A battery-passport project needs a clear allocation of responsibilities before a software platform is selected. The Commission’s guidance update announced on 21 August 2026 helps businesses identify category-dependent data requirements. For exporters and their EU partners, the practical question is who approves the information, who maintains it and what happens when the product or service arrangement changes.
Identify the accountable operator before allocating tasks
Article 77 of Regulation (EU) 2023/1542 sets the passport requirement from 18 February 2027 for LMT batteries, industrial batteries above 2 kWh and electric vehicle batteries placed on the market or put into service. This is not a blanket requirement for every portable battery. This preparation note reflects the current provisions reviewed on 4 October 2026, rather than a new rule announced today.
Under Article 77(4), the operator placing the battery on the market must ensure that passport information is accurate, complete and current. Map the commercial and product-delivery roles first. The company operating the website is not necessarily the operator carrying that obligation.
A written mandate is a task allocation, not a transfer of accountability
Article 77(4) permits written authorisation of another operator. The Commission’s FAQ clarifies that ultimate legal responsibility remains with the responsible operator. It also distinguishes creating and updating passport content from registration in the Registry. Procurement documents should therefore define more than a single deliverable called “a passport”.
As a practical control, allocate responsibility for obtaining evidence, approving changes, publishing corrections and handling exceptions. Agree how supplier changes reach the approver and how updates are tracked. This is an internal workflow recommendation, not a prescribed regulatory form. A test report can support a particular item of evidence without fulfilling the entire passport obligation.
Separate the model baseline from individual-battery records
Article 77(2) covers both model information and information about the individual battery, including information resulting from use. A controlled model baseline can be linked to individual identifiers and subsequent records. Check that supporting reports identify the relevant sample, configuration and revision; a shared PDF cannot represent every battery’s changing condition.
Passport-related information is not automatically public. The regulation differentiates access rights and makes information requirements category-dependent. Check Annex XIII and applicable implementing provisions before exposing restricted or commercially sensitive material. Treat field applicability as a separate review: a guidance document supports preparation but does not create additional legal requirements.
Plan for service exit and lifecycle handovers
Article 77(5) requires open, interoperable, machine-readable and structured information arrangements without vendor lock-in. Article 78 addresses reliable and secure data, privacy and controlled access. An authorised storage or processing provider cannot use or sell the data beyond what is necessary for the relevant service. Availability must also survive the responsible operator ceasing to exist or ending its activity in the Union.
During platform procurement, examine export capability, permissions, continuity arrangements and the exit process, not only initial publication. Article 77(7) separately addresses responsibility and linked replacement passports after preparation for re-use, preparation for repurposing, repurposing or remanufacturing. Do not assume the original account and record can simply continue unchanged, or generalise those cases into a rule that every ordinary repair requires a new passport.
Connect the evidence file to testing preparation
Customers can share the target market, battery category, model revisions, sample description and existing reports with Qianxin to discuss relevant standards and testing needs. The available work and deliverables require written project confirmation. Testing evidence does not replace the operator’s continuing information duties and is not a passport-platform service or regulatory approval.
The original cover is a conceptual illustration, not a working passport interface. This is general compliance information, not product-specific legal advice or a final conformity assessment. Recheck the legislation and implementing requirements before release or significant changes.
