Battery Passport Mandatory Fields — Annex XIII Reference

Last reviewed: August 2026 · PassoNext Team

Direct answer

Annex XIII of EU Battery Regulation 2023/1542 sets out what the battery passport must contain. It is organised as four numbered points, and each point is an access tier rather than a subject area: point 1 is publicly accessible, point 2 is for persons with a legitimate interest and the Commission, point 3 is for notified bodies and market surveillance authorities, and point 4 is individual-battery data. Not every entry applies at once. The European Commission guidance enumerates 71 data points, of which 51 are mandatory for EV at 18 February 2027, 54 for LMT and 36 for industrial above 2 kWh; the rest are conditional, optional, or deferred past that date.

Key Takeaways

Annex XIII of Regulation 2023/1542 defines the contents of the battery passport.
The Commission guidance enumerates 71 data points. Of those, 51 are mandatory for EV at 18 February 2027, 54 for LMT and 36 for industrial above 2 kWh.
Annex XIII is organised as four numbered points, and each point is an access tier rather than a subject grouping.
PassoNext templates are mapped data-point-by-data-point to every Annex XIII requirement.
Some data points require upstream supplier data, so start collection early.

What Annex XIII Requires From Every Battery Passport

The baseline legal requirements for what a digital battery passport must include come directly from Annex XIII of the EU Battery Regulation (Regulation (EU) 2023/1542). This isn’t optional advice; it’s the law. However, regulators don’t ask for every single piece of information on day one. Official guidance from the European Commission outlines 71 specific data points. Of these, 51 are mandatory for electric vehicle batteries by 18 February 2027, 54 for light means of transport, and 36 for industrial batteries over 2 kWh. The remaining fields are either conditional, optional, or scheduled for later deadlines. If a field applies to your product category, you must make sure it is accurate, fully completed, and accessible online before placing the battery on the EU market.

This reference guide breaks down each mandatory data category, explains what you need to provide, and outlines the practical steps manufacturers must take to comply.

Which Batteries Are in Scope

Starting 18 February 2027, the battery passport rules will apply to three specific categories of batteries sold in the EU:

Industrial batteries with a capacity above 2 kWh
Electric vehicle (EV) batteries
Light means of transport (LMT) batteries

Standard portable batteries and SLI (starting, lighting, ignition) units don’t need a passport, though they still have to follow other parts of the Battery Regulation. If you make or import batteries in any of the three categories listed above, meeting the Annex XIII requirements is mandatory.

The February 2027 deadline applies to batteries introduced to the market on or after that date. Items already in the supply chain before the deadline are exempt, but any new unit coming onto the market after February 2027 must have a compliant passport attached to it.

How Annex XIII Is Organised

Annex XIII is divided into four numbered sections. Each section represents a specific access level rather than a topic. This is where many people get confused: the structure determines who gets to view the data, not what type of information it is. There are no “Parts A to F” in Annex XIII.

Point 1: sub-points (a) to (t): publicly accessible information relating to the battery model. Point 1(a) incorporates the information specified in Part A of Annex VI, which is why manufacturer identity, battery category, chemistry, weight and capacity sit here.
Point 2: sub-points (a) to (c): model information accessible only to persons with a legitimate interest and the Commission. Detailed cathode, anode and electrolyte composition, part numbers, and dismantling information.
Point 3: results of test reports, accessible only to notified bodies, market surveillance authorities and the Commission.
Point 4: sub-points (a) to (d): data relating to an individual battery, accessible only to persons with a legitimate interest. Performance values, state of health, battery status, and usage data.

You won’t have to fill out every field right away in February 2027. Commission guidance lists several fields—including the carbon footprint declaration and its label—that stay hidden until secondary legislation defines their final layout. Using the launch-status filter in our directory helps you see what is due immediately and what you can collect now for later publication.

General Battery and Manufacturer Information

These fields verify the identity of the battery itself and the economic operator responsible for putting it on the market. They form the foundational record that connects every other data point to a specific product.

Manufacturer Identity

The passport must clearly list the manufacturer’s official name, registered trade name, street address, email address, and website. If an importer or authorized representative places the battery on the EU market instead of the original manufacturer, you need to include their contact details too.

Manufacturing Facility

You must declare the location of the plant where the battery was assembled, including the country and specific site. If your company operates multiple factories, the passport must point to the exact facility where that specific battery was produced.

