Batteries RegulationTemplateEU

EU Batteries Regulation Battery Passport Data Model Template

A field-level template for mapping Article 77 passport coverage, QR-code access, Annex XIII data groups, access tiers, identifiers, owners, and evidence.

Use it to separate battery-model records from individual-battery records before connecting product master data, conformity files, carbon-footprint declarations, service data, and restricted access controls.

Author
Sorena AI
Published
May 9, 2026
Updated
May 17, 2026
Sections
5

Structured answer sets in this page tree.

Primary sources
4

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated May 17, 2026
Overview

Article 77 of Regulation (EU) 2023/1542 makes the battery passport an electronic record for each LMT battery, each industrial battery with a capacity greater than 2 kWh, and each electric vehicle battery placed on the market or put into service from 18 February 2027. This template turns that rule into a data model: a scope table, a battery-model table, an individual-battery table, an access-rights matrix, and an evidence register tied to the source system that proves each published or restricted value.

Section 1

Article 77 scope and identifier table

Start the schema with a scope table before adding Annex XIII fields. Article 77 covers LMT batteries, industrial batteries above 2 kWh, and electric vehicle batteries. Other battery categories may still need labels, QR-code information, conformity records, due-diligence information, or waste instructions under other provisions, but Article 77 does not make every battery a passport record.

Each covered battery needs a passport reachable through the Article 13(6) QR code. The QR code must link to the unique identifier attributed by the economic operator placing the battery on the market, so the identifier table should be the stable join between product master data, QR artwork, passport endpoints, service systems, and second-life or recycling records.

  • Scope table columns: battery category, capacity in kWh, placed-on-market or put-into-service status, EU market route, Article 77 passport required, scope rationale, and reviewer.
  • Model identifier columns: battery model identifier, manufacturer or responsible economic operator, manufacturing plant location where used by the underlying evidence, EU declaration of conformity reference, and passport schema version.
  • Individual identifier columns: unique identifier, QR-code target URL, serial or production identifier, linked battery-model identifier, current status, passport created date in the source system, and lifecycle event reference.
  • Responsibility columns: economic operator responsible for accuracy, completeness, and update status; authorised operator if another party stores or updates data; written authorisation evidence reference.
  • Lifecycle linkage columns: original passport identifier, new passport identifier after preparation for re-use, preparation for repurposing, repurposing, re-use, or remanufacturing, waste-battery responsibility holder, and recycled-status closure.
Recommended next step

Turn the passport template into a governed data model

Map Article 77 scope, Annex XIII fields, access tiers, identifiers, source systems, and evidence artifacts before publishing QR-code access for covered batteries.

Section 2

Battery-model table for public Annex XIII fields

Annex XIII point 1 is the public model-data block. Build it as a governed battery-model table because those fields describe the battery model, not live telemetry from one physical battery. The table should include the value shown in the passport, the unit or controlled vocabulary, and the evidence artifact that proves it.

A useful public table has one row per field category and one source-of-truth owner. Do not publish a flat list of unverified values: attach the legal basis, the source system, the evidence reference, the validation rule, and the event that forces recalculation or republication.

  • Public table columns: Annex XIII item, field name, passport display value, unit, data type, source system, evidence artifact, accountable owner, validation check, last validated, and update trigger.
  • Identity and label rows: Annex VI Part A label information, Article 13(3) and 13(4) marking information, and the Article 18 EU declaration of conformity reference.
  • Composition rows: battery chemistry, material composition, hazardous substances other than mercury, cadmium, or lead, critical raw materials, and share of renewable content.
  • Sustainability rows: Article 7 carbon-footprint information, responsible-sourcing information from the battery due diligence policy report, and recycled-content information from the Article 8 documentation.
  • Performance rows: rated capacity, voltage ranges, original power capability, expected lifetime in cycles, reference tests, EV capacity threshold for exhaustion, non-use temperature range, warranty period, round-trip energy efficiency, internal resistance, and cycle-life c-rate.
  • Waste-information row: prevention and management information for waste batteries under Article 74(1)(a) to (f), linked to the public battery-model passport record.
Section 3

Access-rights matrix for restricted fields

Do not put every passport field behind the same public endpoint. Annex XIII point 1 is public. Annex XIII point 2 model data is for persons with a legitimate interest and the Commission. Annex XIII point 3 test-report results are for notified bodies, market surveillance authorities, and the Commission. Annex XIII point 4 individual-battery data is for persons with a legitimate interest.

