What data goes in an EU battery passport

People ask about the EU battery passport deadline. Fewer ask the harder question: what actually has to sit inside the passport?

That answer lives in Annex XIII of Regulation (EU) 2023/1542, the EU Batteries Regulation. Article 77 says each in-scope battery needs an electronic record from 18 February 2027. Annex XIII lists what that record must contain, and who is allowed to see which parts.

Here is the practical map.

The passport is a record, not a folder

Article 77 calls the battery passport an electronic record of an individual battery. It holds information about the battery model and information specific to that battery, including what happens while it is used.

That framing matters. If you treat the passport as a pile of PDFs to attach, you will fight the regulation every time a repairer, second-life operator or recycler needs a single field and you cannot hand them a whole document. The right shape is one shared record per battery: fields that different organisations write to over the battery's life.

That is how BPN, the Battery Passport Network, is built. It is a battery registry on a permissioned shared ledger (Hyperledger Fabric, still in pilot). Manufacturers, importers, repairers, auditors and recyclers each write to the same battery record. Files can attach to a record when needed; they are not the passport itself.

Four blocks inside Annex XIII

Annex XIII is organised by audience, not by department inside your company.

1. Public model data (point 1)

This is the layer anyone can read. It covers things people expect when they scan a QR code or compare products:

Manufacturer identity and where the battery was made
Category, mass, capacity, chemistry, hazardous substances and critical raw materials above 0.1% by weight (much of this also appears on the physical label under Annex VI Part A)
Carbon footprint information and related labelling (formats and some dates depend on later implementing acts)
Due diligence / responsible sourcing information referenced from the regulation's due diligence chapter
Recycled content shares for cobalt, lithium, nickel and lead, and the share of renewable content where required
Performance and durability values at model level: voltages, power, expected lifetime, round-trip efficiency, internal resistance, C-rate, markings, EU declaration of conformity, and waste information for end users

Not every public field must be filled on day one. The European Commission's August 2026 guidance, Digital Batteries Passport – data points by category (version 2.0), marks some Annex XIII items as not required to be filled or displayed as of February 2027, because formats or delegated acts are still coming. Carbon footprint declarations and several recycled-content percentages are in that bucket. Your systems still need a place for those fields so you are not redesigning the record in 2028.

2. Legitimate-interest model data (point 2)

This layer is for people who need the battery to stay useful after the factory gate: repairers, remanufacturers, second-life operators, recyclers, and others the Commission will pin down in an implementing act under Article 77(9).

It includes:

Detailed composition, beyond the public chemistry summary
Part numbers for components and contact details for spare parts
Dismantling information
Safety measures

These are still model-level facts. They are simply not for the general public.

3. Authority-only model data (point 3)

Point 3 reserves results of test reports proving compliance for notified bodies, market surveillance authorities and the Commission. That is the compliance evidence trail, not a marketing sheet.

4. Individual battery and use data (point 4)

This is where the passport stops being a static product sheet. For each physical battery, Annex XIII expects:

Performance and durability values for that unit
State of health information (tied to Article 14 and the battery management system)
Status: original, repurposed, re-used, remanufactured or waste
Use data: charge and discharge cycles, negative events such as accidents, and periodically recorded operating conditions (including temperature) and state of charge

A second-life operator and a recycler live here. Without trustworthy unit-level history, "second life" is a guess.

Access is per field, not public vs private

Article 77(2) does not invent a two-bucket lock. It maps Annex XIII points to audiences:

Point 1 → general public
Points 2 and 4 → persons with a legitimate interest (and the Commission, as written for point 2)
Point 3 → notified bodies, market surveillance authorities and the Commission

In BPN, those audiences are entity types on the network. Each field on the battery record can be visible to some entity types and hidden from others. A recycler sees dismantling and state-of-health fields; an anonymous scanner of the QR code sees the public layer; an authority credential can reach the conformity test results. Same record, different view.

Industry guidance such as the Battery Pass Content Guidance and DIN DKE SPEC 99100 turn Annex XIII into concrete attributes without replacing the legal text.

What has to be true by February 2027

Pulling the pieces together for an economic operator placing EV, LMT or industrial batteries above 2 kWh on the EU market:

One electronic record per battery, reachable through a QR code linked to a unique identifier (Article 77(3), with QR rules also in Article 13 and Annex VI Part C).
Model data and unit data both present, as Annex XIII requires.
Access rights enforced so public, legitimate-interest and authority fields do not all spill into one open page.
Room for fields that land later, when implementing acts fix carbon-footprint formats, recycled-content application dates, and who exactly counts as a person with a legitimate interest.

BPN's answer is configuration on a shared ledger: the battery schema and the per-field entity-type rules can move when the EU text moves, without pretending every operator should keep a private copy of the truth.

FAQ

Is Annex XIII only for electric vehicle batteries?

No. Article 77 applies the passport to electric vehicle batteries, light means of transport (LMT) batteries, and industrial batteries with a capacity greater than 2 kWh. The Commission's data-point guidance spells out which fields are mandatory, optional, conditional, or not required at launch for each of those three categories.

Do I need every Annex XIII field filled on 18 February 2027?

You need the passport, and you need the fields the regulation and the applicable acts require for your category at that date. The Commission's August 2026 data-point table is useful here: some Annex XIII items are marked as not to be filled or displayed as of February 2027 pending further acts. Plan the full schema now; enforce what is live then.

Where should the data live?

In one registry record per battery that every authorised operator can update, with field-level access. That is what BPN is for. It runs on Hyperledger Fabric and is still a pilot. If you make or import batteries for the EU market, see how BPN works or ask for a demo.

Sources

Regulation (EU) 2023/1542 — Article 77 and Annex XIII (Official Journal L 191, 28.7.2023)
European Commission, Guidance Document: Digital Batteries Passport – data points by category, version 2.0, 15 August 2026
Battery Pass consortium resources (Content Guidance / DIN DKE SPEC 99100)

If you are mapping Annex XIII into systems now, start from the four blocks, then decide which entity types own each write and each read. The deadline is a date. The data model is the work.