EU Batteries Regulation Battery passport fields under Article 77 and Annex XIII

Annex XIII starts with a public category for information relating to the battery model. Teams should treat this as model-level information that can be shown to the general public, not as live operating data for a specific battery in use.

The public model-level group covers information such as Annex VI general battery information, material composition, carbon footprint information, responsible sourcing information, recycled content information, selected performance characteristics, marking information, the EU declaration of conformity, and waste-battery prevention and management information. Do not publish a custom expanded list unless each field is mapped back to Annex XIII or a delegated act that changes it.

Annex XIII creates restricted groups rather than a single private bucket. Some battery-model information is available only to persons with a legitimate interest and the Commission, some test-report information is available only to notified bodies, market surveillance authorities and the Commission, and individual-battery information is available only to persons with a legitimate interest.

Design access by role because repairers, remanufacturers, second-life operators, recyclers, purchasers, authorities, notified bodies, and the Commission do not all receive the same view. Article 77 requires the Commission to specify which persons count as having a legitimate interest and what they may download, share, publish, or re-use through implementing acts due by 18 August 2026. Until the applicable rules are identified, a passport operator should not invent broader access or reuse rights.

Use the Regulation's own split as the data-model boundary. Article 77 says the passport contains information relating to the battery model and information specific to the individual battery, including information resulting from use. Annex XIII then assigns access categories to those groups.

Model data should describe the battery model and its regulated characteristics. Individual-battery data should follow the specific unit through status changes, use-derived measurements, state-of-health information, and events. When a battery is prepared for re-use, repurposed, remanufactured, or placed back on the market after such activity, Article 77 requires a new passport linked to the original passport or passports.

Responsibility changes at the waste stage. When the battery becomes waste, responsibility for the passport transfers to the producer, its appointed producer responsibility organisation, or the selected waste management operator, depending on the Article 77 route. The passport ceases to exist after the battery has been recycled; the system should preserve any separate records required by waste, conformity, or traceability law rather than treating passport closure as permission to erase them.

Article 77 requires the battery passport to 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. The Regulation also points to ISO/IEC 15459 standards, or equivalents, for the QR code and unique identifier.

Article 78 adds the operating requirements. Access must be free of charge and based on the access rights in Annex XIII and the Article 77 implementing act. Passport data must use open standards, be interoperable, machine-readable, structured and searchable, and be protected by controls for authentication, integrity, security, privacy, and restricted update rights.

The shared DPP registry became operational on 20 July 2026. Commission Implementing Regulation (EU) 2026/1778 takes effect on 6 August 2026 and sets registration, verification, identifier, API, access-management, semantic-repository, and logging rules. The detailed passport data remains in the decentralised system maintained by the responsible economic operator or its authorised service provider.