Model the access rule as metadata on each field group. Article 77(9) leaves further detail to an implementing act on which legitimate-interest persons get access and to what extent they may download, share, publish, or re-use the information, so keep the matrix versioned and do not hard-code broader reuse rights than the source supports.

  • Matrix columns: field group, Annex XIII point, actor category, purpose, permitted operation, commercial-sensitivity flag, authentication method, access decision log, expiry or reassessment trigger, and policy version.
  • Legitimate-interest model rows: detailed composition, cathode/anode/electrolyte materials, replacement-spare source contacts, dismantling diagrams, disassembly sequence, fasteners, tools, damage warnings, cell count and layout, and safety measures.
  • Authority-only rows: test-report results proving compliance with the Regulation or delegated or implementing acts adopted under it.
  • Legitimate-interest individual rows: performance and durability values at market placement and status changes, state of health, status as original, repurposed, re-used, remanufactured, or waste, charging and discharging cycles, accidents, environmental conditions, and state of charge.
  • Governance rows: field owner, access approver, evidence artifact, last access-rights review, and dependency on the Article 77(9) implementing act for legitimate-interest persons and reuse rights.
Section 4

Interoperability and QR-code publishing requirements

The passport data model should be API-ready from the start. Article 77 requires open standards, an interoperable format, transfer through an open interoperable data exchange network without vendor lock-in, and data that is machine-readable, structured, and searchable.

Article 78 adds operational requirements: free access based on access rights, storage by the responsible operator or authorised processor, availability if the responsible operator ceases activity in the Union, restricted write and update rights, authentication, reliability, integrity, security, privacy, and fraud prevention.

  • Publishing fields: QR-code payload URL, unique identifier, identifier issuer, ISO/IEC 15459 mapping, public endpoint, restricted endpoint, API schema version, and human-readable page version.
  • Interoperability fields: semantic field name, unit, data type, controlled vocabulary, source-system identifier, validation rule, update frequency, and export format.
  • Availability fields: data host, authorised processor, continuity arrangement if the operator exits the Union, backup location, and passport-retention state until recycling.
  • Integrity fields: source hash or version reference, signer or approving system, timestamp, change reason, audit log ID, and rollback procedure.
  • Readability fields: QR-code contrast check, readable size, mobile-reader test result, visibility and legibility check, and failure route for unreadable or damaged labels.
Section 5

Evidence register to implement before launch

Use the evidence register as the implementation spine for the passport build. Each row should be testable by product compliance, engineering, sustainability, supply chain, service, and IT before any QR code is released.

The register is intentionally field-level: it should show what value appears in the passport, where it came from, who can access it, who can update it, and what event forces a review or republication.

  • Register columns: field group, field name, Article or Annex XIII basis, access tier, record granularity, passport display value, source system, evidence artifact, accountable owner, updater role, validation rule, and update trigger.
  • Carbon-footprint row example: public model field; Article 7 and Annex XIII point 1; lifecycle carbon footprint and stage values; evidence from the carbon-footprint declaration, plant data, supporting study link, and EU declaration of conformity identifier.
  • Dismantling row example: restricted model field; Annex XIII point 2; diagrams, sequence, fasteners, tools, cell layout, warnings, and safety measures; access limited to legitimate-interest actors and the Commission.
  • State-of-health row example: restricted individual-battery field; Annex XIII point 4; state of health, status changes, use-derived data, environmental conditions, and state of charge; access limited to legitimate-interest actors.
  • Compliance-test row example: authority-only model field; Annex XIII point 3; test-report results proving compliance; access limited to notified bodies, market surveillance authorities, and the Commission.
Primary sources

References and citations

eur-lex.europa.eu
Referenced sections
  • The draft declaration format provides concrete evidence columns for one public passport field group: carbon-footprint values by lifecycle stage, model, plant, conformity declaration number, and supporting-study link.
"Identification number of the EU declaration of conformity"
joint-research-centre.ec.europa.eu
Referenced sections
  • JRC explains methodology support for standardised carbon-footprint calculations for rechargeable industrial batteries above 2 kWh, which is relevant evidence context for passport carbon-footprint rows.
"standardised approach to quantify greenhouse gas emissions"
eur-lex.europa.eu
Referenced sections
  • Annex XIII supplies the field groups and access categories that the evidence register should map into model records, individual-battery records, and restricted data stores.
"specific information and data relating to an individual battery"
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