Guides / EU Battery Passport
EU Battery Passport data fields: checklist by access tier
Last updated 2026-11-01 · Based on Regulation (EU) 2023/1542 (consolidated text of 13 Aug 2026) and European Commission guidance v3.2 (19 Oct 2026) · ~10 min read
From 18 February 2027, every LMT battery, every industrial battery with a capacity above 2 kWh and every electric-vehicle battery placed on the EU market or put into service needs a battery passport: an electronic record reached through a QR code (Regulation (EU) 2023/1542, Art. 77(1) and 13(6)). This guide lists what goes into it, item by item, who is allowed to see each item, and what the European Commission's guidance says is required from day one.
Key facts
- Legal source of the fields: Annex XIII of Regulation (EU) 2023/1542, points 1 to 4.
- Four access tiers: public, legitimate interest (model data), authorities only, legitimate interest (individual battery) (Art. 77(2)).
- The Commission's guidance splits the fields into 71 data points and marks each one mandatory, optional, applicable only in certain cases, or not to be filled as of February 2027. The guidance is non-binding.
- Access is free of charge, according to each person's access rights (Art. 78(b)).
1. The four access tiers
| Who can see it | Annex XIII point | Legal basis | Guidance data points |
|---|---|---|---|
| Anyone (public) | Point 1: information on the battery model | Art. 77(2)(a) | 1–45 (45 points) |
| Persons with a legitimate interest and the Commission (also notified bodies and market surveillance authorities under Art. 77(2)(b)) | Point 2: battery model: detailed composition, spare parts, dismantling, safety | Art. 77(2)(b), (c) | 46–49 (4 points) |
| Notified bodies, market surveillance authorities and the Commission only | Point 3: test report results | Art. 77(2)(b) | 50 (1 point) |
| Persons with a legitimate interest | Point 4: the individual battery: performance values, state of health, status, usage | Art. 77(2)(c) | 51–71 (21 points) |
"Legitimate interest" covers, for model data, repairers, remanufacturers, second-life operators and recyclers who need it for their work, and for individual-battery data, the purchaser (or those acting for them) making the battery available to independent energy aggregators or energy market participants (Art. 77(2), third subparagraph).
2. Public fields (Annex XIII point 1)
Information on the battery model, open to anyone who scans the QR code.
| Annex XIII | Data field (per the Regulation) | Guidance # | Status as of Feb 2027 (EV · LMT · industrial) |
|---|---|---|---|
| Art. 77(3) | Unique identifier attributed by the operator placing the battery on the market, reached through the QR code | 1–2 | Mandatory for all three |
| 1(a) | Annex VI Part A label information: manufacturer; battery category and model identification; place and date (month, year) of manufacture; weight; capacity; chemistry; hazardous substances other than mercury, cadmium or lead; usable extinguishing agent; critical raw materials above 0.1 % weight by weight | 3–15 | Mandatory for all three (manufacturer web and email address: optional) |
| 1(b) | Material composition, including chemistry, hazardous substances and critical raw materials | 16 | Not to be filled as of Feb 2027 (repeats earlier data points) |
| 1(c) | Carbon footprint information (Art. 7(1) and (2)) | 17–18 | Not to be filled as of Feb 2027; applies as Article 7 provides |
| 1(d) | Responsible sourcing, as in the due diligence policy report (Art. 52(3)) | 19 | Not to be filled as of Feb 2027 |
| 1(e) | Recycled content, as in the Art. 8(1) documentation (cobalt, lithium, nickel, lead) | 20–23 | Not to be filled as of Feb 2027; applies as Article 8 provides |
| 1(f) | Share of renewable content | 24 | Mandatory for all three |
| 1(g) | Rated capacity (Ah) | 25 | Not to be filled (repeats data point 11) |
| 1(h) | Minimal, nominal and maximum voltage, with temperature ranges where relevant | 26–28 | Mandatory for all three |
| 1(i) | Original power capability (W) and limits, with temperature range where relevant | 29–30 | Mandatory for all three |
| 1(j) | Expected battery lifetime in cycles, and the reference test used | 31–32 | EV, LMT: mandatory · industrial: if applicable |
| 1(k) | Capacity threshold for exhaustion (EV batteries only) | 33 | EV: mandatory · LMT, industrial: not applicable |
| 1(l) | Temperature range the battery can withstand when not in use (reference test) | 34 | Mandatory for all three |
| 1(m) | Period for which the commercial warranty for the calendar life applies | 35 | If applicable |
