A European customer just asked for battery passport data. Here is what they actually need.
As 18 February 2027 approaches, European importers are sending their suppliers data requests that often arrive with little explanation — sometimes a spreadsheet of unfamiliar field names, sometimes a single line asking for "battery passport information". Both are attempts to gather what the EU Battery Regulation requires. Understanding what sits behind each field lets you answer once, completely, instead of through six rounds of clarification.
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In one line: the request splits into fields you can answer today from documents you already have, fields only your cell supplier can produce, and fields that only exist once the battery is in service — and separating the three at the outset is what turns a months-long exchange into a single reply.
Why the request exists at all
From 18 February 2027 an EU economic operator cannot lawfully place an in-scope battery on the market without a compliant digital passport attached to it. The importer is legally responsible for that passport being present and accurate, but a large part of the mandatory data originates in the manufacturing chain and nowhere else. The request in your inbox is the mechanism by which that data moves.
This is also why the requests feel urgent out of proportion to the deadline: buyers who wait until 2027 to ask will not have answers in time, and they know it.
Sorting the fields into three buckets
Before answering anything, split the request:
Answerable from your existing documents. Battery identity and model, manufacturer and place of manufacture, category, weight, capacity, voltage, intended application, and much of the performance and durability data — these already exist in your specification sheets and test reports.
Only your cell supplier can produce. Cell chemistry detail, the carbon footprint declaration, recycled content shares for cobalt, lithium, lead and nickel, and supply-chain due-diligence information. If you assemble packs from purchased cells, these are not yours to state and must not be estimated.
Only exists in service. State of health and usage data appear after the battery is deployed. Nobody expects these at the point of supply; if a questionnaire asks for them, that is a sign it was written without understanding the lifecycle.
Reply with the first bucket immediately, name the second bucket explicitly as pending with your supplier, and flag the third. A partial answer with a clear map beats silence while you chase everything.
The two fields that cause most of the delay
Carbon footprint. This is a calculated declaration following a prescribed methodology, not an estimate and not a generic industry figure. It has to come from whoever performed the calculation for the cells or the battery. If no study exists, saying so plainly is far better than supplying a number that cannot be substantiated — an inaccurate passport is a compliance failure for your customer, and it will be traced back.
Recycled content. Shares of recycled cobalt, lithium, lead and nickel must be evidenced through the supply chain rather than asserted. Material suppliers are frequently the slowest link, which is why this field should be requested upstream the same week you receive the customer request rather than after you have finished the easy fields.
How to answer once instead of fifteen times
If you supply several European customers, you will receive several versions of the same request in different formats. Building one structured data package per battery type — and keeping it current — converts a recurring interruption into a reusable sales asset.
Answer at battery type level, not per customer or per purchase order.
State the source and date of each figure, so a buyer's auditor can trace it.
Mark unavailable fields as unavailable with a reason and an expected date, rather than leaving blanks that read as evasion.
Agree in writing who publishes the passport and who updates it when data changes.
Re-issue the package when a cell source changes — a chemistry or supplier change invalidates the carbon footprint and recycled-content figures.
Frequently asked questions
Our customer sent a spreadsheet with unfamiliar field names. Where does it come from?
Almost certainly the mandatory data set in Regulation (EU) 2023/1542 for the battery passport, sometimes mapped through the guidance work published around it. If the field names are unclear, ask the customer to state the regulatory field each column corresponds to — that is a reasonable request and speeds both sides up.
We do not have a carbon footprint study. What should we put in that field?
Say that no study exists and give a realistic date if one is planned. Never estimate. The figure must follow a prescribed calculation methodology, and an unsubstantiated number makes your customer's passport inaccurate, which is their compliance failure and your reputational one.
Can we refuse and let the importer sort it out?
You can, but the practical consequence is that the importer cannot lawfully sell your battery in the EU from 18 February 2027. In competitive categories buyers are already using data readiness as a supplier-selection criterion, so refusal tends to resolve itself through the order book.
Do we have to answer separately for every purchase order?
No, and you should not. The data describes a battery type, not a shipment. Prepare one structured package per battery type, keep it versioned, and re-issue it when the cell source or specification changes.