Battery Passport Data: Every Annex XIII Attribute, Who Can See It and the Unique Identifier

Each point has its own group of readers.

The duty rests on Article 77(1) of Regulation (EU) 2023/1542, which is directly applicable. A passport is required for each LMT battery, each industrial battery with a capacity greater than 2 kWh and each electric vehicle battery placed on the market or put into service under the EU Battery Regulation.

Each passport holds the listed information only to the extent it applies to the battery's category or sub-category (Article 77(2), fourth subparagraph). An LMT battery therefore carries no capacity threshold for exhaustion, which point 1(k) requires for electric vehicle batteries only.

What Annex XIII Requires the Passport to Hold

Article 77(2) requires the passport to hold information on the battery model and information specific to the individual battery, including information resulting from its use, as set out in Annex XIII. Model information describes the design, while individual information follows one battery through its life (consolidated text on EUR-Lex).

Annex XIII splits the data into four points, each with its own access group under Article 77(2), second subparagraph, so one passport serves three kinds of reader. Scope and the responsible operator are covered on the EU battery passport page.

The Complete Attribute Table, Point by Point

The table lists all 28 items of Annex XIII in force with their access group, their source and the matching data point of the Commission guidance. The data point numbers come from that non-binding guidance, not from the text of the Regulation.

Point 1: Public Information on the Battery Model

Point 1 of Annex XIII lists 19 items, (a) to (s), that the general public can read through the battery's QR code, from the general label information and material composition to the EU declaration of conformity and the waste information of Article 74(1). It is the only point open to everyone.

Points 1(g) to 1(p) carry the technical values of the model, such as rated capacity in ampere-hours, voltage, power capability in watts and expected lifetime in cycles. Point 1(q) has read "Article 13(4) and (5)" since the corrigendum of 10 April 2026 (OJ L 2026/90285).

Composition appears twice: publicly in point 1(b) and in detail, behind access control, in point 2(a). The Commission FAQ for batteries (question 7.7) calls a 1 % threshold (DIN DKE SPEC 99100) and a 0.1 % threshold (a draft CEN technical specification) both "potentially reasonable" if more detailed than a chemistry label.

Fields That Depend on Other Requirements and Their Dates

Five passport fields carry values that another article of the Regulation produces: carbon footprint (Article 7, point 1(c)), responsible sourcing (Article 52(3), point 1(d)), recycled content (Article 8(1), point 1(e)), performance and durability (Article 10(1), point 4(a)) and state of health (Article 14, point 4(b)). Each is filled once its source obligation applies.

Two of the five values exist from the first day of the passport: Articles 10(1) and 14 have applied since 18 August 2024 for the batteries they cover. Responsible sourcing follows the due diligence obligations, which apply from 18 August 2027 (Article 48(1), as amended by Regulation (EU) 2025/1561).

Carbon footprint and recycled content run on "whichever is the latest" dates tied to Commission acts.

No stage of Article 7 applies as of 13 November 2026, because neither its methodology delegated act nor its format implementing act is adopted; the recycled content methodology act is a draft. Every date is in the EU Battery Regulation timeline.

The table sets out the five fields and their status.

Point 2: Restricted Model Information on Composition and Dismantling

Point 2 of Annex XIII holds four items on the battery model that only persons with a legitimate interest, notified bodies, market surveillance authorities and the Commission may read: the detailed composition, spare-part numbers and sources, dismantling information and safety measures. Point 2(a) names the cathode, anode and electrolyte materials.

Point 2(c) defines dismantling information: exploded diagrams, disassembly sequences, the type and number of fastening techniques, tools, warnings, and the number and layout of cells. Guidance version 3.2 merged former data points 46 and 47 and added member states and notified bodies as readers of data points 46 to 49.

Point 3: Test Reports for Notified Bodies and Authorities

Point 3 of Annex XIII holds the results of test reports proving compliance with the Regulation or its delegated and implementing acts, accessible only to notified bodies, market surveillance authorities and the Commission. The guidance maps point 3 to one entry, data point 50.

Point 3 connects the passport to conformity assessment: the test results that prove compliance sit in the passport for the authorities that check it. Neither the public nor persons with a legitimate interest read them, unlike the notified bodies under the Battery Regulation.