| 1(n) | Initial round-trip energy efficiency and at 50 % of cycle life | 36–37 | EV, LMT: mandatory · industrial: if applicable |
| 1(o) | Internal battery cell and pack resistance | 38 | Mandatory for all three |
| 1(p) | C-rate of the relevant cycle-life test | 39–40 | Charge C-rate: EV, LMT mandatory, industrial if applicable · discharge C-rate: optional |
| 1(q) | Marking requirements of Art. 13(4) and (5) (corrected by corrigendum; separate-collection symbol, Cd/Pb symbol) | 41–42 | Art. 13(4) marking: mandatory · Cd/Pb symbol: if applicable |
| 1(r) | EU declaration of conformity (Art. 18) | 43 | Mandatory for all three |
| 1(s) | Waste prevention and management information, Art. 74(1)(a) to (f) | 44 | Mandatory for all three |
| — | Instructions for use (listed by the guidance under Annex XIII 1(t)) | 45 | On hold pending adoption of the Omnibus proposal (guidance v3.2) |
3. Restricted fields (Annex XIII points 2, 3 and 4)
| Annex XIII | Data field (per the Regulation) | Guidance # | Status as of Feb 2027 (EV · LMT · industrial) |
|---|---|---|---|
| 2(a) | Detailed composition, including materials used in the cathode, anode and electrolyte | 46 | Mandatory for all three |
| 2(b) | Part numbers for components and contact details of sources for replacement spares | 47 | Mandatory for all three |
| 2(c) | Dismantling information: exploded diagrams, disassembly sequences, fastening techniques, tools, warnings, number and layout of cells | 48 | Mandatory for all three |
| 2(d) | Safety measures | 49 | Mandatory for all three |
| 3 | Results of test reports proving compliance with the Regulation or its delegated / implementing acts | 50 | Mandatory for all three |
| 4(a) | Values of the Art. 10(1) performance and durability parameters for the individual battery (capacity and fade, power and fade, internal resistance and increase, round-trip efficiency and fade where applicable, expected lifetime) | 51–60 | EV, LMT: mostly mandatory (efficiency points if applicable) · industrial: if applicable |
| 4(b) | State of health (Art. 14) | 61–66 | EV: state of certified energy (SOCE) mandatory · LMT: remaining capacity, power, efficiency, self-discharge, resistance mandatory · industrial: if applicable |
| 4(c) | Battery status: original, repurposed, re-used, remanufactured or waste | 67 | Mandatory for all three |
| 4(d) | Usage information: number of charge/discharge cycles, negative events such as accidents, operating conditions including temperature, state of charge | 68–71 | If applicable |
"Guidance #" is the data point number in the Commission's guidance document; the status column summarises its EV, LMT and industrial columns. Item names are paraphrased; read the Regulation and guidance for the exact wording.
4. How many fields apply to you on day one
Counting the guidance's 71 data points by status (EV, LMT and industrial columns):
| Battery category | Mandatory | If applicable | Optional | Not to be filled as of Feb 2027 |
|---|---|---|---|---|
| Electric vehicle (EV) | 46 | 8 | 2 | 15 |
| Light means of transport (LMT) | 49 | 8 | 2 | 12 |
| Industrial, > 2 kWh | 31 | 26 | 2 | 12 |
5. Related dates
| Date | What applies | Where |
|---|---|---|
| 18 Aug 2024 | Performance and durability document (Art. 10(1)); state-of-health data in the battery management system (Art. 14(1)) | Arts. 10, 14 |
| 18 Aug 2025 | Separate-collection symbol marking (Art. 13(4)) | Art. 13(4) |
| 18 Aug 2026, or 18 months after the implementing act on labels, whichever is later | General label information (Art. 13(1)) | Art. 13(1) |
| 18 Aug 2026 (deadline set for the Commission) | Implementing acts on who counts as a person with a legitimate interest (Art. 77(9)). Check EUR-Lex for adoption status; we have not confirmed it. | Art. 77(9) |
| 18 Feb 2027 | Battery passport required for each LMT battery, industrial battery > 2 kWh and EV battery placed on the market or put into service; QR code giving access to it (Art. 13(6)) | Arts. 77(1), 13(6) |
| 18 Aug 2027 | Battery due diligence obligations (postponed by Regulation (EU) 2025/1561) | Art. 48; Reg. 2025/1561 |
| 18 Aug 2028, or 24 months after the delegated act, whichever is later | Recycled-content documentation for EV batteries, SLI batteries and industrial batteries > 2 kWh (except exclusively external storage); LMT batteries from 18 Aug 2033 | Art. 8(1) |
| Depends on delegated / implementing acts | Carbon footprint declaration, performance classes and thresholds (EV batteries first) | Art. 7 |
"Whichever is later" dates depend on Commission acts. Check the consolidated text and the list of amendments on EUR-Lex for the current position, including Omnibus proposals not yet adopted.
