What documents do I need for the product passport for batteries?
For the digital product passport for batteries, you gather broadly the same type of information as for other product groups: technical specifications, a declaration of conformity, safety information and data on material composition. What differs for batteries is that the regulation also requires documentation on the origin of raw materials such as cobalt, lithium, nickel and natural graphite. This is a layer that does not occur in the same way for furniture or textiles.
This origin documentation, also known as due diligence on the supply chain, is the section on which most manufacturers and importers have the most questions. Not because it is complicated to understand, but because the data often does not lie with you, but somewhere further down the chain with a supplier or raw materials trader.
What the passport basically requests
For most battery types, this involves a technical file with capacity, chemical composition and expected service life, a declaration of conformity associated with CE marking, a safety data sheet, and data on the percentage of recycled material in the battery. You often already have these documents partially available for product safety and CE marking; the passport bundles them and makes them digitally retrievable via a QR code on or with the product. The difference between what is needed for CE and what the passport additionally requests is something many companies struggle with; examined per product group what belongs gives a more precise picture than a general list can provide.
The origin of raw materials: the section that stands apart
For batteries, the regulation requires you to demonstrate where certain raw materials come from and under what conditions they have been extracted or processed. This means that you, or your supplier, need a due diligence report on the supply chain of these materials. For companies that produce batteries themselves, this information sometimes already lies with the purchasing department. For importers and companies that purchase batteries as part of a larger product, such as tools or an e-bike, this information often lies with a party further down the chain. Supervisory authorities look at this section to see whether the origin is demonstrably documented, not only whether you have received a statement from the supplier without underlying information.
Safety and performance
In addition to origin, the regulation requests data on safety and performance that are specific to batteries: test results on durability and service life under repeated charging, information on whether the battery is removable and replaceable, and data on how the product performs with temperature fluctuations. These documents often come from test reports that already exist for other purposes, such as internal quality control or export documentation, but must for the passport be in a form that is traceable and transferable.
End of life and recycling
A final category concerns what happens to the battery at the end of its life: information on collection, disassembly and recycling options. This section touches on existing legislation on waste management and producer responsibility, and the exact content varies per battery type. For companies that already work with a producer responsibility system, some of this data is often already available, but not always in the form the passport requests.
Where you get these documents from
Because some of this documentation does not originate from your own organisation but from suppliers, the conversation with your suppliers about who supplies which data is one of the first steps. This certainly applies to origin information about raw materials, where you depend on what has been recorded further down the chain. How prodpas.eu processes this data and where the information comes from is explained on the page about how the data is compiled. For frequently asked questions about this product group, there is also an overview of frequently asked questions.
For your own situation, in particular regarding who in the chain is responsible for which piece of documentation, it is advisable to have this reviewed by a lawyer or the competent supervisory authority. Would you first like an indication of what applies to your products? Do the free quick-scan and see in a few questions where you stand.