Point 4: Data on the Individual Battery and Its Use

Point 4 of Annex XIII holds data on the individual battery that only persons with a legitimate interest may read: the Article 10(1) performance and durability values at placing on the market and on any status change, the state of health under Article 14, the battery's status and data resulting from its use. These fields follow one battery.

Point 4(c) records the status as "original", "repurposed", "re-used", "remanufactured" or "waste". Point 4(d) covers charge and discharge cycles, negative events such as accidents, operating conditions including temperature, and the state of charge; the guidance applies data points 68 to 71 as soon as the battery starts to be used.

A battery prepared for re-use, prepared for repurposing, repurposed or remanufactured receives a new passport linked to the original (Article 77(7)), and the passport ceases to exist after the battery has been recycled (Article 77(8)). Status changes are covered under second-life batteries.

Who Can See Which Data: The Three Access Groups

Article 77(2) sorts passport data into three access groups: the general public reads point 1, notified bodies, market surveillance authorities and the Commission read points 2 and 3, and persons with a legitimate interest read points 2 and 4. Point 2 is the only point two groups share.

Access is regulated in line with the essential requirements of Article 78 (Article 77(6)) and is free of charge according to the access rights (Article 78(b)). The operator hosting the passport manages access; the EU registry does not give access to the full passport (Commission FAQ 6.5).

The table sets out the three groups with their legal basis.

Persons with a Legitimate Interest and Their Two Purposes

Article 77(2), third subparagraph, limits legitimate-interest access to two purposes. The first is dismantling information, including safety measures and the detailed composition, for repairers, remanufacturers, second-life operators and recyclers.

The second, for individual batteries, is information the purchaser or parties acting on its behalf need to offer the battery to independent energy aggregators or energy market participants.

Authentication of these persons is not set centrally: Commission FAQ 6.4 treats it as decentralised and names national registers of recyclers and waste operators as a possible aid. Article 14(2) separately gives the legal purchaser and third parties acting on its behalf read-only access under the battery management system and state of health rules.

The Article 77(9) Access Act: Draft Status as of 13 November 2026

As of 13 November 2026 the Commission has not adopted the implementing act under Article 77(9) that specifies the persons with a legitimate interest and the data they may access, download, share, publish and re-use. The statutory deadline for that act was 18 August 2026.

A draft, Ares(2026)9814179, was published on 19 October 2026 under Have Your Say initiative 16473, with feedback until 16 November 2026 and 37 responses by 12 November 2026. It is in inter-service consultation, with adoption planned for the fourth quarter of 2026.

Article 77(9) binds the act to three criteria: evaluating the battery's status, residual value and capability for further use; supporting preparation for re-use, preparation for repurposing, repurposing, remanufacturing or recycling; and limiting commercially sensitive information to the minimum necessary. Pending acts are tracked under battery regulation implementing acts.

The Unique Identifier and How It Links to the Data

The unique identifier is "a unique string of characters for the identification of batteries that also enables a web link to the battery passport" (Article 3(1), point (66)), attributed by the economic operator placing the battery on the market and reached through the QR code (Article 77(3)). It ties the physical battery to its data.

Article 77(3), second subparagraph, requires compliance with the six parts of ISO/IEC 15459, namely 15459-1:2014, 15459-2:2015, 15459-3:2014, 15459-4:2014, 15459-5:2014 and 15459-6:2014 "or their equivalent". A draft delegated act, Ares(2026)9188325, would amend these references, but the Commission had not adopted it as of 13 November 2026.

Under Commission FAQ 5.2, an identifier is created locally or through a commercial service, stored with the passport and registered in the EU registry (Article 77(10), inserted by Regulation (EU) 2024/1781). The QR code is required on every battery by Article 13(6), as set out under battery labelling and QR code requirements.

Data Format and Data Model: What Is Binding as of 13 November 2026

Regulation (EU) 2023/1542 sets no binding data model for the battery passport as of 13 November 2026: Article 77(5) only requires data based on open standards, in an interoperable format, transferable through an open interoperable data exchange network without vendor lock-in, machine-readable, structured and searchable. Annex XIII fixes the content.

Article 78 adds design requirements, such as storage by the responsible operator or its authorised operators, with no sale or re-use of the data beyond the service. It grants no implementing power: only harmonised standards published for that purpose give a presumption of conformity (Article 15(3)), with common specifications as fall-back (Article 16(1)).

