Which data must be included in the battery passport?
Five types of data form the core of the product passport
The battery product passport contains data on identification, materials, climate impact, performance and origin of the battery. Annex XIII of Regulation (EU) 2023/1542 (battery regulation) specifies which data these are exactly. Broadly speaking, they fall into five groups: data that identify the battery and the battery model (and that link to the data in the European battery database), data on material composition (chemistry, critical raw materials, share of recycled material), the carbon footprint of the battery, information on performance and durability (such as capacity, expected lifetime and warranty conditions), and information on the origin of raw materials in the context of due diligence. In addition, it contains practical information for those who must collect, dismantle or recycle the battery at the end of its life. Some of this data applies to the battery model as a whole, other data is specific to the individual battery or the batch in which it was produced.
The delimitation: which batteries this applies to
This data list applies to EV batteries, batteries for light means of transport (LMT, such as e-bikes and scooters) and industrial batteries above 2 kWh. For portable consumer batteries — the ordinary AA battery or a loose power bank cell — no passport requirement applies, and thus not this data list either. Nor does it apply that all data from Annex XIII must be visible to everyone: Article 77 of the battery regulation distinguishes user groups with different access, from the general public scanning the QR code to market actors, notified bodies or supervisory authorities who can access more or different data. So if you think the product passport is one public document with everything in it for everyone, you need to revise that picture: it is rather a layered database with one access point.
The deadline: from 18 February 2027
The obligation to maintain a battery product passport comes into effect on 18 February 2027. Until that date, there is no legal obligation to digitally disclose the data from Annex XIII via a product passport. This does not mean that nothing needs to happen until then: manufacturers and importers who already collect and organise the data will be in a better position when the obligation comes into effect than those who only do so at the last moment. No later fixed date than 18 February 2027 is specified in the text of the regulation; what is certain is this implementation date for the product passport itself, linked to Article 77.
What this means for anyone placing a battery on the market
The order in which this is usually tackled begins by determining which category the battery falls under — EV, LMT or industrial above 2 kWh — because whether the product passport requirement applies depends on this. This is followed by an inventory of which data from Annex XIII is already available, usually from the manufacturer: chemical composition, capacity and lifetime data typically come from technical documentation that already exists. Data on the carbon footprint and the origin of raw materials in the context of due diligence are more often an additional task, because these do not always feature as standard in existing product documentation. Next, this data is merged into the product passport, linked to a unique identification of the battery or battery model, and disclosed via a QR code on or with the battery. If you start this route only shortly before 18 February 2027, you risk that collecting missing data — particularly from suppliers further down the chain — takes more time than expected.
The substantiation: Article 77 and Annex XIII
The obligation to maintain a battery passport follows from Article 77 of Regulation (EU) 2023/1542 (Battery Regulation). The specific data that the passport must contain is detailed in Annex XIII of the same regulation. Article 77 also governs who may access which data, while Annex XIII provides the substantive list: from identification data to material composition, carbon footprint, performance data and information on the origin of raw materials. Both texts can be consulted via EUR-Lex, where the full regulation is published.
Those wishing to start now would do well to place their own product documentation alongside Annex XIII and review which data are already established and which are still missing — in particular, data on carbon footprint and origin of raw materials often require additional investigation with suppliers. Batpas.eu compiles the passport on the basis of the data supplied, hosts it for ten years and provides the QR data carrier that refers to the data.
What this is based on
- Regulation (EU) 2023/1542, Annex XIII (data in the battery passport)
- Regulation (EU) 2023/1542, Article 77 (battery passport)
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
Annex XIII of Regulation (EU) 2023/1542 (Battery Regulation) lists which data the battery passport must contain. It is a substantial list, structured into several categories that together provide a complete picture of the battery: from identification to chemistry, from performance to recycling. Article 77 of Regulation (EU) 2023/1542 (Battery Regulation) stipulates that this data is made accessible via the QR code. For a company that imports or places batteries on the market, this means above all: collecting data that often already exists somewhere at the manufacturer, and bringing it together in a structured manner.
