---
title: "EU Batteries Regulation battery passport fields FAQ"
canonical_url: "https://www.sorena.io/artifacts/eu/batteries-regulation/faq/battery-passport-fields"
source_url: "https://www.sorena.io/artifacts/eu/batteries-regulation/faq/battery-passport-fields"
author: "Sorena AI"
description: "FAQ on Article 77 and Annex XIII battery passport field groups, public and restricted access, QR codes, unique identifiers, and model versus individual battery data."
published_at: "2026-05-09"
updated_at: "2026-05-09"
keywords:
  - "EU Batteries Regulation"
  - "battery passport"
  - "Article 77"
  - "Annex XIII"
  - "QR code"
  - "unique identifier"
  - "access rights"
  - "Batteries Regulation"
---
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---

# EU Batteries Regulation battery passport fields FAQ

FAQ on Article 77 and Annex XIII battery passport field groups, public and restricted access, QR codes, unique identifiers, and model versus individual battery data.

*FAQ* *Battery passport* *EU*

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

Article 77 requires battery passports for LMT batteries, industrial batteries above 2 kWh, and electric vehicle batteries, with field access controlled by Annex XIII.

Use this FAQ to separate public fields, restricted field groups, QR and unique identifier requirements, and responsibility for keeping passport data accurate.

Under the EU Batteries Regulation, the battery passport is not one open field list. From 18 February 2027, Article 77 applies the passport requirement to 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. Annex XIII then separates model-level and individual-battery information, while Article 78 requires access rights, interoperability, security, and controlled update permissions.

## Which EU Batteries Regulation battery passport fields are public?

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.

- Build the passport data model with a field-level access category: public model information, restricted model information, authority-only information, or individual-battery information.
- Keep public fields tied to the battery model and version, so changes to chemistry, performance data, declaration status, or Article 13 marking information trigger review.
- Avoid exposing individual usage, state-of-health, accident, or operating-condition data as public information unless a later binding rule expressly changes the access category.

Sources for this answer:

- [Regulation (EU) 2023/1542 on batteries, Article 77 and Annex XIII](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Binding source for the battery passport's model-level public information category and the split between public and restricted access.
- [EUR-Lex summary of Regulation (EU) 2023/1542](https://eur-lex.europa.eu/EN/legal-content/summary/sustainability-rules-for-batteries-and-waste-batteries.html?ref=sorena.io) - Official summary confirming that QR codes and battery passports are part of the Regulation's labelling and information framework.

## Which battery passport information is restricted under Annex XIII?

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.

The practical point is access design: repairers, remanufacturers, second-life operators, recyclers, purchasers, authorities, notified bodies, and the Commission do not all receive the same view. Article 77 also says the Commission must specify which persons count as having a legitimate interest and what they may download, share, publish, or re-use.

- Separate restricted model information used for dismantling, safety, detailed composition, replacement spares, and similar circular-economy activities from public model information.
- Keep compliance test-report access narrower: Annex XIII places those results with notified bodies, market surveillance authorities, and the Commission.
- Treat individual-battery data, including status, state of health, use-derived data, and recorded operating conditions, as a legitimate-interest access workflow rather than a public web page.

Sources for this answer:

- [Regulation (EU) 2023/1542 on batteries, Article 77 and Annex XIII](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Binding source for Annex XIII restricted access groups and Article 77 legitimate-interest implementing-act criteria.

## How should teams separate model data from individual battery data?

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.

- Store a model record for fields that are shared by all units of the same regulated battery model.
- Store an individual record for unit-specific status, use, state-of-health, and lifecycle-event data.
- Create update controls for status changes such as original, repurposed, re-used, remanufactured, or waste, because those labels affect access and responsibility.

Sources for this answer:

- [Regulation (EU) 2023/1542 on batteries, Article 77 and Annex XIII](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Binding source for the distinction between battery-model information, individual-battery information, and new linked passports after re-use, repurposing or remanufacturing.

## What do Article 77 and Article 78 require for QR codes, identifiers, and access rights?

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.