Battery Model and Technical Identifiers

The record needs to specify the model identifier, battery type, and official date of market entry. You must list the total weight in kilograms and the rated capacity in ampere-hours (Ah). You also need to state the chemistry type, detailing the active materials used inside the cathode and anode.

Unique Identifier and QR Code

Every battery requires a globally unique, machine-readable code that connects the physical item to its digital record. You must print a QR code on the battery casing so anyone with a standard smartphone can scan it to access the passport. The QR code has to meet ISO/IEC 18004 standards and remain readable for the entire working life of the battery.

Carbon Footprint

The carbon footprint rules are easily among the most demanding parts of Annex XIII. They require detailed lifecycle carbon tracking at a level that most companies haven’t had to perform before.

Carbon Footprint Value

You must disclose the battery’s total carbon footprint, measured in kilograms of CO2 equivalent per kilowatt-hour of total energy provided over its expected service life (kgCO2e/kWh). You need to calculate this number using the methodology laid out in the delegated act under Article 7(1) of the Battery Regulation. The calculation covers every phase: extracting raw materials, manufacturing, shipping, and end-of-life processing.

Carbon Footprint Performance Class

After calculating the footprint, you must assign the battery to a specific carbon footprint performance class set by the Commission. These classes rank products from lowest to highest carbon impact. This rating system helps buyers compare items easily and sets up future maximum carbon limits designed to keep high-emission products off the EU market.

Manufacturing Carbon Footprint Share

The passport must highlight the percentage of total carbon emissions that comes strictly from the manufacturing stage. Separating factory-gate emissions from the rest of the supply chain offers clear insight into production efficiency and supports the EU’s push for cleaner manufacturing across Europe.

Link to Carbon Footprint Study

You must include a working link to the full carbon footprint study or supporting verification files. This allows regulatory agencies to audit your numbers and helps downstream business partners complete their own due diligence checks.

Supply Chain Due Diligence

This section focuses on ethical material sourcing. The Battery Regulation turns supply chain due diligence into a mandatory requirement, and your passport must contain proof that your company complies.

You need to include details about your company’s supply chain due diligence policies, along with a link to your latest official due diligence report. These requirements apply specifically to four critical raw materials: cobalt, lithium, nickel, and natural graphite.
Your documentation must show that your processes align with recognized global standards, such as the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. Authorities will review these submissions closely to ensure your due diligence goes beyond basic paperwork and actively addresses supply chain risks.

Material Composition and Hazardous Substances

These fields require full transparency regarding what goes into the battery. The goal is to protect human health, reduce environmental risks, and build a stronger circular economy.

Hazardous Substances

The passport must report any Substances of Very High Concern (SVHCs) listed under REACH (Regulation (EC) 1907/2006) or hazardous materials covered by the CLP Regulation (Regulation (EC) 1272/2008). The entry must state the exact name, concentration, and location inside the battery for any regulated substance above the legal reporting threshold.

Material Composition

You will need to specify the exact chemical composition of the battery, including the formulas of the cathode, anode, and electrolyte. Moreover, you will have to provide information on the weight percentage of some raw materials, namely cobalt, lithium, nickel, manganese, and lead. The information is necessary for the EU system of resources and future recycled content criteria.

Recycled Content

The passport should include information about the proportion of recycled cobalt, lithium, nickel, and lead in the battery compared to their total weight. Starting from 18 August 2031, there will be certain mandatory minimums for recycled content of these substances: 16% of cobalt, 6% of lithium, 6% of nickel, and 85% of lead. There will be additional increases in these numbers on 18 August 2036.

Performance and Durability

These parameters provide buyers, vehicle owners, and refurbishers with the performance records they need to evaluate a battery’s condition and expected lifespan.

Initial Performance Parameter

When commercializing the battery, the following specifications have to be included in the passport: capacity rating (Ah), voltage rating (V), cycle life and calendar life expectancy, round-trip efficiency at 50% cycle life, internal resistance (ohms), and charging and discharging rate of C. These specifications have to be determined according to the standardized tests procedures set in delegated acts.

State of Health Over Time

For EV batteries and industrial storage systems with built-in management software, the passport must support live operational updates. The battery’s State of Health (SOH)—expressed as a percentage of remaining capacity compared to its original rating—must be updated periodically over time. This requirement turns a static data sheet into a dynamic, ongoing product log.

