EU Batteries Regulation Battery Passport Fields

Start the field model with the battery category. Article 77 covers LMT batteries, industrial batteries above 2 kWh, and electric vehicle batteries. Portable batteries, SLI batteries, and smaller industrial batteries may still have labelling, QR-code, conformity, removability, or waste information duties elsewhere in the Regulation, but they are not the passport categories named in Article 77(1).

The economic operator placing the covered battery on the market must ensure that the passport information is accurate, complete, and up to date. The operator may authorise another operator in writing to act on its behalf, but the passport design should still preserve responsibility, update rights, and evidence of who supplied each data element.

The passport needs tiered access. Annex XIII point 1 is public. Under Article 77(2), notified bodies, market surveillance authorities, and the Commission can access the model information in points 2 and 3. Persons with a legitimate interest can access the point 2 model information and point 4 individual-battery information only for the statutory purposes and within the access rules set by the Article 77(9) implementing act.

The passport must be accessible through the QR code referred to in Article 13(6). That QR code links to a unique identifier attributed by the economic operator placing the battery on the market. Article 78 adds technical controls: free access based on access rights, open and interoperable formats, restricted update rights, data integrity, security, privacy, and continued availability.

Article 77(9) requires the Commission to specify by 18 August 2026 who qualifies as a person with a legitimate interest, which point 2 and point 4 information each person may access, and the extent of download, sharing, publication, and re-use rights. A passport design should keep those permissions configurable instead of treating all repair, second-life, energy-market, or recycling users alike.

Annex XIII is the safest starting point for a passport field catalogue. It does not require every data point to be published to every actor. Build the catalogue by access group, then attach source systems, validation rules, and update triggers to each group.

For public model-level information, Annex XIII points back to Annex VI Part A and adds composition, carbon footprint, due diligence, recycled content, renewable content, capacity, voltage, power capability, lifetime, warranty, efficiency, resistance, c-rate, marking, EU declaration of conformity, and waste-prevention information. Treat those as field categories that may need subfields, not as a license to invent extra public fields.

A common implementation error is mixing model data and individual-battery telemetry in one flat table. Article 77 says the passport contains information relating to the battery model and information specific to the individual battery. Annex XIII then makes the split concrete: most public fields are model-level, while state of health, battery status, usage history, cycles, negative events, operating conditions, and state of charge are individual-battery fields with restricted access.

This distinction matters for architecture. Model-level fields can usually be versioned by product compliance, engineering, sustainability, supplier documentation, conformity assessment, and waste-information owners. Individual-battery fields need serial or unique-identifier linkage, controlled update rights, event capture, and access logic for allowed legitimate-interest purposes.

For implementation, build a catalogue that records the legal source, access tier, data owner, source system, validation rule, and update trigger for each Annex XIII field category. The catalogue should avoid unsupported extra field lists: add subfields only when they are needed to satisfy an Annex XIII category, an Article 77 technical requirement, a delegated or implementing act, or a verified source-of-record system.

Before publication, test three paths: a consumer scanning the QR code should see only public model data; a user admitted under the Article 77(9) legitimate-interest rules should see only the point 2 or point 4 data allowed for that purpose; and a market surveillance authority or notified body should be able to access the point 2 and point 3 model information available to that role.