- Do not treat the QR code as the passport itself; it is the access route that links to the unique identifier and passport record.
- Assign responsibility for accuracy, completeness, and updates to the economic operator placing the battery on the market, or to an authorised operator acting on its behalf.
- Design role-based permissions for reading, introducing, modifying, and updating passport information before exposing the passport externally.

Sources for this answer:

- [Regulation (EU) 2023/1542 on batteries, Articles 77 and 78](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Binding source for QR-code access, unique identifier requirements, operator data-maintenance responsibility, interoperability, and access-right controls.
- [European Commission news on the EU Batteries Regulation](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 that the QR code gives access to a digital passport with detailed information for consumers and professionals in the value chain.

## Primary sources

- [Regulation (EU) 2023/1542 on batteries](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Primary legal source for Article 77 battery passport scope, Annex XIII field-access categories, QR and unique identifier requirements, and Article 78 technical design rules.
  - Quote: "Battery passport"
- [EUR-Lex summary of Regulation (EU) 2023/1542](https://eur-lex.europa.eu/EN/legal-content/summary/sustainability-rules-for-batteries-and-waste-batteries.html?ref=sorena.io) - Official summary source for the Regulation's information, labelling, QR code, and battery passport context.
  - Quote: "QR code and battery passports"
- [European Commission news on the EU Batteries Regulation](https://environment.ec.europa.eu/news/new-law-more-sustainable-circular-and-safe-batteries-enters-force-2023-08-17_en?ref=sorena.io) - Commission implementation-context source explaining that QR codes provide access to digital battery passports for consumers and value-chain professionals.
  - Quote: "access to a digital passport"

