Battery passport 2027: what is public and who reads the rest
From 18 February 2027, every electric-vehicle battery, every light-means-of-transport battery and every industrial battery above 2 kWh placed on the EU market needs a battery passport (Regulation (EU) 2023/1542, Article 77). Most of the anxiety we hear is about the wrong thing. The passport is not one big public data dump: the regulation sorts its content into four groups, each with its own audience, and the Commission’s own guidance says several fields need not be filled on day one. Here is the map.
Who needs one, and how it is reached
The duty falls on the economic operator placing the battery on the market or putting it into service. It must keep the passport accurate, complete and up to date, and may authorise another operator to do so on its behalf (Article 77(4)). Every battery carries a QR code from the same date (Article 13(6)); for passport batteries that code links to a unique identifier and, through it, to the passport (Article 77(3)). Access is free of charge, within each reader’s rights (Article 78). A battery that is prepared for re-use, repurposed or remanufactured gets a new passport linked to the passport of the original battery, or batteries (Article 77(7)), and a passport ceases to exist once the battery is recycled (Article 77(8)).
The four groups in Annex XIII
| Annex XIII group | Who may read it | What it holds |
|---|---|---|
| 1. Battery model, public | Everyone, through the QR code | Identity and manufacturer details (Annex VI Part A), material composition including chemistry, hazardous substances and critical raw materials, carbon footprint, responsible-sourcing information, recycled content, renewable content, rated capacity, voltage and power figures with temperature ranges, expected lifetime in cycles and the test used, capacity threshold for exhaustion (EV batteries), storage temperature range, calendar-life warranty period, round-trip efficiency, internal resistance, cycle-life test C-rate, markings, the EU declaration of conformity, and the information on preventing and managing waste batteries |
| 2. Battery model, restricted | Persons with a legitimate interest, plus the Commission, notified bodies and market-surveillance authorities (Article 77(2)) | Detailed composition of cathode, anode and electrolyte; part numbers and sources of spares; dismantling information (exploded diagrams, disassembly sequences, fastening techniques, tools, warnings, cell count and layout); safety measures |
| 3. Battery model, authorities | Notified bodies, market-surveillance authorities, the Commission | Test reports proving compliance |
| 4. Individual battery, restricted | Persons with a legitimate interest | Performance and durability values at placing on the market and at each status change, state of health, status (original, repurposed, re-used, remanufactured, waste), and use data such as cycle counts, negative events, temperature history and state of charge |
Two things follow from the table. First, the public part is about the model: nothing about an individual battery’s life is public. Second, “legitimate interest” is not a commercial relationship with the manufacturer. Article 77(2) names the purposes that qualify: dismantling, safety and detailed composition, where the reader is a repairer, remanufacturer, second-life operator or recycler; and, for an individual battery, the purchaser’s use of that battery on the energy market. Access follows the actor and the purpose, not who sold whom the battery.
What is still undecided
Who exactly counts as a person with a legitimate interest, and how far they may download, share, publish or re-use groups 2 and 4, is for a Commission implementing act (Article 77(9)). It was due by 18 August 2026 and has not been adopted. The passport deadline is unaffected. In practice this means a passport must ship with the restricted groups protected before the legal definition of who may pass through the gate exists - a good reason to design the access model now rather than in January 2027.
What can wait, according to the Commission’s guidance
The Commission’s “Digital Batteries Passport - data points by category” guidance, version 2.0 of 15 August 2026, marks several Annex XIII fields as not to be filled or displayed as of February 2027:
- Carbon footprint declaration and performance class label - the format waits for an implementing act.
- Responsible-sourcing report - the due-diligence duties that produce it apply only from 18 August 2027 (Article 48(1), as postponed by Regulation (EU) 2025/1561).
- Recycled cobalt, lithium, nickel and lead shares - to be applied in line with Article 8 and its delegated act, not yet adopted.
- Printable and downloadable instructions for use - not in the regulation today; the guidance lists it as a future Annex XIII point 1(t) and puts it on hold pending adoption of the Omnibus package.
- Two further points the guidance treats as duplicates of data already provided elsewhere in the passport.
One caution, in the guidance’s own words: it “should not be considered as representative of the European Commission’s official position” and “does not extend in any way the rights and obligations deriving from applicable legislation”. Annex XIII still lists every one of those fields. Our reading: build the fields, hold the data where you have it, and treat their absence as acceptable on day one, not as a reason to drop them.
The registry
The operator placing the battery on the market must also upload its unique identifier to the Commission’s Digital Product Passport Registry (Article 77(10), added by Regulation (EU) 2024/1781, whose Article 13 sets up the registry). The registry has been live since 20 July 2026, batteries are its first product group, and registration is per individual battery. Operators enrol with EU Login and a qualified electronic seal or signature, then register through the web form or by uploading registration files. Implementing Regulation (EU) 2026/1778 also provides for registration by a verified third party on an operator’s behalf, a procedure the registry has not opened yet.
Where a platform helps
The Soverio DPP Platform maps Annex XIII to 35 readiness checks in 9 categories, and follows the Commission’s guidance by marking the deferred fields as such: they are still validated when present, but their absence is not reported as a gap. Public fields and authority-only fields are enforced at field level as the regulation splits them; the boundary of groups 2 and 4 is designed to take the implementing act’s definition when it arrives. Each passport gets its QR code and unique identifier, and the registry files are generated for you from the Starter plan up. On the Enterprise plan, as part of consulting services, Soverio prepares and submits your registrations through your verified account and will register on your behalf as soon as the registry opens third-party registration. Every check reports what your data evidences; none of them issues a compliance verdict.
Frequently asked questions
Which batteries need a passport from 18 February 2027?
Electric-vehicle batteries, light-means-of-transport batteries, and industrial batteries with a capacity above 2 kWh, when placed on the market or put into service from that date (Article 77(1)).
Is the whole battery passport public?
No. Only the battery-model information in Annex XIII point 1 is public. Detailed composition and dismantling information are restricted to persons with a legitimate interest and to authorities, individual-battery data to persons with a legitimate interest, and test reports to authorities only.
Who is a “person with a legitimate interest”?
The regulation names the purposes - dismantling, composition and safety for repairers, remanufacturers, second-life operators and recyclers, and energy-market use for the purchaser - and leaves the exact list of persons to a Commission implementing act that is not yet adopted.
Do I need the carbon footprint and recycled-content figures on day one?
According to the Commission’s guidance of 15 August 2026, not yet: the carbon-footprint format and the recycled-content rules wait for further acts. Annex XIII still lists them, so hold the data where you have it.
What happens to the passport when a battery is repurposed or recycled?
A battery prepared for re-use, repurposed or remanufactured receives a new passport linked to the passport of the original battery, or batteries; the passport ceases to exist once the battery is recycled.
Sources: Regulation (EU) 2023/1542 (Arts. 13, 48, 77, 78, Annex XIII), as amended by Regulation (EU) 2024/1781 (Arts. 13 and 78) and Regulation (EU) 2025/1561; Implementing Regulation (EU) 2026/1778 on the registry; the Commission’s “Digital Batteries Passport - data points by category”, v2.0, 15 August 2026. This article reflects the state of the implementing acts as of September 2026.
Preparing a battery passport? Talk to us - or read how Soverio DPP consulting runs a readiness assessment against Annex XIII. Batteries are the first product group to get a passport; ESPR and Digital Product Passports covers the ones that follow.