Battery passport evidence checklist for EU market placement
A field-by-field checklist for the supplier evidence that feeds the EU battery passport: material origin, due-diligence records for cobalt, natural graphite, lithium, and nickel, recycled-content documentation, and carbon-footprint inputs. Built to collect and version the source documents behind each passport field before a battery is placed on the market.
Operational guide, not legal advice · Regulation (EU) 2023/1542, as amended
Collect the source evidence behind each passport field before placement
Under Article 77, from 18 February 2027 each LMT battery, each industrial battery with a capacity greater than 2 kWh, and each electric vehicle battery placed on the market or put into service needs an electronic record. Valent helps you gather, date, and version the supplier evidence behind those fields, material origin, due-diligence records, recycled content, and carbon-footprint inputs, before the battery reaches the EU market.
Why this matters
The battery passport is a digital record attached to individual batteries, but each field is only as defensible as the supplier document behind it. If those source records are not collected, dated, and versioned before placement, there is no clean way to show where a field came from when a market surveillance authority or a downstream purchaser asks.
The supplier evidence behind a material-origin field lives in an email thread, so no one can produce a dated source when the field is questioned.
Due-diligence records for cobalt, natural graphite, lithium, and nickel are pulled together per audit instead of kept current, so the chain of custody has gaps by placement time.
Recycled-content figures for cobalt, lead, lithium, or nickel are quoted from a supplier message with no dated document behind them.
A carbon-footprint figure is treated as final before the methodology is settled, so the underlying study cannot be reproduced when the pending acts enter into force.
Battery passport at a glance
Applies from
18 February 2027, for batteries placed on the market or put into service on or after that date. It is not retroactive to stock already on the market.
In scope
LMT batteries, industrial batteries with a capacity greater than 2 kWh, and electric vehicle batteries. Portable and SLI batteries are not covered by the passport, though all batteries carry a QR code from the same date.
Who is responsible
The economic operator placing the battery on the market must keep passport data accurate, complete, and up to date (Art. 77(4)). That duty can be assigned to another operator in writing, but not avoided.
Where fields come from
Passport fields draw on supplier evidence assembled before placement: material origin and chain of custody, due-diligence records for cobalt, natural graphite, lithium, and nickel, recycled-content documentation, and a carbon-footprint declaration where applicable.
Still pending
The Art. 77(9) implementing act defining legitimate-interest access was due by 18 August 2026 and had not been adopted as of mid-2026. Detailed technical specifications for the data model are also still being developed, so treat unofficial data-model guidance as provisional.
Dates that shape the evidence work
18 August 2026
Deadline for the Art. 77(9) implementing act on legitimate-interest access. It had not been adopted as of mid-2026, so plan for the passport without relying on final access rules.
18 February 2027
The battery passport applies to in-scope batteries placed on the market or put into service from this date, and all batteries must carry a QR code.
18 August 2027
Supply-chain due diligence obligations apply, postponed from 18 August 2025 by Regulation (EU) 2025/1561. The evidence feeds the due-diligence-related passport fields.
18 August 2028
Recycled-content documentation for cobalt, lead, lithium, and nickel applies from this date, or 24 months after the pending delegated act enters into force, whichever is later. Minimum recycled shares begin 18 August 2031.
Date not set
Carbon-footprint declaration timing depends on pending delegated and implementing acts that had not been adopted as of mid-2026. No fixed date can be stated; keep the supporting study reproducible so the figure can be finalized when the acts land.
Passport evidence action plan
Use this sequence to turn the passport from a 2027 deadline into evidence work your quality, regulatory, procurement, and operations teams can run now.
01
Inventory the in-scope batteries
List every model you place on the EU market and mark which are LMT, industrial over 2 kWh, or EV. Those need a passport from 18 February 2027; portable and SLI batteries carry a QR code from the same date but no passport.
Battery category and capacity for each modelWhether it is placed on the market or put into service in the EUThe economic operator placing each model on the marketQR-code and unique-identifier ownership per model
02
Map passport fields to source evidence
For each passport field, name the supplier document behind it, the internal owner, and the effective date. This turns an abstract data model into a concrete list of evidence to collect and version.
Field-to-document mapping for every modelOwner and renewal cadence per fieldEffective date and version for each source documentGaps flagged before, not during, placement
03
Stand up the material-origin file
Build the traceability record that supports the origin and due-diligence fields. It should connect each raw material to a supplier, a country of origin, and the transactions from extraction onward.