6. Steps to get ready
- Confirm scope. List every battery model you place on the EU market and classify it under Art. 3: LMT, industrial (note the 2 kWh threshold) or EV. Only those three categories need a passport from 18 Feb 2027.
- Name the responsible operator. The economic operator placing the battery on the market keeps the passport accurate, complete and up to date (Art. 77(4)). It may authorise another operator in writing, for example a passport service provider.
- Plan the identifier and QR code. Each passport is reached through a QR code (Art. 13(6)) linking to a unique identifier compliant with ISO/IEC 15459-1:2014, 15459-2:2015, 15459-3:2014, 15459-4:2014, 15459-5:2014 and 15459-6:2014 or equivalent (Art. 77(3)). The identifier must also be uploaded to the registry under Art. 13(1) of Regulation (EU) 2024/1781 (Art. 77(10)).
- Map each field to an owner and a source. Use the tables above: label and technical data come from engineering and test reports; composition and spares from R&D and supply chain; per-battery state-of-health and usage data from the battery management system (Art. 14).
- Separate model data from per-battery data. Points 1–3 describe the battery model; point 4 changes over the life of each individual battery and needs a data pipeline, not a one-off upload.
- Set access rights. Public, legitimate-interest and authority-only data must be served to the right audience free of charge (Art. 78(b)). Keep an eye on the Art. 77(9) implementing acts that define legitimate interest.
- Request supplier data early. Cell makers usually hold composition, resistance, cycle-life and test data. Put the requests in contracts now.
- Plan for life events. A repurposed or remanufactured battery gets a new passport linked to the original (Art. 77(7)); the passport ceases to exist after the battery is recycled (Art. 77(8)); data must stay available if the operator ceases to exist (Art. 78).
- Re-check the official sources before go-live. The Commission guidance is non-binding and "may be further developed", and several fields depend on delegated acts that were not yet applicable when we checked.
Get the working file
Our EU Battery Passport Readiness Kit puts all 71 data points into a bilingual (EN/中文) Excel gap assessment with category filters, status drop-downs, a readiness dashboard, a suggested owner and evidence source per point, a 13-week plan and a supplier data-request template. A team licence covers up to 5 users. Free related tool: Battery Pack Calculator.
AI-assisted content. This guide was drafted with AI assistance from the official texts listed under Sources. It has not been reviewed by a lawyer, homologation engineer or other qualified professional and is not legal or certification advice. Always read the current official text before relying on it. How we use AI. 本文由 AI 辅助根据官方原文整理,未经律师或认证工程师审核,不构成法律或认证意见,请以官方最新文本为准。
Sources (official)
- Regulation (EU) 2023/1542 (Batteries Regulation), Official Journal text, EUR-Lex
- Regulation (EU) 2023/1542, consolidated text of 13 August 2026, EUR-Lex
- European Commission, Digital Batteries Passport: data point by category (guidance v3.2, 19 Oct 2026, PDF)
- European Commission news: guidance to support preparations for the Digital Batteries Passport
- European Commission: Digital Product Passport for batteries
- Regulation (EU) 2025/1561 (postponement of battery due diligence obligations), EUR-Lex
欧盟电池护照数据字段清单(中文摘要)
依据欧盟电池法规 (EU) 2023/1542 第 77 条:自 2027 年 2 月 18 日起,投放欧盟市场或投入使用的每块 LMT 电池、容量大于 2 kWh 的工业电池和电动汽车电池都必须有电池护照,通过二维码(第 13(6) 条)访问。字段来自附件 XIII:第 1 点公开(型号信息);第 2 点仅限有合法利益者和欧盟委员会(以及公告机构、市场监管机构);第 3 点仅限公告机构、市场监管机构和欧盟委员会(测试报告结果);第 4 点仅限有合法利益者(单体电池的性能、健康状态、状态和使用数据)。欧盟委员会指南 v3.2 将其拆分为 71 个数据点(公开 45、受限 26),并标注 2027 年 2 月时的必填情况:电动车必填 46、LMT 49、工业 31。最后更新 2026-11-01;AI 辅助整理,未经专业人士审核,请以官方原文为准。