(EU) 2023/1542 · Annex XIII(3)
Results of test reports: the passport tier only regulators see
This is the one passport field that neither a buyer nor a recycler will ever open. Its closed audience is exactly why it gets underestimated: since nobody in the industry will read it, it feels less pressing than the public fields. In fact it carries a decision that is easy to miss — how much of a document actually belongs in the passport, how much stays in the technical file, and how the list of reports grows every time the Commission adopts another act under this Regulation.
Results of reports are not the reports
Point 3 of Annex XIII speaks of the results of test reports proving compliance with the requirements of this Regulation or of any delegated or implementing act adopted pursuant to it. Module A in Part A of Annex VIII, by contrast, lists the test reports themselves among the elements of the technical documentation. Two artefacts, two homes: the full report with method, samples and raw measurements stays in the technical file, while the outcome goes into the passport. Companies do one of two things — upload the whole report, or assume the technical file already discharges the passport duty.
The scope does not stop at today's text
The reference to delegated and implementing acts means the list of reports is open-ended. The Regulation itself announces several: the delegated acts setting minimum values under Article 10(5), which the Commission is to adopt by 18 February 2026 for industrial batteries above 2 kWh and by 18 February 2027 for LMT batteries; the implementing acts on harmonised labelling specifications that Article 13(10) sets for 18 August 2025; and common specifications under Article 16. A list frozen today will have to be widened.
A notified body was not necessarily involved
The access tier is misleading as a label. Notified bodies are readers here, not necessarily authors. Article 17(1) allows conformity with Articles 6, 9, 10, 12, 13 and 14 to be assessed for series production under Module A — internal production control, where the manufacturer declares on its sole responsibility and no notified body appears. Only Article 17(2), for Articles 7 and 8 on carbon footprint and recycled content, requires Module D1 or G. So you may hold no notified body certificate at all for this field and still owe test results.
Method quality is a separate requirement
Article 15(1) requires tests, measurements and calculations for Articles 9, 10, 12, 13, 14 and 78 to be made using reliable, accurate and reproducible methods that take generally recognised state-of-the-art methods into account and whose results are deemed to be of low uncertainty. Presumption of conformity comes, under Article 15(3), only from a harmonised standard whose reference is published in the Official Journal of the European Union. A result with no stated method is weak evidence even when the number is right.
Substance evidence is the same pattern in other clothes
Article 6(1) places the Annex I restrictions of this Regulation in addition to those in Annex XVII to Regulation (EC) No 1907/2006 and in Article 4(2), point (a), of Directive 2000/53/EC. The words in addition to signal separate lists, not one shared list. A dossier assembled for REACH therefore does not by itself demonstrate compliance with Article 6, because it was built against a different list. And since Article 6 sits among the requirements assessed under Article 17(1), that evidence belongs to the results this field asks for.
Where it goes wrong
- Expecting the field to require a notified body certificate — under Module A there is no notified body in the procedure at all.
- Uploading complete test reports when point 3 asks for results; the reports belong in the Annex VIII technical documentation.
- Assuming a compiled technical file discharges the passport obligation by itself.
- A frozen list of reports that ignores the delegated and implementing acts the Regulation still announces.
- Carrying REACH files across as Article 6 evidence — Annex I to this Regulation is a separate list of restrictions.
Frequently asked
Who can see this field?
Only notified bodies, market surveillance authorities and the Commission. Article 77(2), point (b), sets that tier for the information in points 2 and 3 of Annex XIII.
Do I need a notified body?
Not necessarily. Article 17(1) allows Module A without a notified body for Articles 6, 9, 10, 12, 13 and 14, while Article 17(2) requires Module D1 or G for Articles 7 and 8.
When does this field fall due?
With the passport itself. Article 77(1) provides that from 18 February 2027 each LMT battery, each industrial battery above 2 kWh and each electric vehicle battery placed on the market or put into service has an electronic record.
How long must the evidence be kept?
Article 38(4) requires manufacturers to keep the technical documentation and the EU declaration of conformity at the disposal of national authorities for 10 years after the battery has been placed on the market or put into service.
Check whether you can prove this field
The free check runs through every mandatory field for your battery category. No sign-up.
Start the check