What Data Goes Into the EU Digital Battery Passport?
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The Battery Passport is the most advanced Digital Product Passport rollout in the EU right now — it's the first sector where the Commission has published a detailed, data-point-by-data-point breakdown of exactly what has to go into the passport. If you're working on batteries, this is worth understanding in detail before you touch textiles, construction products, or any of the other categories still waiting on their delegated acts.
This post is based on the European Commission's Guidance Document: Digital Batteries Passport – data points by category (Version 2.0, 15 August 2026), read alongside Regulation (EU) 2023/1542 (the Batteries Regulation). If you need a refresher on the DPP framework generally, start with our overview of what the DPP is and our post on EU DPP requirements and timeline.
Which batteries does this cover?
The guidance applies to three categories defined under Article 3 of the Batteries Regulation:
- EV batteries — batteries used to power electric vehicles
- LMT batteries — batteries for light means of transport (e-bikes, e-scooters, and similar)
- Industrial batteries — with a capacity greater than 2 kWh
Each data point in the Commission's guidance is marked separately for each of these three categories, because applicability genuinely differs by category — a field that's mandatory for EV batteries might be optional, conditional, or not required at all for industrial batteries, and vice versa.
How the guidance grades each data point
Rather than a flat "required" list, each data point carries one of several statuses:
- Mandatory — must be provided.
- Optional — to be filled if the information is available (e.g. manufacturer website or email).
- If applicable / applicable only in certain cases — depends on the specific battery's technical characteristics or design.
- Not to be filled/displayed as of February 2027 — the requirement exists in the Regulation, but isn't yet operative, usually because a format, delegated act, or implementing act is still pending.
That last category matters a lot in practice — it means the legal obligation exists on paper, but the Commission hasn't yet specified how to report it, so there's nothing to submit yet.
The broad categories of information required
Without listing every individual field, the data points fall into a handful of natural groupings:
Identification and manufacturer details. Unique identifier, who's responsible for registering the passport, manufacturer name and address, battery category, model/batch/serial identification, place and date of manufacture — all mandatory across all three battery types.
Physical and technical specifications. Weight, capacity, chemistry, voltage (minimum, nominal, maximum), power capability and limits, internal resistance, C-rate, and similar performance parameters — mandatory for EV and LMT batteries, with some fields shifting to "if applicable" or "only for some industrial batteries" for the industrial category.
Material composition and substances of concern. Hazardous substances (other than mercury, cadmium, or lead, which are handled separately), critical raw materials present above 0.1% weight, detailed composition of the cathode, anode, and electrolyte, and the appropriate hazard marking under Article 13.
Compliance and legal documentation. The EU declaration of conformity, results of test reports proving compliance with the Regulation, and information on waste battery prevention and management.
Repair, dismantling, and safety information. Part numbers for components, contact details for replacement spares, exploded diagrams and disassembly sequences, tools required, and applicable safety measures — all mandatory, reflecting the Regulation's circular-economy goals.
Dynamic, lifecycle data. Charging/discharging cycle counts, battery status (original, repurposed, re-used, remanufactured, or waste), and — notably — state-of-health information, which is handled differently depending on category: EV batteries report "state of certified energy," while LMT batteries report remaining capacity, remaining power capability, and related metrics instead.
What's required, but not yet operative
Several sustainability-related data points are explicitly flagged as not to be filled or displayed yet, despite being written into the Regulation:
- Carbon footprint declaration and label — the format is still to be specified in an upcoming implementing act.
- Responsible sourcing information (from the battery due diligence policy report) — not required until August 2027.
- Recycled content percentages for cobalt, lithium, nickel, and lead — pending application of the relevant delegated act.
- Detailed instructions for use in a downloadable, printable format — on hold pending adoption of the "Omnibus" simplification package.
If you're building your data collection processes now, it's worth building placeholders for these fields so you're not scrambling once the underlying acts land.
A caution on the source itself
The Commission is explicit that this guidance document is not itself legally binding: it "does not extend in any way the rights and obligations deriving from applicable legislation nor introduce any additional requirement." Treat it as the clearest available practical interpretation of the Batteries Regulation and its annexes — but the Regulation and its delegated and implementing acts remain the actual legal source.
Sources
- Guidance Document: Digital Batteries Passport – data points by category (v2.0, 15 August 2026) — European Commission, DG GROW
- Regulation (EU) 2023/1542 (Batteries Regulation) — EUR-Lex
- Digital Product Passport: Frequently Asked Questions (FAQ) — European Commission, DG GROW
This article reflects publicly available EU guidance current as of September 2026 and is not legal advice. The underlying guidance document itself is subject to further revision, and several data points depend on delegated or implementing acts that had not yet been adopted at time of writing.
