--- title: "EU Batteries Regulation Battery Passport Fields" canonical_url: "https://www.sorena.io/artifacts/eu/batteries-regulation/battery-passport-fields" source_url: "https://www.sorena.io/artifacts/eu/batteries-regulation/battery-passport-fields" author: "Sorena AI" description: "Field-level guide to Article 77 and Annex XIII battery passport data: scope, QR access, public and restricted fields, and model versus individual battery records." published_at: "2026-05-09" updated_at: "2026-05-09" keywords: - "EU Batteries Regulation" - "battery passport" - "Article 77" - "Annex XIII" - "QR code" - "LMT batteries" - "industrial batteries" - "electric vehicle batteries" - "Batteries Regulation" - "battery data" --- **[SORENA](https://www.sorena.io/)** - AI-Powered GRC Platform [Home](https://www.sorena.io/) | [Solutions](https://www.sorena.io/solutions) | [Artifacts](https://www.sorena.io/artifacts) | [About Us](https://www.sorena.io/about-us) | [Contact](https://www.sorena.io/contact) | [Portal](https://app.sorena.io) --- # EU Batteries Regulation Battery Passport Fields Field-level guide to Article 77 and Annex XIII battery passport data: scope, QR access, public and restricted fields, and model versus individual battery records. *Batteries Regulation* *Battery passport fields* *EU* ## EU Batteries Regulation Battery Passport Fields Use this page to separate Article 77 passport scope from Annex XIII field groups before designing a battery passport data model. The guide focuses on which batteries need a passport, which data is public or restricted, how the QR code and unique identifier work, and which fields are model-level or individual-battery data. Article 77 of Regulation (EU) 2023/1542 does not require a passport for every battery category. From 18 February 2027, the electronic battery passport applies to each LMT battery, each industrial battery with a capacity greater than 2 kWh, and each electric vehicle battery that is placed on the market or put into service. Annex XIII then divides the passport content into model-level public data, model-level restricted data, authority-only compliance data, and individual-battery data for persons with a legitimate interest. ## Which batteries need an Article 77 battery passport? 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. - In-scope passport categories: LMT batteries, industrial batteries with capacity greater than 2 kWh, and electric vehicle batteries. - Trigger: the covered battery is placed on the market or put into service from the Article 77 application date. - Primary owner: the economic operator placing the battery on the market, with written delegation possible. - Lifecycle change: re-used, repurposed, remanufactured, or waste-status batteries can shift responsibility and may require linked passport records. Sources for this answer: - [Regulation (EU) 2023/1542 on batteries and waste batteries](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Article 77 is the binding source for the battery categories that must have a passport, the economic operator responsibility rule, and passport lifecycle rules. - [EUR-Lex summary of sustainability rules for batteries and waste batteries](https://eur-lex.europa.eu/EN/legal-content/summary/sustainability-rules-for-batteries-and-waste-batteries.html?ref=sorena.io) - EUR-Lex summarizes that battery passports apply to LMT, industrial and EV batteries and distinguishes them from wider labelling and QR-code measures. *Recommended next step* *Placement: after field catalogue section* ## Turn Annex XIII into a battery passport data model Use this guide to separate public, restricted, authority-only, model-level, and individual-battery fields before building or reviewing a passport implementation. - [Open Batteries Regulation Research Copilot](/solutions/research-copilot.md): Ask battery passport implementation questions against cited EU source material. - [Discuss battery passport implementation](/contact.md): Review Article 77 scope, Annex XIII fields, and passport data ownership with Sorena. ## How Article 77 structures passport access Do not treat the passport as one public data dump. Article 77 and Annex XIII create access tiers. Some model information is public; some model information is restricted to persons with a legitimate interest and the Commission; test-report evidence is restricted to notified bodies, market surveillance authorities, and the Commission; individual-battery operational data is restricted to persons with a legitimate interest. 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. - Public access: Annex XIII point 1 model-level information. - Legitimate-interest access: detailed composition, dismantling and safety information, and individual-battery data where the access purpose is allowed. - Authority and notified-body access: test reports proving compliance with the Regulation or acts adopted under it. - Access mechanism: a QR code links to a unique identifier; the passport is not just a static label. Sources for this answer: - [Regulation (EU) 2023/1542 on batteries and waste batteries](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Articles 77 and 78 establish the passport access tiers, QR-code link to a unique identifier, and essential technical requirements for access rights and interoperability. - [European Commission news on the Batteries Regulation entering into force](https://environment.ec.europa.eu/news/new-law-more-sustainable-circular-and-safe-batteries-enters-force-2023-08-17_en?ref=sorena.io) - The Commission explains the practical purpose of QR-code access to a digital passport with detailed battery information for consumers and value-chain professionals. ## Annex XIII field groups to model first 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. - Public