# EU Battery Passport: A Field-by-Field Guide to Annex XIII

> A practical guide to battery passport data fields, access rights, lifecycle updates, phased sustainability requirements and implementation readiness.

## The battery passport is an individual-battery record

From **18 February 2027**, electric-vehicle batteries, light means of transport batteries and industrial batteries with capacity greater than 2 kWh must have a battery passport when placed on the EU market or put into service. Article 77 of Regulation (EU) 2023/1542 establishes the obligation; Annex XIII specifies its information categories. This is not a universal passport requirement for every portable or starter battery. [2](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023R1542)

The passport combines information about the **battery model** with information about the **individual battery**. A QR code connects the physical battery to its unique identifier and electronic record. The responsible economic operator must ensure that information is accurate, complete and up to date.

A critical implementation distinction is that the passport’s launch does not accelerate every underlying sustainability obligation. Carbon-footprint declarations, recycled-content documentation and due-diligence reporting have their own application rules. The Commission’s October 2026 guidance explicitly distinguishes fields required at launch from information that is conditional or not yet required to be displayed. [1](https://single-market-economy.ec.europa.eu/document/download/cd1e5e6c-4a4a-4b99-995a-49eb6916187e_en)

## Annex XIII: public model-level information

The following table covers every lettered category in Annex XIII, section 1. “Static” and “dynamic” are implementation descriptions, not separate legal classifications. Static information still needs version control when specifications or supporting documents change.

All fields below are publicly accessible under Annex XIII; applicability remains subject to battery category and the underlying provision. [2](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023R1542)

| Field | Required information | Typical update pattern |
|---|---|---|
| 1(a) | Annex VI, Part A general battery information | Mostly static |
| 1(b) | Material composition: chemistry, hazardous substances other than mercury, cadmium or lead, and critical raw materials | Static by model/version |
| 1(c) | Article 7 carbon-footprint information and performance class | Versioned as applicable |
| 1(d) | Responsible-sourcing information from the Article 52(3) due-diligence report | Periodic |
| 1(e) | Article 8 recycled-content information | Periodic/model-plant-year |
| 1(f) | Share of renewable content | Versioned |
| 1(g) | Rated capacity, in Ah | Static baseline |
| 1(h) | Minimum, nominal and maximum voltage, including relevant temperature ranges | Static baseline |
| 1(i) | Original power capability, limits and relevant temperature range | Static baseline |
| 1(j) | Expected lifetime in cycles and reference test | Static baseline |
| 1(k) | Capacity threshold for exhaustion, for EV batteries | Static baseline |
| 1(l) | Non-use temperature range and reference test | Static baseline |
| 1(m) | Commercial warranty period for calendar life | Versioned terms |
| 1(n) | Initial round-trip efficiency and efficiency at 50% of cycle life | Model/test information |
| 1(o) | Internal cell and pack resistance | Model baseline |
| 1(p) | C-rate used in the relevant cycle-life test | Static test metadata |
| 1(q) | Applicable separate-collection and chemical-symbol markings | Versioned compliance information |
| 1(r) | EU declaration of conformity | Versioned document |
| 1(s) | Article 74(1)(a)–(f) waste-prevention and management information | Periodically reviewed |

### Unpacking the incorporated fields

Field 1(a) incorporates more than a product name. Annex VI, Part A covers manufacturer identification, battery category and identification, place and date of manufacture, weight, capacity, chemistry, specified hazardous substances, suitable extinguishing agents and critical raw materials above the relevant concentration threshold. These should be structured attributes, not buried in an unsearchable label image. [2](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023R1542)

Similarly, field 1(s) incorporates instructions on waste prevention and life extension; users’ contribution to separate collection; available collection, reuse and recycling arrangements; safety when handling waste batteries; the meaning of markings; and the environmental, health and safety implications of substances in batteries.

The passport therefore needs both **machine-readable values** and understandable instructions. A numerical capacity field cannot substitute for safe waste-handling guidance.

## Restricted model information and individual-battery data

Annex XIII creates distinct access groups. Public visibility must not be confused with access for a repairer, recycler or authority. The following table covers sections 2–4 and their update characteristics. [2](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023R1542)

| Field | Information | Access group | Update pattern |
|---|---|---|---|
| 2(a) | Detailed composition, including cathode, anode and electrolyte materials | Persons with a legitimate interest | Model/version |
| 2(b) | Component part numbers and contact details for sources of replacement parts | Persons with a legitimate interest | Periodic |
| 2(c) | Dismantling information, including diagrams, disassembly sequences, fastenings, tools and warnings | Persons with a legitimate interest | Model/version |
| 2(d) | Safety measures | Persons with a legitimate interest | Periodic |
| 3 | Test-report results proving compliance with the Regulation or relevant delegated or implementing acts | Notified bodies, market-surveillance authorities and Commission | Versioned evidence |
| 4(a) | Performance and durability values when placed on the market and following changes in status | Persons with a legitimate interest | Baseline plus events |
| 4(b) | State-of-health information under Article 14 | Persons with a legitimate interest | Dynamic |
| 4(c) | Battery status: original, reused, repurposed or remanufactured, or waste | Persons with a legitimate interest | Event-driven |
| 4(d) | Use-related information: cycles, negative events, operating conditions and charging history | Persons with a legitimate interest | Dynamic |

“Legitimate interest” is not a licence to expose all restricted data to anyone who registers an account. Operators need a documented access policy aligned with applicable implementing rules, purpose limitations and confidentiality protections.

