Requesting passport data from Chinese suppliers
Most Chinese battery and component suppliers have heard of the EU battery passport by now — many have not started. The usual failure mode is a buyer sending one large spreadsheet, hearing silence, and concluding the supplier is “not DPP ready”. In practice the supplier is stuck on three fixable things: what exactly is required, who is responsible for what, and in which format. This page gives you a workflow that fixes all three.
1. Split your field list in two
- Regulatory data points — Annex XIII items, tiered per the Commission guidance v2.0 (mandatory / conditional / deferred / voluntary). These are non-negotiable and shared by every battery in the category;
- Buyer-specific additions — your own sustainability or marketing asks (e.g. a specific LCA methodology, your platform onboarding). Price and schedule these separately; do not blend them into the regulatory ask.
The gap checklist tool marks every row with its tier, so the split is visible to both sides.
2. Put the duty split in writing
Under Regulation (EU) 2023/1542 Art 77(4) and 77(10), the operator who first places the battery on the EU market or puts it into service creates the passport and registers the unique identifier. A written mandate can delegate the work to the supplier or a service provider, but statutory liability does not transfer automatically. Three clauses to add to POs or contracts:
- Who creates and maintains the passport (you, the supplier under mandate, or a third-party platform);
- Who registers the unique identifier with the EU registry — and who carries organisation validation (legal persons need an eIDAS qualified seal under the current user guide);
- Data-update duties after sale (dynamic metrics, incident records) and how long each party keeps its data.
3. Send the bilingual request pack — not a bare spreadsheet
The free Supplier Request Pack ships English filing sheets plus Chinese instructions, so a factory quality engineer can act without translating your emails. Recommended email sequence (all three included as .txt files):
- Initial request: state scope (product, model, battery category), the field-list version, the format, and that you will confirm who registers;
- Acknowledgement (from supplier): confirms the responsible person, the data they already hold, and a gap list;
- Gap & clarification round: both sides mark missing items with owners and dates.
Field IDs in the pack match the tools on this site, so statuses move cleanly between your tracker and your supplier’s workbook.
4. Handle gaps without stalling
| Gap type | Realistic fix | What not to do |
|---|---|---|
| Deferred items (recycled content, due diligence — from 18 Aug 2027) | Plan now, collect later; note the later statutory date in the tracker | Don’t demand them for a Feb 2027 delivery |
| Conditional items (usage history, substances of concern) | Trigger only when the scenario applies; record the reason when not applicable | Don’t force “n-a” without a reason |
| Test reports against EU norms | Budget a testing round with a lab (EN/IEC methods differ from GB standards) | Don’t accept GB-only reports as substitutes |
| Carbon footprint | Await the delegated-act methodology; agree the accounting boundary early | Don’t convert a Chinese-method LCA number 1:1 |
| Upstream sourcing evidence | Push via your supplier to tier-2/3 with the same field IDs | Don’t demand full BOM/recipes — mark status, not values |
5. A realistic timeline (from today)
| When | Milestone |
|---|---|
| Weeks 1–2 | Triage done; duty split drafted; pack sent to top suppliers |
| Weeks 3–6 | First status returns; gap list consolidated; identifier scheme chosen (ISO/IEC 15459 agency) |
| Weeks 7–12 | Software/hosting shortlist and demos; organisation validation started if you register; testing scheduled |
| By Feb 2027 | Dry run on dummy data; live onboarding for first shipper batches |
Sensitivity note: sharing data across borders also touches Chinese data-export rules. The pack’s sharing checklist records recipient, purpose and version — most product-parameter data in international trade falls under exemptions, but personal information or “important data” requires a proper assessment (see the supplier-side page: 一本数据、两本护照).