model data: Annex VI Part A label information plus sustainability, performance, conformity, marking, and waste-management information listed in Annex XIII point 1. - Restricted model data for legitimate-interest users and the Commission: detailed cathode, anode and electrolyte composition, replacement-spares sources, dismantling information, and safety measures. - Authority-only model data: test-report results proving compliance. - Restricted individual-battery data: performance and durability values at placement and status changes, state of health, status such as original or repurposed, use data, cycles, negative events, operating conditions, and state of charge. Sources for this answer: - [Regulation (EU) 2023/1542 on batteries and waste batteries](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Annex XIII is the binding source for the four battery-passport information groups and their access-right categories. - [EUR-Lex summary of sustainability rules for batteries and waste batteries](https://eur-lex.europa.eu/EN/legal-content/summary/sustainability-rules-for-batteries-and-waste-batteries.html?ref=sorena.io) - EUR-Lex summarizes the wider Batteries Regulation context for components, recycled content, QR-code information, and passport obligations. ## Model data and individual-battery data are different records 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. - Use a model record for stable attributes such as manufacturer label data, chemistry, declared capacity, carbon footprint, due diligence report references, recycled content, marking, and conformity information. - Use an individual-battery record for state changes such as original, re-used, repurposed, remanufactured or waste, plus use-derived data and state-of-health information. - Link re-used, repurposed, or remanufactured passports to original passport records where Article 77 requires a new passport linked to the original passport or passports. - Keep commercially sensitive and safety-relevant data behind the Annex XIII access tier that supports the user's role and purpose. Sources for this answer: - [Regulation (EU) 2023/1542 on batteries and waste batteries](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Article 77 and Annex XIII support the split between battery-model information and individual-battery information, including new passports for re-used, repurposed or remanufactured batteries. ## A practical battery passport field catalogue 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 the public model data; a repairer, remanufacturer, second-life operator or recycler should see only the legitimate-interest data they are allowed to access; and an authority or notified body should be able to access the compliance evidence reserved to that role. - Catalogue columns: Annex XIII group, field category, access tier, model or individual-battery record, accountable owner, source system, validation evidence, update trigger, and QR or identifier dependency. - Required controls: no vendor lock-in, machine-readable and searchable data, restricted introduce-modify-update rights, data integrity, security, privacy, and continued passport availability. - Review triggers: new model, changed battery status, passport delegation, remanufacturing or repurposing, updated conformity evidence, changed due diligence or recycled-content evidence, and QR or unique-identifier changes. - Do not publish restricted detailed composition, dismantling, safety, test-report or individual-use data as public fields unless an access rule clearly permits it. Sources for this answer: - [Regulation (EU) 2023/1542 on batteries and waste batteries](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Articles 77 and 78 support the catalogue controls for access rights, open interoperable data, update restrictions, security, privacy, and continued availability. - [European Commission news on the Batteries Regulation entering into force](https://environment.ec.europa.eu/news/new-law-more-sustainable-circular-and-safe-batteries-enters-force-2023-08-17_en?ref=sorena.io) - The Commission news item supports the visitor-facing explanation that QR-code passport data is intended for consumers and professionals along the battery value chain. ## Primary sources - [Regulation (EU) 2023/1542 on batteries and waste batteries](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Binding source for Article 77 battery passport scope, QR-code access, unique identifiers, operator responsibility, Article 78 technical requirements, and Annex XIII field groups. - Quote: "Battery passport" - [EUR-Lex summary of sustainability rules for batteries and waste batteries](https://eur-lex.europa.eu/EN/legal-content/summary/sustainability-rules-for-batteries-and-waste-batteries.html?ref=sorena.io) - Plain-language EUR-Lex overview confirming that QR-code and battery-passport measures sit within the Batteries Regulation's labelling and information framework. - Quote: "Information and labelling" - [European Commission news on the Batteries Regulation entering into force](https://environment.ec.europa.eu/news/new-law-more-sustainable-circular-and-safe-batteries-enters-force-2023-08-17_en?ref=sorena.io) - Commission explanation of the policy purpose of QR-code access to digital battery passports for consumers and value-chain professionals. - Quote: "A QR code will provide access to a digital passport" ## Related Topic Guides - [Batteries Regulation vs ESPR](/artifacts/eu/batteries-regulation/batteries-regulation-vs-espr.md): Compare EU Batteries Regulation duties with ESPR framework rules: scope, economic operators, DPP overlap, delegated acts, sustainability evidence, and reuse limits. - 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