evidence, comes from the manufacturer. Do not fill a supplier gap with an estimate: you are the party answerable for the declared data, and a plausible number is still an inaccurate one.