Dynamic information also requires interpretation. A state-of-health value without its timestamp, measurement method and battery identity is difficult to use safely. Retain the original baseline separately from subsequent measurements rather than overwriting history.

## Carbon-footprint phase-in under Article 7

Article 7 separates **declarations**, **performance classes** and **maximum thresholds**. The statutory dates below are earliest dates, not unconditional application dates: the Regulation also links application to the entry into force of the relevant secondary legislation. [2](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023R1542)

| Battery category | Declaration: earliest date | Performance class: earliest date | Maximum threshold: earliest date |
|---|---|---|---|
| EV | 18 February 2025 | 18 August 2026 | 18 February 2028 |
| Rechargeable industrial, over 2 kWh, excluding exclusively external storage | 18 February 2026 | 18 August 2027 | 18 February 2029 |
| LMT | 18 August 2028 | 18 February 2030 | 18 August 2031 |
| Rechargeable industrial, over 2 kWh, with exclusively external storage | 18 August 2030 | 18 February 2032 | 18 August 2033 |

Declaration requirements apply on the relevant date **or 12 or 18 months after the relevant acts enter into force**, depending on category, whichever is later. Performance classes generally use an 18-month secondary-legislation condition; maximum thresholds use 18 months for EV batteries and generally 24 months for the other listed categories.

Consequently, a compliance calendar must track the adopted methodology and implementing format, not merely copy the earliest dates into a spreadsheet. Requirements dependent on secondary legislation not finally adopted remain **expected**, not operationally settled.

## Recycled-content phase-in under Article 8

For relevant industrial batteries above 2 kWh, EV batteries and SLI batteries containing cobalt, lead, lithium or nickel, recycled-content documentation starts from **18 August 2028**, or 24 months after the relevant delegated act enters into force, whichever is later. The initial documentation requirement excludes industrial batteries with exclusively external storage. LMT documentation starts from **18 August 2033**. [2](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023R1542)

Minimum shares for covered batteries are:

| Application date | Cobalt | Lead | Lithium | Nickel |
|---|---:|---:|---:|---:|
| 18 August 2031: covered industrial, EV and SLI batteries | 16% | 85% | 6% | 6% |
| 18 August 2036: covered industrial, EV, SLI and LMT batteries | 26% | 85% | 12% | 15% |

The percentages concern the relevant recovered materials in active materials, not a single percentage of total battery weight. Supplier evidence must preserve the material-specific denominator and calculation basis.

Battery due-diligence obligations were separately postponed to **18 August 2027**. That postponement should not be mistaken for a postponement of the February 2027 passport obligation. [4](https://eur-lex.europa.eu/eli/reg/2023/1542/2025-07-31/eng)

## DIN DKE SPEC 99100 and the Battery Pass themes

**DIN DKE SPEC 99100:2025-02** provides a detailed attribute framework. It is useful implementation guidance, not an alternative legal source or automatic proof of EU compliance. Battery Pass notes that its earlier guidance and longlist were updated to align with the specification. [3](https://thebatterypass.eu/assets/images/content-guidance/pdf/DIN_DKE_SPEC_99100.PDF)

Battery Pass organises attributes into seven themes: general battery and manufacturer information; compliance, labels and certifications; carbon footprint; supply-chain due diligence; materials and composition; circularity and resource efficiency; and performance and durability. These themes provide a practical ownership structure across legal, engineering, procurement and service teams. [1](https://thebatterypass.eu/wp-content/uploads/q-a_content-guidance_4.pdf)

## What real implementations demonstrate

Volvo’s EX90 passport, developed with Circulor, illustrates an early production implementation combining material traceability and carbon information with QR-based access. Volvo describes access through a code inside the vehicle’s B-pillar. It is evidence that passport infrastructure can operate before mandatory application—not proof that every future regulatory requirement was already satisfied. [2](https://www.volvocars.com/fr-ch/news/technology/la-volvo-ex90-inaugure-le-passeport-batterie/)

Battery Pass’s demonstrator and attribute work offer a different implementation lesson: interoperability requires common definitions, access rules and update processes, not merely an attractive consumer page.

## Implementation checklist

- Confirm battery category, capacity and responsible economic operator.
- Map every Annex XIII field, including incorporated annexes and articles.
- Mark conditional fields with their legal trigger.
- Separate model, manufacturing-batch and individual-battery records.
- Preserve baseline values and timestamp dynamic updates.
- Implement access controls before loading confidential information.
- Connect supplier evidence to carbon and recycled-content calculations.
- Test QR durability, identifier persistence and exportability.
- Plan responsibility transfers for reuse, repurposing and remanufacturing.
- Validate against the latest Commission guidance and adopted secondary acts.

## Sources

- https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023R1542
- https://eur-lex.europa.eu/eli/reg/2023/1542/2025-07-31/eng
- https://single-market-economy.ec.europa.eu/document/download/cd1e5e6c-4a4a-4b99-995a-49eb6916187e_en
- https://thebatterypass.eu/assets/images/content-guidance/pdf/DIN_DKE_SPEC_99100.PDF
- https://thebatterypass.eu/wp-content/uploads/q-a_content-guidance_4.pdf
- https://www.volvocars.com/fr-ch/news/technology/la-volvo-ex90-inaugure-le-passeport-batterie/