Evidence is product data, not an attachment
Product-passport and sustainability obligations become reliable when claims are connected to evidence. Certificates, test reports, supplier declarations, material data and safety information need versions and the right product context.
Nulara treats evidence as structured product objects. A document is not only stored in a folder; it is linked to product, variant, batch, data field, validity and responsibility — and referenced in the credential via a SHA-256 hash so tampering is detectable.
Which evidence typically becomes relevant
The Battery Regulation 2023/1542 requires a battery passport from 18 February 2027 for LMT batteries, electric-vehicle batteries and industrial batteries above 2 kWh. Article 77 and Annex XIII separate public model data, restricted model data, notified-body and authority data, and individual-battery data. Relevant evidence includes the EU declaration of conformity, carbon footprint, responsible-sourcing and due-diligence information, recycled content, test reports and state-of-health data. Under REACH and the Waste Framework Directive, SVHC information above 0.1% w/w matters both for communication duties and SCIP notifications.
- Conformity: EU declaration of conformity, CE-related documents, technical documentation, test reports and manufacturer declarations where the relevant legal act or delegated ESPR act requires them.
- Materials & SCIP: Substance information, REACH Article 33 communication, SCIP notification data from 0.1% w/w SVHC in articles and supplier evidence.
- Battery mandatory fields: For affected battery categories: carbon footprint, responsible-sourcing and due-diligence information, recycled content, state-of-health/performance data and test-report results with role-based visibility.
- Reporting: Product-level input data for CSRD/ESRS and Scope 3 processes; the actual reporting obligations remain company-level obligations.
How versioning reduces audit risk
A product passport is only as reliable as the sources behind its claims. If documents are overwritten or stored without validity, it later becomes unclear which state was published or used for reporting.
Nulara stores evidence with versions, approvals and data-field context. Teams can see whether a claim is reviewed, expired, replaced or still only prepared internally — ready for audit, market surveillance and certification.
Sources and next steps
The sources show why evidence must stay structured across product passport, battery passport and reporting contexts.
Read next in Nulara
- Battery Passport - Evidence and roles in the battery-passport context.
- CSRD - Bridge between product data and sustainability reporting.
- JSON-LD / Verifiable Credentials - Machine-readable and verifiable evidence structures.
Primary sources
- European Commission: ESPR and Digital Product Passport - Official context that concrete DPP information is set product group by product group.
- ECHA: SCIP database - Reporting obligation for SVHCs in articles above 0.1% w/w under Article 9 of the Waste Framework Directive.
- EUR-Lex: Regulation (EU) 2023/1542, Article 77 - Seven battery-passport data categories: conformity, carbon footprint, due diligence, materials, circularity, performance and general information.
- European Commission: corporate sustainability reporting - Official CSRD and ESRS context for sustainability reporting.
- EUR-Lex: Delegated Regulation (EU) 2023/2772 - Legal source for the first European Sustainability Reporting Standards.
- GHG Protocol: Scope 3 Standard - Method framework for indirect value-chain emissions.
Frequently asked questions
- Which documents belong on a product passport?
- That depends on the product and legal act. Common examples include declarations of conformity, test reports, material evidence, supplier declarations, SCIP references and validity-related approvals. For affected battery categories, carbon-footprint, due-diligence, recycled-content and performance data are added.
- What does role-based access mean for the Battery Passport?
- Battery Regulation Annex XIII distinguishes public data, restricted data, notified-body and authority data, and individual-battery data. Nulara maps this visibility at credential level so not every evidence field becomes public.
- Why is a document folder not enough?
- A folder does not reliably show which document version supports which product-passport claim, whether it is still valid and who approved it. Nulara links evidence, data field, validity and responsibility as structured objects.
