Who Is Responsible for the Data in a Battery Passport and How Do You Show Where It Came From?
Short answer: The economic operator placing the battery on the market. Article 77(4) of Regulation (EU) 2023/1542 says that operator "shall ensure that the information in the battery passport is accurate, complete and up to date". The Commission's FAQ adds that authorising someone else to publish the passport "does not transfer the ultimate legal responsibility". Nothing in the Regulation, in DIN DKE SPEC 99100 or in the open passport data models defines a row that says who declared what. We think a passport needs one, so ours carries a provenance statement: for every row, declared by the operator, estimated by ActivateDigital or not stated. This guide explains the rule and why an estimate must never look like the maker's number.
- Article 77(4) makes the economic operator placing the battery on the market responsible for the passport being accurate, complete and up to date.
- No passport data model carries a flag for estimated or not available, so the provenance statement is our own practice.
- Every public row is in one of three states: declared by the operator, estimated by ActivateDigital or not stated.
Jump around this page
- What the law says about responsibility
- Why we added a provenance statement
- The rule: one of three states per row
- What the provenance statement contains
- What turns an estimate or a blank into a declaration
- What would change this page
- Frequently asked questions
- Get a free passport check
- Keep exploring
- Primary sources
What the law says about responsibility
Article 77(4): "The economic operator placing the battery on the market shall ensure that the information in the battery passport is accurate, complete and up to date. It may give written authorisation to any other operator to act on its behalf" (Regulation (EU) 2023/1542, Article 77). "Economic operator" is defined widely in Article 3(1)(22) to include the manufacturer, the authorised representative, the importer, the distributor and the fulfilment service provider. For a home storage battery made in China and sold under a European brand, the operator placing it on the market is usually the importer or the brand, not the cell maker.
The Commission FAQ repeats the point twice: "The economic operator placing the battery on the market remains responsible for compliance and for the data included". A written authorisation to a service provider "does not transfer the ultimate legal responsibility" (Commission FAQ on the battery passport). Article 78 adds that the passport data "shall be stored by the economic operator responsible ... or by operators authorised to act on their behalf". It must remain available after that operator ceases to exist.
The passport does carry two pointers to responsibility already. Annex XIII point 1(r) is the EU declaration of conformity. Article 7(1)(g), when it applies, is a public link to the study behind the carbon footprint. Both point at other documents. Neither says, row by row, whether a value was declared by the operator or produced by someone else.
Why we added a provenance statement
We looked for one. The Battery Pass consortium's content guidance, its data model, DIN DKE SPEC 99100, the Catena-X battery passport model and the IDTA submodels all type the sustainability rows as plain numbers with no flag for estimated, assessed or not available. The nearest things are a demonstrator disclaimer and an optional legal statement field in the Catena-X product carbon footprint model (Catena-X PCF Rulebook v4). The Global Battery Alliance's 2024 pilot passports went further than the specs and labelled each value by its evidence: external audit, standard, self-reported or validated (GBA battery passport pilots).
That gap matters most for the four rows no manufacturer publishes yet. A carbon footprint estimate built from public factors is useful. A carbon footprint estimate that a reader takes for the maker's Article 7 declaration is a misstatement with the operator's name on it. The only way to show the first without risking the second is to say, in the passport, which it is.
The rule: one of three states per row
| State | Who stands behind the value | What the row shows | What goes in the regulated field |
|---|---|---|---|
| Declared by the operator | The economic operator placing the battery on the market, or the manufacturer through it | The value, the operator's name, the date, the source document (study link, declaration, certificate) | The value |
| Estimated by ActivateDigital | Us, as a labelled estimate | A separate block: method name and version, the inputs used, the factor sources, the date, the central value and its range, plus a line saying it does not satisfy the legal requirement | Nothing. The regulated field stays empty and the row above reads "Not declared by manufacturer" |
| Not stated | Nobody yet | The legal status in words: which article, when it is due, which act is pending, checked on what date | Nothing |
Three habits keep the states apart. The estimate block looks different: its own heading, its own border, the word estimate in the title, the range printed with the number. The estimate never reuses the regulated property: in the data model it sits in an extension, so a machine reading the passport cannot mistake it for the declared value either. And no derived label is ever shown: a performance class letter, for instance, is never worked out from an estimate, because the classes do not exist yet and an estimate is not a declaration.
What the provenance statement contains
At the top of the passport, or wherever the public rows are listed: the name of the economic operator placing the battery on the market, the EU declaration of conformity number where held, the date the passport was last checked against the law, then one line per public row stating its state. For the four deferred or undefined rows the line also carries the legal reason, so a reader sees "Carbon footprint: not stated. Not yet required under Article 7; method act not adopted as at 6 November 2026" rather than an empty cell.
Where ActivateDigital publishes a passport on an operator's behalf, the statement names the written authorisation under Article 77(4) and the rows the operator has confirmed.
What turns an estimate or a blank into a declaration
For every row it is the same shape: the operator's value, the document behind it, the date and the operator's confirmation that it may be published. The specific documents differ by row and are set out in each field guide: the Article 7 study for carbon footprint, the chain of custody mass balance for recycled content, the bill of materials for renewable content. The moment the declaration arrives, the estimate block is removed, not merged. The row's state changes.
For the rest of the passport, where battery passport data comes from covers the evidence behind each row. Who can see which parts of the passport covers the access tiers the Regulation sets.
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What would change this page
- Adoption of the implementing act on access rights under Article 77(9), which may add rules on who can download, share or re-use passport data.
- A revision of the passport data models or DIN DKE SPEC 99100 that adds a provenance or data quality flag to the public rows.
- Adoption of the carbon footprint or recycled content acts, which would change the legal reason shown against those rows.
Frequently asked questions
Who is legally responsible for a battery passport?
The economic operator placing the battery on the market, under Article 77(4). That is often the importer or the brand rather than the cell manufacturer.
Can a service provider take on that responsibility?
It can publish and maintain the passport under written authorisation. The Commission FAQ says that authorisation does not transfer the legal responsibility.
Does the Regulation require a statement of who declared each value?
No. It requires the data to be accurate, complete and up to date. It carries the EU declaration of conformity. The row by row statement is our own practice, added so that estimates and blanks can be shown honestly.
Why not just show the estimate in the carbon footprint row with a footnote?
Because readers and machines both take the regulated row for the declared value. A footnote does not survive a copy. A separate block with its own label does.
What happens to the estimate when the maker declares?
It is removed and the declared value takes the row. The two are never averaged or combined.
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Get a free passport check
Bring one battery model and tell us who places it on the EU market. We'll show what its passport would say, row by row, about who stands behind each value. Request a free passport check.
Keep exploring
The questions this page usually raises next.
- CompareNext questionWhat Goes in a Battery Passport When the Manufacturer Hasn't Published the Data?Carbon footprint, recycled content, renewable content and who declared what are blank on every real battery passport.
- CompareNext questionCan You Estimate a Battery's Carbon Footprint for the EU Battery Passport?The passport carbon footprint is per kWh of lifetime energy, not capacity. No maker has declared one.
- CompareNext questionWhere Do Battery Passport Data Points Actually Come From?Battery Passport data comes from multiple evidence families, not one database.
Primary sources
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EU law
Does this reach your products?
ActivateDigital builds the battery record from the documents you already hold, and says which of the 32 fields in our battery model your evidence answers.