Tracking live SOH data makes it far easier to repurpose batteries for a second life. For example, an EV battery retired with an 80% SOH score can easily move into stationary energy storage. Without clear, verified SOH records, second-life buyers can’t accurately judge a battery’s value or safety. The digital passport solves that problem.

End-of-Life Information

This section ensures that essential directions for safe handling, waste collection, and material recycling remain connected to the product throughout its entire life.

Dismantling Instructions

The record must include or link to step-by-step dismantling guides tailored to the specific battery model. These guides must show technicians how to safely remove the battery pack from a vehicle or device. They should detail the exact steps, required tools, safety measures, and any components that require special handling.

Safety Information

It is essential to describe safety measures related to the management of the end-of-life product including fire protection measures, possible chemical hazards, and basic first aid instructions. Such information is extremely important for the employees of waste management companies, waste transportation, and recycling.

Collection and Recycling Information

All information regarding collection and recycling processes should be described in the passport, as well as available collection schemes and take-back systems, which can be applied to this particular product. In addition, if appropriate, the passport should indicate the name of the organization responsible for producer responsibility.

Data Access Tiers

Not all data in Annex XIII is open to everyone. The Battery Regulation uses a three-tiered permission system that controls who can view specific details based on their role.

Public Access

Anyone can scan the QR code to view basic public details. This includes manufacturer contact info, model details, battery chemistry, rated capacity, carbon footprint class, recycled content percentages, collection guidance, and the unique identifier. Public access helps consumers make informed buying choices and handle waste safely.

Persons of Legitimate Interest

A second, restricted tier is reserved for qualified professionals, such as independent repair shops, second-life operators, recyclers, and researchers. This level unlocks detailed performance logs, historical SOH records, disassembly guides, and complete chemical breakdowns. Access requires user verification and operates under strict data protection rules.

Authorities Only

Sensitive business records—like raw supply chain due diligence audits and complete carbon footprint studies—can be restricted exclusively to market surveillance agencies and customs officials. This tier protects company trade secrets while giving inspectors the data they need to verify compliance.

Data Format and Interoperability Requirements

All data supplied under Annex XIII must be formatted as structured, machine-readable records. The Battery Regulation specifically requires passport data to use standardized schemas that allow software systems to process and exchange data automatically via APIs.

The QR code must encode the unique identifier so scanning it immediately opens the correct online passport record. The QR code acts as the bridge connecting the physical battery to its digital record. It must meet ISO/IEC 18004 standards and remain scannable across the full working lifespan of the battery.

System interoperability is a core legal requirement. Inspection platforms across Europe—including national market surveillance databases and EU customs systems—must be able to query these records easily. Proprietary data layouts that block standard database tools will not pass regulatory compliance checks.

How PassoNext Maps to Annex XIII

PassoNext is built to mirror the complete Annex XIII data schema directly. Every regulatory requirement maps to an explicit input field within the software. While our internal organizational layouts group fields for user convenience, the underlying system respects the access tiers mandated by European law. The automated compliance engine assesses each draft passport against the full list of Annex XIII fields, flagging data gaps before publication so teams know precisely which data inputs require further collection.

The platform creates the unique identifier code, renders the required QR graphic format, and automatically enforces the three-level permission architecture. When market surveillance authorities initiate data requests, the system delivers complete records in machine-readable formats without delay.

Practical Guidance — Starting Your Annex XIII Data Collection

The February 2027 enforcement deadline is approaching rapidly. Gathering all the required Annex XIII datasets requires time, structured supply chain communication, internal system upgrades, and new lab testing routines.

Conduct a Gap Analysis

Begin by auditing existing engineering files against the full Annex XIII field structure. Most companies already track basic manufacturing identities and physical specifications. Operational performance metrics are often captured during factory quality checks. The primary gaps usually involve lifecycle carbon scores, supply chain due diligence records, and exact recycled content percentages. Calculating carbon footprints demands specialized Life Cycle Assessment (LCA) expertise, while due diligence auditing requires tracing mineral sources through multiple supplier tiers. Detailed chemical breakdowns down to exact weight percentages may also require issuing new data requests to component suppliers.

