Who may view which data from the battery passport?

Three levels of access: public, supervisory and stakeholders

Not everyone who opens the battery passport sees the same data: the passport has different access levels, ranging from freely accessible to everyone to restricted for a limited group of parties. Anyone who scans the QR code on a battery arrives at an information layer intended for the general public — think of general product information and performance data. In addition, there is a layer of data that is only accessible to parties with a demonstrable interest in that information, such as supervisory authorities, notified bodies, customs, and market participants further down the chain who deal with the battery (for example in repair, reuse or recycling). This division is not a choice of the platform or of the party compiling the passport, but follows from the system of the Battery Regulation itself, which determines for each data category who may access it.

For whom this applies, and what it does not cover

This access structure applies to the digital battery passport as mandated for batteries falling under the Regulation: EV batteries, batteries for light transport vehicles and industrial batteries above 2 kWh. The regulation concerns who may access which data within the passport — not the question of who may physically open, repair or dismantle the battery, and not about data protection in the sense of the GDPR. Personal data fall outside this system altogether; they have no place in a product passport and the access levels of the passport say nothing about them. Business confidential information, such as manufacturing secrets, is a separate category: it should not simply end up in the public layer of the passport, regardless of who else has access to other parts.

From 18 February 2027, no obligation until then

The obligation to maintain a battery passport — and with it the obligation to structure the access levels as the Regulation prescribes — will take effect from 18 February 2027. Until that date, there is no legal obligation to have a passport with tiered access. What is already established, however, is the text of the Regulation itself: Article 77 and Article 78 of Regulation (EU) 2023/1542 already lay down how the passport and access to it must look once the obligation comes into effect. Anyone now working with an importer or manufacturer on building a passport is therefore working within an established framework, even though its implementation is not yet mandatory.

How this works in practice for those having a passport compiled

For an importer or trader having a battery passport prepared, this begins with separating data by category: what information is intended for the end user or consumer who scans the QR code, and what information is only relevant to parties further down the chain, such as a recycler or a supervisory authority. That separation determines how the passport is technically set up — not every data set belongs behind the same QR code with the same openness. Next, it is important to determine which data from your own records (of manufacturer or importer) fall into the confidential category and therefore do not belong in the public layer, even though they are part of the passport. If you have the passport hosted by a third party, it is advisable to ask how that party technically separates the access levels: is the public layer truly kept separate from the layer for stakeholders, and how is it determined whether someone belongs to that latter group. That is a practical question that can be answered now, even without the obligation yet in force.

Where this comes from: Article 77 and Article 78

The obligation to provide a battery passport and the classification of data according to accessibility — public, and restricted to parties with a legitimate interest such as competent authorities and market actors in the value chain — is set out in Article 77 of Regulation (EU) 2023/1542 (Battery Regulation). Article 78 of the same regulation addresses the technical design and operation of the passport, and thus how those access levels are technically implemented, for example via the QR data carrier and the underlying systems. Together, these two articles form the basis for both the content (who may see what) and the form (how that is technically arranged) of the battery passport.

Those who wish to ascertain now which data will end up in which layer of the passport later on can best do so on the basis of their own product data: document which information is already available at the manufacturer or importer, and discuss with the party compiling the passport how that data is classified according to accessibility. For the precise, current text of Articles 77 and 78, the official publication in the EUR-Lex register is the appropriate source.

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

The battery passport is not a document with a single access level. Some data are accessible to anyone who scans the QR code, others only to a limited group of parties with a justified interest. This layering forms the basis of Article 77 of Regulation (EU) 2023/1542 (battery regulation), and is technically elaborated in Article 78. For a company that has the passport compiled, this distinction is relevant: it determines in part which data are and are not freely visible to competitors, customers and supervisors.

What is expected of you

Making a distinction between public and restricted access

The passport contains data that are accessible to the general public — think of general product information and safety information — and data that are only visible to specifically designated parties, such as market participants, notified bodies, or authorities responsible for market surveillance. For a company with 10 to 100 employees, this means that when submitting data to the platform, it must be clear in advance which data fall into which category. This is not always a technical choice; it also touches on the question of which information a company prefers not to have shared broadly.

Ensuring that sensitive information is not inadvertently made public

Not everything in the passport is intended for everyone. Some data, such as exact composition or supplier details, can be commercially sensitive. A company that has the passport compiled would be well advised to determine in advance which data fall under the heading of confidential and which must be publicly accessible. More on that distinction is described on the page on or whether business-sensitive data must be made public.

Allowing access to align with the role of the user

Whoever consults the passport sees a different picture depending on their role: a consumer who scans the QR code sees something different from a recycler who processes the battery at the end of its life, or a supervisor who checks whether obligations have been met. For a company, this means that the data that are submitted must be structured in such a way that the system can also deliver that role-based presentation. This affects, for example, the data on collection and recycling, which are primarily relevant to parties processing the battery at the end of its life, and less so to the average end user.

Ensuring the timeliness of data, regardless of who looks

Regardless of who has access, the information that is visible must be up to date. A supervisor who has access to data that no longer match the actual state of the battery will get little from it. How often data must be updated and who is responsible for it is explained on the page on how current the data in the battery passport must be.

Where things go wrong in practice

An importer of e-bike batteries supplies all data in a single file, without distinguishing between what should be public and what should have restricted access. The platform then cannot automatically determine which fields must be behind an access threshold, with the risk that sensitive information is broadly visible by default.

A manufacturer of industrial batteries assumes that the passport is only viewed by its own customer, and therefore does not provide separate instructions on who within the chain (recycler, supervisor, next owner) needs which data. When the battery is sold to a third party, this creates uncertainty about who may access which information.

A machine builder assumes that the exact material composition automatically remains confidential, without explicitly marking this when submitting. Because this distinction is not recorded, the information ends up in the part of the passport that is visible to everyone.

A battery trader switches software suppliers for their own product administration and submits the new dataset without re-specifying the previously agreed access levels. The result is that data that was previously restricted becomes treated as public in the new submission.

A scooter importer assumes that submitting data to the platform automatically means that supervisory authorities have access to it, without verifying whether this has actually been arranged — resulting in confusion at the moment an inspection takes place.

What you can record

An overview of which data from the passport fall under "publicly accessible" and which under "restricted access", per product category.
An internal agreement on who within the company is responsible for marking confidential data when submitting to the platform.
Documentation of the reasoning why certain data are marked as commercially sensitive, so that this can be explained when requested by a supervisory authority — see also the templates on the page about protecting commercially sensitive data.
A fixed procedure for updating data, including who is responsible for it and when it takes place.
An overview of the data categories that must be included in the passport, so that no category is overlooked when determining access levels — the basis for this is on the page about which data must be included in the battery passport.
An agreement with your own IT or data supplier on how role-based access is technically secured when data is submitted to the platform.

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.