Country of origin and transaction chain from extraction to immediate supplierSupplier identity for each covered raw materialRaw-material description, trade name, and typeQuantities in the battery by percentage or weight
04
Build the due-diligence evidence set
Assemble the Chapter VII records that feed the due-diligence-related fields for cobalt, natural graphite, lithium, and nickel. Confirm scope against the EUR 40 million threshold and prepare notified-body verification ahead of 18 August 2027.
Due-diligence policy communicated to suppliersNotified-body verification and periodic audit reportsSupplier third-party verification reports (Art. 50(3))Risk assessments and mitigation records across Annex X categories
05
Version recycled-content and carbon-footprint inputs
Keep dated recycled-share documentation for cobalt, lead, lithium, and nickel per model, year, and plant, and keep the carbon-footprint study reproducible. Both depend on pending acts, so version everything so a figure can be finalized cleanly rather than rebuilt.
Recycled-share documents tied to model, year, and plantRecorded methodology basis for each figureCarbon-footprint inputs by life-cycle stage and plantVersion history so superseded figures never reach the passport
Material origin and chain of custody
Passport due-diligence fields rest on traceability evidence you can show back to source. The traceability system should identify upstream actors and connect each raw material to a supplier and a country of origin.
Country of origin and the market transactions from extraction to your immediate supplier
Supplier name and address for each covered raw material
Description of the raw material, including trade name and type
Quantities of each raw material in the battery, by percentage or weight
Due-diligence-related information (cobalt, natural graphite, lithium, nickel)
Chapter VII obligations apply from 18 August 2027 to operators placing batteries on the market, unless net turnover is below EUR 40 million and the group stays under that threshold. Policies must be verified and periodically audited by a notified body, built on the OECD Due Diligence Guidance framework.
Your battery due-diligence policy, communicated to suppliers and the public
Third-party verification reports issued by a notified body concerning suppliers (Art. 50(3))
Risk assessments and mitigation records across the Annex X environmental and social risk categories
Where a conflict-affected or high-risk source lacks verification reports, OECD-aligned upstream data such as mine of origin, trading and processing locations, and taxes, fees, or royalties paid
Industrial batteries over 2 kWh, EV, and SLI batteries containing cobalt, lead, lithium, or nickel in active materials will need documentation of recycled shares per model, year, and manufacturing plant. The methodology delegated act was due by 18 August 2026 and had not been adopted as of mid-2026, so keep the underlying documents ready rather than a single unsourced figure.
Recycled-share documentation per battery model, year, and manufacturing plant
Supplier statements tied to a dated document, not a figure quoted in a message
The methodology basis for each recycled share, to be aligned once the delegated act is adopted
A plan for the minimum shares beginning 18 August 2031 (16% cobalt, 85% lead, 6% lithium, 6% nickel) and the step-up on 18 August 2036 (26% cobalt, 85% lead, 12% lithium, 15% nickel)
Carbon-footprint inputs (where applicable)
The Article 7 declaration covers EV batteries, rechargeable industrial batteries over 2 kWh, and LMT batteries, per battery model per manufacturing plant, expressed in kg CO2e per kWh over expected service life. Its application timing depends on pending delegated and implementing acts, so collect and version the inputs now without committing to a date.
Manufacturing-plant location and per-model energy data
Life-cycle-stage inputs behind the declared footprint
The supporting study, kept reproducible so it can be finalized when the methodology and format acts enter into force
Version history for every input, so a superseded figure never reaches the passport
Checklist
Build the passport evidence trail before placement
Valent keeps each field tied to a dated, versioned source document and an approval record, so the passport can be populated and defended before a battery is placed on the market.
01
Identify which battery models are LMT, industrial over 2 kWh, or EV, and therefore need a passport from 18 February 2027; keep portable and SLI separate, as they carry a QR code but no passport.
02
Map each passport field to its source supplier document, an owner, and an effective date, then collect and version those documents before placement.
03
Confirm whether Chapter VII due diligence applies against the EUR 40 million net-turnover threshold, and if so keep notified-body verification and supplier third-party verification reports current ahead of 18 August 2027.
04
Keep dated recycled-content documentation for cobalt, lead, lithium, and nickel, and keep the carbon-footprint study reproducible so it can be finalized when the pending acts enter into force.
05
Tie the economic operator placing each battery on the market to the Art. 77(4) accuracy obligation, record any written delegation, and preserve reviewer identity, decision, and version history behind every field.
Be ready before the next customer asks
See how Valent keeps supplier evidence, review decisions, and release records ready, so proving compliance never holds up the business.
