How do I document the battery chemistry in the battery passport?

Battery chemistry is one of the mandatory data in the passport

You record battery chemistry by including the composition of the battery as part of the data collected for the battery passport, as mentioned in Annex XIII to Regulation (EU) 2023/1542. This concerns the type of battery chemistry — for example lithium-ion, nickel-metal hydride or another composition — as recognizable data within the passport, alongside other technical characteristics such as capacity and material origin. This data comes in practice from the manufacturer or importer of the battery, who is the first to know which cells and materials have been processed. In addition, separate from the passport, there is also a requirement regarding the chemical composition on the physical label of the battery itself, governed by Article 13 of the same regulation. The passport and the label are thus two separate places where chemistry information appears, each with their own purpose.

For whom this applies, and where the boundary lies

This subject matter applies to batteries that fall under the digital passport obligation: EV batteries, batteries for light vehicles (such as e-bikes and scooters) and industrial batteries above 2 kWh. For smaller portable batteries, such as individual batteries for consumer electronics, this passport obligation does not apply in the same way. It is also important what is not being requested: the passport asks for battery chemistry as recognizable data, not for a complete technical formulation or exact mixing ratios from the manufacturer. Proprietary production information therefore does not need to appear in the passport — it concerns the level of data listed in Annex XIII, not everything a manufacturer records internally. Furthermore, completing this data in the passport does not replace the separate labelling obligation under Article 13; both exist alongside each other.

From when this becomes mandatory

The obligation to maintain a digital battery passport, containing inter alia battery chemistry, will apply from 18 February 2027. Until that date, there is no legal obligation to disclose this data via a digital passport, although preparing for it can be worthwhile since the data are often already recorded somewhere at the manufacturer or importer. What is already mandatory at present, separately from the passport obligation, is the labelling requirement from Article 13 — this stands on its own and is not linked to the passport start date.

How this is handled in practice

The first step is to establish what chemistry type the battery actually has — this information typically comes from the cell manufacturer or is already mentioned in technical documentation provided upon import or purchase. The second step is to name this data unambiguously, so that it aligns with the classification used in the passport (for example a standard designation of the chemistry instead of an internal product code). The third step is to provide this data, together with the other required information from Annex XIII, to the party that assembles and hosts the passport — in the case of batpas.eu this is done on the basis of data supplied by the manufacturer or importer. An important consideration: if a product is supplied in multiple batch sizes or cell variants, it is important to clearly identify which chemistry applies to each variant, so that the passport displays the correct chemistry for the correct product. Finally, it is advisable to check that the chemistry designation on the label (in accordance with Article 13) and that in the passport correspond with each other, so that no contradictory information arises between the physical product and the digital data.

The legal basis: Annex XIII and Article 13

That battery chemistry belongs in the passport follows from Annex XIII of Regulation (EU) 2023/1542, which lists the data that the battery passport must contain. That there is also a separate requirement regarding chemical composition on the label of the battery itself follows from Article 13 of the same regulation, which governs the labelling and marking of batteries. For the precise wording and classification of this data, the official text of the regulation is the appropriate source, since the exact wording is decisive for how a given item is classified and assessed.

If you want to start now, it is best to begin by collecting the technical documentation in which the cell chemistry of the product is specified, and to check whether the current label already meets the requirements of Article 13. This data forms the basis on which the digital passport can be built later, quickly and without complications.

What this is based on

The Regulation itself is on EUR-Lex. We refer for each statement; you need not believe us.

What you need to do concretely

What is expected of you

Battery chemistry is one of the data points that, according to Annex XIII of Regulation (EU) 2023/1542, belongs in the battery passport. It concerns the designation of the type of chemistry on which the battery is based — for example lithium iron phosphate, lithium nickel manganese cobalt or a lead acid variant. This may seem straightforward, but in practice three separate obligations apply.

Naming the chemistry correctly

The designation of battery chemistry must correspond with what is actually in the cell, and not with a marketing name or a collective term that the manufacturer uses internally. For a company with 10 to 100 employees, this usually means that someone must consult the technical documentation from the cell manufacturer — often a datasheet in English or Chinese — and take the chemistry designation from it in the form that the regulation expects. For composite batteries with multiple cell types (for example in larger industrial applications), it is necessary to establish whether there is one dominant chemistry or whether multiple chemistries must be listed separately.

Aligning the designation with the labelling

Article 13 of Regulation (EU) 2023/1542 sets requirements for the labelling and marking of batteries, including information about composition. The chemistry designation in the passport and that on the physical label should match. For an importer who takes batteries from multiple suppliers, this means that a control step is needed: does what is on the box or nameplate correspond with what is entered in the passport? Where discrepancies arise — for example because a supplier has changed cells without updating the type number — this must be resolved before publication.

Linking chemistry recognisably to other passport data

Battery chemistry does not stand alone in the passport. It is linked to which hazardous substances must be reported, to the manner in which the material composition is specified, and to the way in which the share of recycled cobalt, lithium, nickel and lead is demonstrated. For a company that has the passport compiled on the basis of supplier data, this means that the chemistry designation serves as a fixed anchor point: all other technical data must be consistent with it. A passport that states the chemistry as "lithium iron phosphate" but lists cobalt compounds in the hazardous substances list that do not fit with that type of chemistry raises questions.

Where things go wrong in practice

An importer of e-bike batteries takes the chemistry designation from the supplier's webshop text, while the actual cell specification states a different composition. The webshop text is written for sales, not for technical accuracy, and the two sources do not match.

A scooter retailer works with multiple battery packs that are externally identical but come from different cell suppliers. Because the type designation on the outside is the same, it is assumed that the chemistry is also the same — while the supplier has meanwhile changed cells.

A machine builder who assembles industrial battery packs above 2 kWh from purchased modules uses the same generic chemistry designation for each passport, even when different modules in practice contain different cell chemistries.

At a manufacturer, the chemistry designation is correctly recorded on first entry, but not updated when the cell supplier changes later. This also touches on the question how current the data in the battery passport must be — a chemistry designation is not a one-time entry, but data that is affected by every change in the supply chain.

A company lists the chemistry in the passport in a different notation than on the physical label — for example an abbreviation in the passport versus a fully written name on the label — which means that on inspection it is not immediately clear whether it is the same battery.

What you can record

The cell manufacturer's technical datasheet, containing the chemistry designation as used by the manufacturer itself.
An internal translation table or naming convention that links the manufacturer term to the designation used in the passport, so that different staff members refer to the same chemistry in the same way.
Correspondence or procurement documentation in which a cell replacement with a supplier is recorded, including the date on which this was implemented in the passport.
A comparison between the chemistry designation on the physical label (in accordance with Article 13 of Regulation (EU) 2023/1542) and the designation in the passport, as a control step before publication.
An overview per product line or type number of which chemistry is contained therein, especially for companies that offer multiple variants of the same physical model.
A note on the relationship between the chemistry designation and the reported hazardous substances, so that an inspector can see at a glance that both data sets match.

For a broader overview of which data besides chemistry are also mandatory, the page on which data exactly must be included in the battery passport is a suitable starting point.

This is not legal advice. This page provides general information about the legislation that this platform covers. We do not know your situation. If in doubt about your own case, consult a lawyer or the competent supervisory authority.

Written with AI based on the sources above, checked by a human on 2026-08-22. Is something wrong? Let us know — corrections take priority.