## 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.
- [Battery Passport Data Model Template for the EU Batteries Regulation](/artifacts/eu/batteries-regulation/battery-passport-data-model-template.md): Template for an EU Batteries Regulation battery passport data model: Article 77 scope, QR-linked identifiers, Annex XIII field groups, access tiers, owners, and evidence.
- [Battery passport evidence workflow under EU Regulation 2023/1542](/artifacts/eu/batteries-regulation/battery-passport-evidence-workflow.md): Build a battery passport evidence workflow for Article 77 and Annex XIII: QR code access, access rights, provenance, conformity evidence, lifecycle updates, and ownership.
- [Battery Passport vs ESPR Digital Product Passport](/artifacts/eu/batteries-regulation/battery-passport-vs-digital-product-passport.md): Compare the EU Batteries Regulation battery passport with the ESPR digital product passport framework across scope, access rights, QR and data carrier rules, interoperability, and reuse limits.
- [EU Batteries Regulation Applicability Test](/artifacts/eu/batteries-regulation/applicability-test.md): Decide whether Regulation (EU) 2023/1542 applies to a battery, battery cell, module, pack, product with an incorporated battery, operator role, or EU market activity.
- [EU Batteries Regulation Article 11 removability FAQ](/artifacts/eu/batteries-regulation/faq/removability-and-replaceability.md): FAQ on Article 11 removability and replaceability duties for portable and LMT batteries, including end-user removal, professional replacement, spares, software, and evidence.
- [EU Batteries Regulation Article 11: battery removability and replaceability](/artifacts/eu/batteries-regulation/removability-and-replaceability.md): Article 11 guidance for portable and LMT batteries: end-user replacement, independent professionals, instructions, spare batteries, compatible batteries, software limits, and evidence.
- [EU Batteries Regulation Article 13 labels and consumer information](/artifacts/eu/batteries-regulation/labeling-and-consumer-information.md): Article 13 guide to EU battery labels, separate collection marking, heavy-metal symbols, QR code links, capacity and duration notices, packaging fallback, and evidence.
- [EU Batteries Regulation Article 8 recycled content calculation FAQ](/artifacts/eu/batteries-regulation/faq/recycled-content-calculation.md): FAQ on Article 8 recycled content calculations for EU Batteries Regulation battery models, materials, thresholds, documentation, and delegated methodology status.
- [EU Batteries Regulation Battery Categories and Scope](/artifacts/eu/batteries-regulation/battery-categories-and-scope.md): Classify batteries under Regulation (EU) 2023/1542 across portable, SLI, LMT, electric vehicle, and industrial categories, including incorporated batteries and multipurpose products.
- [EU Batteries Regulation battery category routing workflow](/artifacts/eu/batteries-regulation/battery-category-routing-workflow.md): Classify portable, SLI, LMT, EV, industrial, and incorporated batteries under Regulation (EU) 2023/1542, then route carbon footprint, recycled content, passport, removability, due diligence, and waste-battery duties.
- [EU Batteries Regulation Battery Passport Fields](/artifacts/eu/batteries-regulation/battery-passport-fields.md): 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.
- [EU Batteries Regulation category routing FAQ: portable, LMT, SLI, EV and industrial batteries](/artifacts/eu/batteries-regulation/faq/category-routing.md): FAQ guidance for routing batteries under Regulation (EU) 2023/1542 across portable, LMT, SLI, EV and industrial categories, including incorporated batteries and obligation checks.
- [EU Batteries Regulation compliance checklist](/artifacts/eu/batteries-regulation/checklist.md): A grounded checklist for Regulation (EU) 2023/1542 covering battery category, operator role, conformity, CE marking, labels, QR codes, passports, removability, due diligence, waste batteries, and evidence records.
- [EU Batteries Regulation compliance structure](/artifacts/eu/batteries-regulation/compliance.md): Structure Batteries Regulation compliance by battery category, operator role, conformity evidence, passport data, removability, due diligence, and waste-battery responsibility.
- [EU Batteries Regulation Conformity Assessment](/artifacts/eu/batteries-regulation/conformity-assessment-and-ce-marking.md): Article 17 and Annex VIII guide to EU Batteries Regulation conformity assessment, EU declarations of conformity, CE marking, notified bodies, and release evidence.
- [EU Batteries Regulation deadlines and compliance calendar](/artifacts/eu/batteries-regulation/deadlines-and-compliance-calendar.md): A grounded EU Batteries Regulation calendar for application dates, secondary-act dependencies, QR and passport milestones, removability, carbon footprint, recycled content, and waste obligations.
- [EU Batteries Regulation due diligence program: Chapter VII requirements](/artifacts/eu/batteries-regulation/due-diligence-program.md): Article 47-52 guide to battery due diligence policies, management systems, supply-chain controls, Annex X risks, third-party verification, disclosure, and records.
- [EU Batteries Regulation due diligence threshold FAQ](/artifacts/eu/batteries-regulation/faq/due-diligence-thresholds.md): FAQ on the EU Batteries Regulation Chapter VII due diligence threshold, Article 47 exclusions, Annex X raw materials, and verification and disclosure records.
- [EU Batteries Regulation Due Diligence Thresholds](/artifacts/eu/batteries-regulation/due-diligence-thresholds.md): Check when Chapter VII battery due diligence applies under Regulation (EU) 2023/1542, including the EUR 40 million turnover exclusion, second-life battery exclusion, raw material scope, and notified-body verification route.
