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
Oct 15, 2026
Overview

Article 77 of Regulation (EU) 2023/1542 makes the an electronic record for each light means of transport (LMT) battery, each industrial battery with a capacity greater than 2 kilowatt-hours (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, or remanufacturing, waste-battery responsibility holder, and recycled-status closure. Keep 're-used' as an Annex XIII status value rather than treating it as an additional Article 77(7) transfer operation.
  • Registry submission columns: battery unique identifier, responsible operator, upload owner, target registry, submission status, acknowledgement or error, submission date, and the passport record linked to that identifier.
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.
  • 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. Under Article 77(2), point 2 model data is accessible to notified bodies, market surveillance authorities, the Commission, and persons with a legitimate interest. 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. Keep the matrix versioned, record the act and effective version used, and do not hard-code broader rights than the applicable 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.
  • Restricted point 2 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.
  • Point 3 compliance-test 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 to assign and check each passport field before launch. Product compliance, engineering, sustainability, supply chain, service, and IT should be able to verify the value, source, access rule, and update owner 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 for notified bodies, market surveillance authorities, the Commission, and legitimate-interest actors within their applicable rights.
  • 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: Annex XIII point 3 model field; test-report results proving compliance; access limited to notified bodies, market surveillance authorities, and the Commission.
Primary sources

References and citations

eur-lex.europa.eu6 citations
Referenced sections
  • Primary legal source for Article 77 passport scope, QR-code and unique-identifier access, operator responsibility, Article 78 interoperability requirements, and Annex XIII passport data fields.
  • Article 77 defines which batteries need a passport, how the QR code links to a unique identifier, who is responsible for passport accuracy, and how responsibility transfers after preparation for re-use, preparation for repurposing, repurposing, remanufacturing, or waste status before the passport ceases after recycling.
  • Annex XIII point 1 lists public battery-model information, including label data, composition, sustainability, performance, marking, conformity, and waste-management information.
Show 3 more
  • Article 77, Article 78, and Annex XIII separate public data, restricted point 2 model data, point 3 test-report data for notified bodies, market surveillance authorities and the Commission, and individual-battery data, with restricted access and update rights.
  • Articles 13, 77, and 78, plus Annex VI Part C, support QR-code access through a unique identifier, readable QR design, open standards, interoperable machine-readable data, free access based on rights, continuity, restricted update rights, and security controls.
  • 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.
"battery passport"
More quoted passages
"battery model and information specific to the individual battery"
"accessible to the public"
"commercially sensitive is limited to the minimum necessary"
"machine-readable, structured and searchable"
"specific information and data relating to an individual battery"
eur-lex.europa.eu3 citations
Referenced sections
  • Source for practical carbon-footprint evidence fields such as manufacturer, battery model, plant location, lifecycle-stage values, conformity declaration number, and supporting-study link.
  • The draft declaration format shows practical evidence fields for Article 7 carbon-footprint data: manufacturer, battery model, manufacturing plant location, lifecycle-stage values, conformity declaration number, and a public supporting-study link.
  • 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.
"Life-cycle carbon footprint"
More quoted passages
"Battery model"
"Identification number of the EU declaration of conformity"
environment.ec.europa.eu3 citations
Referenced sections
  • Commission overview connecting labels, QR codes, digital passports, informed consumer decisions, and value-chain circular-economy use cases.
  • Commission overview explains the public purpose of labels and QR-code access to digital passport information for consumers and battery value-chain professionals.
  • Commission public communication confirms the practical role of labels, QR codes, and digital passports for consumers and battery value-chain professionals.
"digital passport"
More quoted passages
"A QR code will provide access"
"key data will be provided on a label"
joint-research-centre.ec.europa.eu2 citations
Referenced sections
  • JRC implementation context for standardised carbon-footprint methodology for rechargeable industrial batteries above 2 kWh under the Batteries Regulation.
  • 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.
"rechargeable industrial batteries"
More quoted passages
"standardised approach to quantify greenhouse gas emissions"
data.europa.eu
Referenced sections
  • ESPR Article 13 includes battery unique identifiers in the DPP registry; Article 78 adds the battery-identifier upload provision to Batteries Regulation Article 77.
"ecodesign requirements for sustainable products"
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