(EU) 2023/1542 · Annex XIII(1)(a) -> Annex VI, Part A(3)
Place of manufacture: which of the three plants is the right one
A battery is almost never made at one address. The cells come from one plant, the modules from another, pack assembly happens at a third — often across three companies and two countries. Point 3 of Part A of Annex VI asks for the place of manufacture as the geographical location of a battery manufacturing plant, in the singular, without saying which link in that chain it means. So companies enter what is at hand: the supplier's registered address. That is the most common error on this field, and the easiest one to spot.
A registered address is not a plant's geographical location
The address in the company register and the address of the production line are rarely the same thing. With large Asian suppliers the head office sits in one city and the plant in another province — and that gap is exactly the gap between the data the regulation asks for and the data that is easiest to obtain. The same applies to naming only a country: point 3 asks for the location of a plant, not for the country of origin from your customs paperwork.
The plant is the unit of account for two other obligations
Article 7(1) requires a carbon footprint declaration to be drawn up for each battery model per manufacturing plant, and lists information about the geographic location of the battery manufacturing plant among its mandatory items. Article 8(1) requires recycled content documentation for each battery model per year and per manufacturing plant. The plant you name here therefore has to be the plant those two documents are keyed to. If it is not, your own file contradicts itself, and that is visible without any analysis.
The field that changes without the product changing
Qualifying a second source or moving a line changes neither the datasheet nor the chemistry, but it changes this field. Article 77(4) requires the economic operator placing the battery on the market to ensure that the passport information is accurate, complete and up to date. This is therefore not a field to capture once at product launch, but a field with a trigger: qualifying a new plant has to trigger a passport correction.
Where it goes wrong
- The supplier's registered head office instead of the plant's geographical location.
- Naming only a country, although point 3 asks for the location of a plant.
- The pack assembly plant in this field and the cell plant in the recycled content documentation under Article 8(1), with no explanation of the difference.
- One location for a model built at two plants, although Article 7(1) requires a footprint declaration per plant.
- A one-off capture with no trigger when a new plant is qualified, despite Article 77(4).
Frequently asked
Which plant do we name — cell, module or assembly?
The text refers to a battery manufacturing plant and does not single out a link in the chain. Because Articles 7(1) and 8(1) are keyed to the manufacturing plant, your entry has to be reconcilable with them. Which reading you adopt is a legal question and we do not settle it for you.
Is naming the country enough?
Point 3 asks for the geographical location of a battery manufacturing plant. The country of origin on customs documents answers a different question and is not the same information.
What if the same model comes from two plants?
The regulation anticipates that case: Article 7(1) requires a carbon footprint declaration per model per plant, and Article 8(1) requires documentation per plant and per year. Annex VI provides one entry for this data point, so the divergence has to be resolved and the resolution recorded.
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