- [EU Batteries Regulation economic operator roles FAQ](/artifacts/eu/batteries-regulation/faq/economic-operator-roles.md): FAQ on manufacturer, importer, distributor, fulfilment service provider, producer, and second-life operator roles under Regulation (EU) 2023/1542.
- [EU Batteries Regulation FAQ](/artifacts/eu/batteries-regulation/faq.md): Answers to practical EU Batteries Regulation questions on battery categories, CE conformity, QR labels, battery passports, due diligence, removability, and waste collection duties.
- [EU Batteries Regulation NANDO and notified bodies FAQ](/artifacts/eu/batteries-regulation/faq/nando.md): When notified bodies matter under the EU Batteries Regulation, how to use the Single Market Compliance Space/NANDO lookup, and what scope evidence to retain.
- [EU Batteries Regulation penalties and fines: Article 93 enforcement framework](/artifacts/eu/batteries-regulation/penalties-and-fines.md): Source-grounded guide to EU Batteries Regulation penalties: Article 93 Member State rules, market-surveillance action, formal non-compliance, due diligence enforcement, and evidence to preserve.
- [EU Batteries Regulation Producer Responsibility](/artifacts/eu/batteries-regulation/waste-collection-and-producer-responsibility.md): Grounded guide to EU Batteries Regulation EPR: producer registration, free take-back, portable and LMT collection targets, distributor duties, treatment evidence, and Member State boundaries.
- [EU Batteries Regulation producer responsibility reporting workflow](/artifacts/eu/batteries-regulation/producer-responsibility-reporting-workflow.md): A source-grounded workflow for EU Batteries Regulation producer registration, EPR reporting, collection evidence, take-back records, and Article 75 data handoffs.
- [EU Batteries Regulation QR code and label timing FAQ](/artifacts/eu/batteries-regulation/faq/qr-and-label-timing.md): FAQ on Article 13 battery labels, the 18 February 2027 QR code rule, battery passport access, and Commission act dependencies under Regulation (EU) 2023/1542.
- [EU Batteries Regulation recycled content and recovery targets](/artifacts/eu/batteries-regulation/recycled-content-and-recovery-targets.md): Article 8 recycled-content duties, Annex XII recycling efficiency and material recovery targets, covered battery categories, materials, dates, and evidence records.
- [EU Batteries Regulation requirements overview](/artifacts/eu/batteries-regulation/requirements.md): A grounded overview of Regulation (EU) 2023/1542 requirements for battery scope, sustainability, conformity, labels, QR codes, passports, due diligence, waste duties, and evidence outputs.
- [EU Batteries Regulation supplier due diligence questionnaire](/artifacts/eu/batteries-regulation/battery-due-diligence-supplier-questionnaire.md): Supplier questionnaire structure for EU Batteries Regulation battery due diligence: Chapter VII scope, Annex X raw materials, supply-chain evidence, verification, disclosure, and records.
- [EU Batteries Regulation: carbon footprint declaration requirements and data](/artifacts/eu/batteries-regulation/carbon-footprint-declarations.md): Article 7 carbon footprint declaration scope, required fields, lifecycle stages, technical documentation, and public-access evidence for EU battery compliance.
- [EU Batteries Regulation: CE Marking FAQ](/artifacts/eu/batteries-regulation/faq/ce-and-conformity-assessment.md): FAQ on Article 17 conformity assessment, Annex VIII modules, EU declarations of conformity, CE marking, notified bodies, and importer and distributor checks under Regulation (EU) 2023/1542.
- [EU Batteries Regulation: choosing the right conformity assessment route](/artifacts/eu/batteries-regulation/conformity-assessment-route-workflow.md): Choose the Article 17 conformity assessment route for batteries under Regulation (EU) 2023/1542, including Module A, D1, G, notified body evidence, declaration, and CE marking outputs.
- [EU Batteries Regulation: evidence pack for carbon footprint and recycled content targets](/artifacts/eu/batteries-regulation/carbon-footprint-and-recycled-content-evidence.md): What to keep for EU Batteries Regulation Article 7 carbon-footprint declarations and Article 8 recycled-content documentation, with covered battery categories and source-linked evidence fields.
- [EU Batteries Regulation: Waste Collection FAQ](/artifacts/eu/batteries-regulation/faq/waste-collection-and-recycling-reporting.md): FAQ on EU Batteries Regulation waste battery collection, producer registration, free take-back, collection targets, recycling, and reporting evidence.
- [EU Battery Passport Implementation Under Article 77](/artifacts/eu/batteries-regulation/battery-passport-implementation.md): Source-grounded implementation guide for Article 77 battery passports: scope, QR codes, identifiers, access rights, updates, storage, and responsibility transfers.
- [FAQ: EU Batteries Regulation carbon footprint performance classes](/artifacts/eu/batteries-regulation/faq/carbon-footprint-classes.md): FAQ on Article 7 carbon footprint declarations, performance classes, maximum-threshold sequencing, covered battery categories, and delegated-act dependencies.

*Recommended next step*

*Placement: after access-rights section*

## Turn battery passport fields into an access-controlled data model

Use Article 77, Annex XIII, and Article 78 to separate public model fields, restricted model fields, authority-only records, and individual-battery data before exposing the passport.

- [Open Research Copilot](/solutions/research-copilot.md): Answer EU Batteries Regulation implementation questions with cited source material.
- [Discuss battery passport implementation](/contact.md): Review Article 77 scope, Annex XIII access groups, and passport evidence workflows with Sorena.


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