The general digital product passport for other products follows the separate EU ecodesign rules. The registry's API Integration Guide and Semantic Data Guide, published on 30 October 2026, cover registration, not passport content. Industry attribute lists and data models are described under battery passport standards.

The Commission's 71 Data Points by Category

The Commission's guidance "Digital Batteries Passport - data point by category", version 3.2 of 19 October 2026, breaks Annex XIII into 71 data points and marks each as applicable per battery category; it is non-binding and does not introduce legal requirements. The guidance document follows Annex XIII point by point.

Our count of cells reading exactly "Mandatory" gives 45 for electric vehicle batteries, 48 for LMT batteries and 31 for industrial batteries. Version 3.2 added data point 40 and limited data points 51 to 66 to specific industrial batteries, after an earlier update the Commission announced on 21 August 2026.

The table gives the count per category with its specific data points.

Table: Our count of cells reading exactly "Mandatory" in guidance version 3.2, made on 12 November 2026; see methodology and fact-checking.

Eight Data Points Not Filled from February 2027

The guidance lists eight data points that are not to be filled when passports start, because the obligation behind them does not yet apply. They are data points 17 and 18 (carbon footprint declaration and label), 19 (responsible sourcing), 20 to 23 (recycled cobalt, lithium, nickel and lead) and 45 (instructions for use).

Data points 17 and 18 wait for the implementing act on the carbon footprint format. Data point 19 is "required from August 2027" in the guidance's wording, matching the Article 48(1) date above, and data point 45 cites point 1(t) of a pending proposal. Data point 19 rests on battery due diligence.

How to Prepare the Passport Data

Preparing passport data means assigning each Annex XIII item to an owner and a source document before the passport date, because the economic operator placing the battery on the market answers for accurate, complete and up-to-date data under Article 77(4).

A written authorisation for another operator does not transfer that responsibility (Commission FAQ 2.1), and six steps follow.

1. Confirm which battery category applies.
2. Map each attribute table row to an owner and a source document.
3. Flag the five dependent fields and eight unfilled data points.
4. Attribute identifiers under ISO/IEC 15459 and plan the registry upload.
5. Restrict points 2 to 4 and check that battery passport software meets Articles 77(5) and 78.
6. Align points 1(r) and 3 with the technical documentation.

Need help preparing battery passport data? The full sequence by role and category is set out in the battery regulation compliance programme.

Proposed Changes to Annex XIII and Other Passport Rules

The Commission proposal COM(2025) 504 (procedure 2025/0134(COD)) would add point 1(t), instructions for use for stationary battery energy storage systems only, and as of 13 November 2026 it is pending: the agreed text was approved in committee on 14 July 2026 and the plenary is indicatively set for 23 November 2026. Point 1(t) is not law.

The Commission proposal words it as instructions for use that can be printed, downloaded and saved on an electronic device for access at all times, and the procedure status reads "Awaiting Parliament's position in 1st reading" (OEIL). It is tracked among the pending battery regulation amendments.

Passport Data Questions

Five questions recur about the data a battery passport holds.

Is all passport data public?

No: only point 1 of Annex XIII is public. Points 2 and 3 are restricted to notified bodies, market surveillance authorities and the Commission, and points 2 and 4 to persons with a legitimate interest (Article 77(2), second subparagraph).

Does the passport need real-time use data?

No: the Commission's FAQ for batteries says dynamic data must be updated at least when the battery's status changes and that real-time updates are not required. The FAQ is non-binding guidance.

In which language must the passport data be given?

Information that is not language-neutral is given in the language or languages easily understood by end-users, as determined by the member state where the battery is made available (Commission FAQ 7.4). The FAQ itself is non-binding.

Must the carbon footprint fields be filled in February 2027?

No: guidance version 3.2 marks data points 17 and 18 as not to be filled, because Article 7 does not yet apply to any category as of 13 November 2026. The obligation is explained under carbon footprint declaration.

Can the Commission change the Annex XIII list?

Yes: Article 77(2) empowers the Commission to amend Annex XIII by delegated act, under a delegation of five years from 17 August 2023 that is tacitly extended (Article 89(2)). No act has amended Annex XIII as of 13 November 2026; only a corrigendum changed point 1(q).