Engage Your Suppliers Early

Upstream vendors hold critical datasets that cannot be generated internally. This includes mineral origin tracking, recycled content disclosures, and granular chemical formulas. Initiate these supplier conversations immediately. Embed compliance data requirements into new vendor purchase orders and supply contracts. Suppliers who delay providing necessary data create immediate regulatory roadblocks for your finished goods.

Establish Your Carbon Footprint Methodology

Declaring carbon footprint figures requires conducting formal Life Cycle Assessments using the precise methodology specified in secondary acts passed under Article 7. Retain LCA experts or build internal computational tools right away. The initial calculation phase will take significant effort; subsequent updates will run faster once data collection routines are embedded into operations.

Do Not Wait for Final Implementing Acts

Although secondary technical standards are still being finalized by European authorities, the primary data categories mandated in Annex XIII are already fixed in law. The scope, categories, and attributes are defined. Delaying data collection until every minor technical detail is published creates a high risk of non-compliance. Start gathering records against the published Annex XIII architecture immediately, refining specific data entries as final technical guidelines clear publication.

Regulatory Status and Updates

This reference manual outlines the regulatory framework as of March 2026, resting on Regulation (EU) 2023/1542 as printed in the Official Journal of the European Union. Secondary delegated and implementing acts are continually rolling out to refine specific technical standards. Subscribe to Regulatory Radar on PassoNext.digital to monitor upcoming legislative updates and stay informed as enforcement milestones approach.

What This Means For Your Business

Clarifying which data fields your battery passports must contain is the critical starting point for market compliance. Every field links directly to explicit provisions inside Regulation 2023/1542, and market surveillance officers will audit records for completeness.

Many producers discover that 40% to 60% of the required information already exists inside existing test reports, quality documentation, and safety certifications. The challenge lies in extracting those disparate records, converting them into required digital formats, and filling remaining gaps—especially regarding supply chain material origins and verified recycled content ratios.

Action Steps

Download or review the full Annex XIII field list for your battery type.
Map your existing data assets against each required field.
Identify gaps — particularly in carbon footprint, recycled content, and supply chain due diligence.
Use PassoNext AI document extraction to pull data from existing test reports and certifications.
Contact suppliers for fields you cannot fill internally.

EU DPP Regulatory Hub

Battery Passport

Days

Feb 18, 2027

Frequently asked questions

Which batteries must comply with Annex XIII data field requirements?

Annex XIII applies to three categories placed on EU market from 18 February 2027: industrial batteries with capacity above 2 kWh, electric vehicle (EV) batteries and light means of transport (LMT) batteries. Portable batteries and SLI batteries (starting, lighting, ignition) are excluded from the passport requirement but subject to other provisions of the Battery Regulation.

How many mandatory data fields are in a battery passport?

The European Commission guidance of 28th July 2026 enumerates 71 data points. Mandatory and required as of February 2027: 51 for EV, 54 for LMT and 36 for industrial above 2 kWh. Several further data points are listed in Annex XIII but are not to be filled or displayed at that date, including the carbon footprint declaration and label. Market surveillance authorities will check completeness against the requirements in force at the time.

How is the Annex XIII data organised?

Annex XIII is organized as four numbered points, and each point is an access tier rather than a subject area. Point 1 is publicly accessible information about battery model, sub-points (a) to (t) and point 1(a) incorporates the information specified in Part A of Annex VI. Point 2 is model information accessible only to persons with a legitimate interest and the Commission. Point 3 is test reports accessible only to notified bodies and market surveillance authorities. Point 4 is individual-battery data for persons with a legitimate interest. Annex XIII has no Parts A to F.

Who can access which parts of the Annex XIII data?

The Battery Regulation establishes three tiers of data access. Public access includes fields such as manufacturer identity, battery model, chemistry type, rated capacity, carbon footprint performance class, recycled content shares and the unique identifier. Persons of legitimate interest, such as repairers, second-life operators, and recyclers, can access detailed performance data, state-of-health history, dismantling instructions, and detailed material composition. Certain commercially sensitive data may be restricted to market surveillance and customs authorities only.

What recycled content minimums apply under Annex XIII?

From 18 August 2031, minimum recycled content thresholds apply: 16% cobalt, 6% lithium, 6% nickel and 85% lead expressed as a percentage of the total weight of each material in the battery. These thresholds increase again from 18 August 2036. The passport must track and report recycled content from the outset to establish baselines.

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