Regulatory anchor
The primary legal instrument is Regulation (EU) 2023/1542 (Battery Regulation), which establishes due diligence, labelling, conformity, recycling targets, and the battery passport accessible via QR code.
Key concepts used throughout this chapter:
- Art. 77 — obligation to make passport information available; retention; updates; third-party access.
- Annex IV — categories of information in the passport (identity, carbon, materials, performance, compliance, supply chain, etc.).
- Economic operator — manufacturer, importer, distributor, fulfilment service provider (Art. 3).
- Notified Body (NB) — third-party conformity assessment where required (Art. 38, Art. 17 DoC).
- Art. 39 / Art. 48 — due diligence policies for raw materials and operator responsibility.
Delegated and implementing acts (e.g. carbon footprint methodology, attribute detail) will extend Annex IV over time; the platform uses a catalogue-driven attribute model so new fields can be added without schema rewrites.
Typical manufacturer path (Phase 1)
For a paying pilot customer, acceptance is defined as completing WF-01 → WF-07 for at least one model—including NB conformity—and generating active public QR scans. Later workflows (WF-08 … WF-12) cover use phase, ownership, end-of-life, second life, and recycling handoff.
- Register battery model (WF-01)
- Create passports and static Annex IV data (WF-02)
- Declare carbon footprint on the model (WF-03)
- Onboard suppliers and attestations (WF-04)
- Run compliance checks (WF-05)
- Obtain NB assessment (WF-06)
- Place on market with economic-operator chain (WF-07)
Workflow reference (WF-01 … WF-12)
Status badges on /app/workflows are computed from your tenant data (models, passports, grants, obligations). Definitions below are stable regulatory context.
Battery Model Registration
Register the battery product family (model code) before serialised units. Model-level data—materials, circularity, carbon, and BOM—applies to every passport created under that model.
Legal basis Reg. (EU) 2023/1542 Art. 77(1) (battery passport obligation); Annex IV (information to be included). Type + serial practice aligns with DIN/DKE model/unit structure.
Passport Creation & Static Data
Issue one digital passport per physical battery with serial number and public identifier (QR). Capture static Annex IV fields: identity, manufacturing, and unit-specific overrides where required.
Legal basis Art. 77(1)–(2) and Annex IV; Art. 3 (manufacturer, batch, serial definitions). Art. 77(3) retention of passport data for ten years after last placement on the market.
Carbon Footprint Declaration
Declare cradle-to-gate carbon footprint and performance class at model level for categories in scope (EV, LMT, industrial batteries above 2 kWh).
Legal basis Art. 7 (carbon footprint rules); Annex II (methodology); implementing/delegated acts on kg CO₂e per kWh and performance class labelling.
Supply Chain Due Diligence
Onboard suppliers and collect facility-level attestations for raw materials and components in the due-diligence scope.
Legal basis Art. 39 and Art. 48 (due diligence policies for economic operators); Art. 52 (due diligence on waste batteries) where applicable.
Compliance Engine Check
Continuous validation that mandatory passport attributes and checklist obligations are satisfied before market placement and on data changes.
Legal basis Art. 77(1) (complete and up-to-date passport); Art. 90 (enforcement); national implementing acts and future delegated acts on attribute sets.
NB Conformity Assessment
Manufacturer proposes a notified-body review; NB assesses the technical file and records approval, changes requested, or rejection.
Legal basis Art. 17 (EU declaration of conformity); Art. 38 (conformity assessment procedures); harmonised standards and NB Regulation (EU) 2019/1020.
Market Placement
Record the ordered chain of economic operators when the battery is first made available on the Union market and set passport status to on market.
Legal basis Art. 38(6) (obligations of manufacturer/importer); Art. 40 (authorised representative); Art. 44 (distributor); Art. 3(48) producer responsibility organisation where applicable.
In-Service Dynamic Data
Capture state of health, cycle count, and related performance data during use—via BMS ingest or operator entry (Phase 1 uses periodic snapshots).
Legal basis Art. 77(1) (dynamic passport information); Annex IV performance attributes; Art. 14 for remanufactured/repurposed batteries where relevant.
Ownership & Custodianship
Track changes of operator or owner responsible for the battery and support legitimate-interest access for repair and remanufacturing partners.
Legal basis Art. 77(7) (change of economic operator contact details); Art. 77(8) (access for persons acting on behalf of third parties).
End-of-Life Declaration
Declare end of first life and hand off to waste-management and recycling pathways.
Legal basis Art. 59 (collection); Arts. 56–58 (recycling efficiency and material recovery); interface with Directive 2008/98/EC on waste.
Second-Life Assessment
Assess whether a battery can be repurposed for second-life use before final recycling, including eligibility and any re-certification.
Legal basis Art. 14 (remanufactured and repurposed batteries); Art. 77 passport updates for second-life status and conformity where required.
Recycler Handoff
Grant cross-tenant access to recycler or waste operator; confirm receipt and record recovery performance against regulatory targets.
Legal basis Arts. 56–57 (recycling efficiency and recovery targets); Art. 8 (extended producer responsibility information obligations).
Where to act in the application
| Workflow | Primary routes (manufacturer) |
|---|---|
| WF-01 | /app/models, /app/models/new, LMT catalogue |
| WF-02 | /app/passports, /app/passports/new |
| WF-03 | Model → Carbon footprint |
| WF-04 | /app/supply-chain |
| WF-05 | /app/compliance |
| WF-06 | Passport → propose NB grant; partner /app/nb/engagements |
| WF-07 | Passport → Place on market (lifecycle) |
| WF-08 | Passport performance / BMS ingest API |
| WF-09 | Phase 1 stub — ownership transfer planned |
| WF-10 | Passport EoL declaration (when enabled) |
| WF-11 | Repairer grants; second-life metadata |
| WF-12 | Recycler inbound; cross-tenant grants |
Further reading
- Regulation (EU) 2023/1542 — official EUR-Lex text (Battery Regulation).
- docs/manufacturer-flows.md — engineering decisions for Phase 1 UI.
- docs/phase1-status.md — acceptance criteria and implementation status.
- Help: Data model — how model vs passport data is stored.