The report presents a comprehensive framework for the conformity assessment of battery passport data, focusing on how information can be exchanged, verified, and updated throughout a battery’s life cycle. Four primary data‑exchange options are outlined. The simplest, “One‑Up‑One‑Down,” limits data sharing to the two directly involved partners, which restricts the ability to perform checks beyond those two entities. A more centralized approach, the “Back‑End of Economic Operator,” places responsibility on a single operator who collects all necessary data and ensures that assessments are performed, thereby providing a complete view of the value stream. The “Traceability App” or “track & trace” system gathers data from every participant, enabling automatic checks and maintaining a holistic record. Finally, a blockchain‑based solution creates a tamper‑proof ledger of assessments, allowing all stakeholders to verify the completeness and integrity of the data chain.

The assessment of use‑phase data is identified as a key challenge because such data must be updated continuously. Static data points, once entered, require only a single verification, whereas dynamic data—such as battery health metrics recorded by a Battery Management System (BMS)—must be regularly validated. The report proposes that routine tests, similar to those used for vehicle battery durability, could be applied to a representative sample of batteries. If the measured values align with those reported by the BMS over multiple tests, the BMS can be certified as reliable. For batteries lacking a BMS, secondary legislation could mandate periodic checks against defined test procedures. The framework emphasizes that the frequency of updates and the methods for verifying correctness should be specified by standards or regulation, enabling automated or event‑driven validation processes.

Transfer cases, such as re‑use, repurposing, or remanufacturing, require a new conformity assessment by the new economic operator. The same four data‑exchange options apply, but the absence of a direct supplier‑customer relationship in some scenarios limits the use of second‑party assessments. The report stresses that waste operators play a crucial role in ensuring that a battery passport is terminated when a battery is disposed of, preventing misuse of passport data on other batteries. Custom authorities, as defined in the European Single Procurement Document, may access passports to verify compliance with formal requirements, though they cannot confirm the accuracy of the claims themselves.

The scope of assessment is described at multiple levels: market, organisational, product, process, and individual data point. Methods are categorized as internal (first‑ or second‑party) or external (third‑party), with EU conformity assessment and market surveillance treated separately. The EU conformity assessment follows Annex VIII procedures, allowing manufacturers to issue an EU declaration of conformity and, if a notified body is involved, a certificate or statement. The CE marking is affixed to the battery, and the declaration is embedded in the passport.

The Battery Pass consortium, a German‑based collaboration, brings together manufacturers, suppliers, waste operators, and regulatory bodies to develop and test these assessment methods. The consortium’s partners assume distinct roles: manufacturers conduct the initial conformity assessment; suppliers provide data for the value stream; waste operators ensure proper passport termination; and regulatory authorities oversee market surveillance. The project operates within a defined timeframe and is supported by European Union funding mechanisms, reflecting the broader policy goal of establishing a trustworthy digital product passport for batteries across the EU.