Identification and basic data
Every battery that receives a passport must be traceable to a specific model or, in the case of industrial and EV batteries, to an individual unit. This requires a consistent method of type designation, production date and location, and a link between the physical product and the digital file. For an importer of, say, fifteen hundred e-bikes per year, this means that the basic data per batch or per serial number must clearly match what the manufacturer supplies — not what is on the packaging, because in practice these two still often diverge.
Composition and chemistry
The regulation requires data on the material composition and chemical composition of the battery. This is more than naming a product category: it concerns the type of battery and the materials used in sufficient detail to support the rest of the passport — from CO2 footprint to recycling instruction. How do I document the battery chemistry in the battery passport? goes into more detail on how that data is practically recorded, and what data about the materials in a battery do I need to provide exactly describes what level of detail is required in this regard.
Recycled material
For cobalt, lithium, nickel and lead, Annex XIII requires a statement of the proportion of recycled material. This figure does not come from an estimate, but must be traceable to the source of the raw materials as supplied by the manufacturer. For a trading company that purchases batteries from multiple manufacturers, this means that this data must be requested and kept separately per product line — and sometimes per supplier — because it differs per batch.
Performance and sustainability
Capacity, nominal voltage, expected service life and similar performance characteristics belong in the passport. This data typically comes from the manufacturer's technical documentation, but must be taken over in the correct form and unit. Which performance and sustainability data belong in the passport? sets out which fields this precisely covers.
State of health
For batteries already in use — such as a second-hand e-bike battery or an industrial battery that changes hands — the current state of health must be apparent. This is one of the few pieces of data that changes after sale, which requires a process that goes beyond filling in once. What is the state of health of a battery and why must it be included? describes what this concept means and when it becomes relevant.
Safety and hazardous substances
The passport also contains safety information and a statement of hazardous substances incorporated in the battery. For machinery manufacturers that install batteries in their own equipment, this is a piece of data that also connects to their own technical documentation. What safety information must be in the battery passport? and Which hazardous substances must I report in the battery passport? go into further detail here.
CO2 footprint
Annex XIII requires a statement of the CO2 footprint of the battery, made up of the life cycle from raw material to production. This is one of the arithmetically most laborious parts of the passport, and How do I determine the carbon footprint of a battery? describes how that calculation is built up in practice.
Collection and end of life
Finally, the passport contains information about collection, dismantling and recycling: how the battery must be handled at the end of its life and what steps are involved. Which data on collection and recycling belong in the battery passport? elaborates on this section further.
Where things go wrong in practice
A common situation is that an importer receives a technical datasheet from the manufacturer, but this datasheet does not cover all fields of Annex XIII — the CO2 footprint or the recycled content is missing, for example, because the manufacturer does not yet routinely track this. Another situation: data are filled in generically per product line, whereas the state of health must be tracked precisely for each individual battery once it is in use. It also occurs that a company has the material composition internally, but in a form that does not align with what the QR data carrier requires — resulting in delays when delivering the passport. A fourth situation is that hazardous substances appear on the safety data sheet, but have not been transferred to the passport format, causing these two documents to diverge.
What you can record
- An overview per product line of which data from Annex XIII are already available at the manufacturer, and which still need to be requested.
- A fixed request format towards manufacturers or suppliers, so that data are received in a usable and consistent form.
- An internal agreement on who is responsible for keeping up to date data that may change, such as the state of health — see also How often must I update the data in the battery passport?.
- An overview of which data are publicly accessible and which remain restricted to specific parties, with a reference to Who may view which data from the battery passport? and Must I make business-sensitive data publicly available in the battery passport?.
- An archive of the underlying source files per batch or serial number, so that a datum in the passport can always be traced back to the original statement by the manufacturer.
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.