Battery Passport: What Volkswagen’s Delivery Problems Can Teach Us About Compliance Readiness

Battery Passport: Make Time for Testing Before Compliance Determines Your Deliveries

What happens when new requirements take effect and a company is not ready?

In September 2018, Volkswagen passenger car deliveries in Europe fell by 42.6% compared with the same month a year earlier. One of the main reasons was difficulty meeting new EU requirements for emissions and fuel consumption testing. Parts of its range had not yet received the necessary approvals, limiting the availability of cars for customers.

What happened? From September, the new testing rules, known as WLTP, became a condition for registering most new cars in the EU. Yet, at the end of August, Volkswagen had secured the required approvals for only seven of its fourteen main model lines in Germany. The approval process for the rest of its range had not been completed in time. (Read more about the story — Reuters).

The story shows that even a large, experienced organisation can face restrictions on sales and deliveries when preparations for new requirements are not completed in time.

For manufacturers and importers preparing for the Battery Passport, it offers a useful lesson.

A Date in the Calendar Becomes a Business Requirement

From 18 February 2027, a battery passport will be required for light means of transport (LMT) batteries, electric vehicle batteries, and industrial batteries with a capacity greater than 2 kWh placed on the EU market or put into service in the EU.

For manufacturers and importers, this means factoring battery passport readiness into delivery planning. Alongside product availability, transport and documentation, companies will need to confirm that the relevant battery has the required passport containing the appropriate information.

WLTP type approval and the Battery Passport involve different requirements. They share an important principle: preparing a product for sale also means meeting the applicable regulatory conditions.

That makes it worth checking readiness early — before a particular customer delivery depends on it.

A Quick Launch and Verified Readiness

A Battery Passport solution can be put in place efficiently. Starting preparations early also allows a company to confirm that it works under its actual operating conditions.

Does the available data relate to the correct model and individual battery? Can its source be verified? Does the QR code lead to the right passport? Can the intended users access the appropriate information? What happens when a supplier submits a correction or a data gap appears?

These questions are best answered using real data and a representative batch of batteries.

The first delivery subject to the new requirement should not be the first test of the entire process.

What Should Be Checked Before the First Delivery?

The scope of testing should reflect the company's scale and way of working. Not every project needs extensive integration. Every project should, however, confirm a few essential elements:

• Data: the required information is available, consistent and linked to the correct batteries.

• Access: identifiers and QR codes work, and users can access the appropriate information.

• Responsibility: it is clear who verifies data, resolves discrepancies and approves changes.

• Exception handling: the company knows what to do when information is missing, a correction is needed or a supplier changes.

This verification also requires the client's participation. Its team understands the products, supplier relationships and order fulfilment process. An implementation partner can structure and guide the preparations, while joint verification helps ensure that the process fits the organisation's day-to-day operations.

Starting Earlier Creates Room for Decisions

A manufacturer may need to confirm information across several departments. An importer may need to agree with a supplier on what data will be provided and how it will be shared. In both cases, checking early establishes what already works and what still needs attention.

If the data is ready and the process works correctly, the company gains confirmation of its readiness. If gaps emerge, there is time to address them before the planned delivery.

Plan to be ready before the requirements take effect, leaving room for verification and any necessary adjustments.

Volkswagen's experience shows that adapting to new requirements can have a measurable impact on product availability, even in a large, experienced organisation. Battery Passport preparations therefore deserve a place in operational planning today.

At LexVolta, we help manufacturers and importers organise their data and prepare their Battery Passport processes to support predictable deliveries.

Want to establish what your company should check before 18 February 2027?

Email us at contact@lexvolta.eu or book a 15-minute introductory call. We will help you identify a practical first step.

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