For vehicle manufacturers, homologation teams and production operations in Europe and the United Kingdom.
An eCoC and a battery passport are separate records with different purposes. The eCoC concerns vehicle conformity in the type-approval workflow. The battery passport concerns a battery under the EU Batteries Regulation. Manufacturers can coordinate their source data, but completing one record does not establish completion of the other.
Article 77 of Regulation (EU) 2023/1542 sets 18 February 2027 for passports for electric vehicle batteries, light means of transport batteries and industrial batteries above 2 kWh placed on the market or put into service. The 2 kWh threshold belongs to the industrial-battery category; do not apply it as a blanket threshold for EV batteries. Build the applicability assessment around the actual battery and market.
| Question | Vehicle eCoC | Battery passport |
|---|---|---|
| What is the subject? | The vehicle’s conformity and approval-linked particulars. | The battery, with model-level and individual-battery information. |
| What is the reference framework? | The applicable vehicle type-approval and electronic CoC rules. | The EU Batteries Regulation, including Articles 77–78 and Annex XIII. |
| Which identity must stay clear? | Vehicle identity, approval reference and certificate version. | Battery identity and its relationship to the relevant battery record. |
| Which data owners are involved? | Homologation, engineering, production and certificate operations. | Battery suppliers and the responsible economic operator, with other owners as applicable. |
| What should a shared data project preserve? | The vehicle record and its released evidence. | The battery record and its own access and lifecycle requirements. |
| Does one replace the other? | No battery-passport completion is established by an eCoC. | No vehicle eCoC submission is established by a passport. |
The eCoC side should be assessed against the vehicle approval framework and the actual receiving route. The comparison above is a project-planning aid. It is not a universal data model or a claim that the two records share an authority endpoint.
A vehicle manufacturer may source battery systems from another organisation, integrate them into a vehicle and supply several markets. Those commercial relationships should be made explicit in the compliance project. Identify which legal entity has each responsibility and which supplier must provide the supporting information. Do not assign all passport responsibilities to the eCoC team merely because it already manages regulatory records.
Create separate sign-off lines for vehicle conformity and battery information. A common project board can coordinate delivery dates and data dependencies, while each responsible team reviews its own record. Supplier data availability, information-access rights and the response to a battery change should be settled before the production deadline creates pressure.
A useful internal model can relate a VIN to the battery installed at a particular point, while retaining the distinct battery identifier and the evidence for that relationship. Treat this as a proposed manufacturer data-control approach, not an assertion that every passport field belongs in an eCoC or that the VIN should replace the battery identity.
Plan what happens if the battery changes before vehicle release, if a supplier corrects its data, or if a later service event changes the installed battery. Determine which record owner reviews each event and which controlled record should change. Avoid overwriting historical relationships simply to make the latest configuration look consistent everywhere.
UK Government guidance for Northern Ireland describes the EU Batteries Regulation and the 2027 passport provision in that jurisdiction. A UK-based manufacturer supplying the EU also needs an EU-market assessment. Company location alone should not determine the compliance route.
For Great Britain, consult current UK rules rather than assuming automatic adoption of every EU passport requirement. The UK digital product records policy consultation discusses the UK approach. A consultation is policy context, not proof that an identical GB legal requirement has been enacted. Record the applicable market and the legal basis used by the project.
This market assessment should sit alongside, rather than inside, the vehicle eCoC delivery decision. A vehicle’s approval scheme, its UK or EU submission route and the battery’s market-access obligations must each remain understandable to the people approving the release.
| Work package | Concrete output | Review question |
|---|---|---|
| 1. Scope | Battery categories, economic operators and destination markets | Which actual products and entities are in scope? |
| 2. Source inventory | Supplier and internal data owners with available evidence | Who can provide and correct each required input? |
| 3. Identity mapping | Documented vehicle-to-battery relationships where needed | Can a configuration change be explained later? |
| 4. Record boundaries | Separate eCoC and passport data dictionaries | Are shared fields reused without merging obligations? |
| 5. Exception workflow | Missing-data, battery-change and correction scenarios | Who stops or approves the next release step? |
| 6. Acceptance evidence | Reviewed sample records for the actual routes | What proves the required record was completed? |
Illustrative scenario: an EV manufacturer receives an updated battery configuration shortly before vehicle release. The project should ask two questions. First, does the changed vehicle remain consistent with the applicable approval and certificate data? Second, which battery record and supplier information belong to the installed battery? A positive answer to only one question leaves the other workflow unresolved.
The teams can share an internal change reference and source evidence, while retaining separate decisions. If supplier passport information is missing, record that gap with its owner. If the vehicle data is wrong, use the vehicle conformity correction path. Do not create a dummy passport entry or alter a signed vehicle record to hide the mismatch.
Ask for a demonstration using one representative vehicle, its battery relationship and a controlled change scenario. Evaluate which data the proposed system actually manages, how source evidence is preserved, and which responsibilities remain with suppliers or other services. The presence of a QR code or a downloadable XML file does not by itself demonstrate completion of either regulatory workflow.
Electronic COC discussions should focus on the manufacturer eCoC operating workflow and its interfaces with your data landscape. Define any battery-passport service as its own scope and verify the responsible provider and acceptance criteria. Discuss your vehicle-data project, or review the related EV range and consumption data guide.
They address different subjects and obligations. An eCoC concerns vehicle conformity; a battery passport concerns the battery under its applicable framework. Completing one does not establish completion of the other.
Article 77 specifies electric vehicle batteries, LMT batteries, and industrial batteries above 2 kWh. The stated capacity threshold relates to industrial batteries, not a general exemption for smaller EV batteries.
Assess the actual destination and economic-operator role. EU supply and Northern Ireland require their own analysis. Check Great Britain’s current rules separately; a company’s UK location does not resolve all market obligations.
A manufacturer can design controlled reuse where meaning, permissions and applicability align. Preserve separate record identities, review responsibilities and lifecycle events instead of assuming a shared dataset fulfils both obligations.
Reviewed on 16 October 2026. Authority statements below are distinguished from our suggested operating controls. Receiving-system instructions and the applicable approval scheme govern the actual submission.
Continue with Electronic COC articles that connect eCoC readiness, manufacturer rollout and certificate release control.
Build a reliable EV eCoC data chain from approved WLTP records to the individual vehicle. Check range definitions, consumption units and configuration changes.
A practical guide to eCoC data ownership inside manufacturer teams, covering source systems, approval data, review responsibility and correction control.
Type Approval Data Checklist for eCoC Preparation: a practical Electronic COC guide for manufacturers planning type approval data for eCoC, Vehicle COC workflow and eCoC preparation.