A battery passport is the electronic record that every electric vehicle battery, every light means of transport (LMT) battery and every industrial battery above 2 kWh must carry from 18 February 2027 under Regulation (EU) 2023/1542. New European Commission guidance says that on that date, several of its best-known fields are not to be filled in at all: the carbon footprint, and all four recycled-content shares.
That is close to the opposite of the preparation advice we have seen, ours included. Below is what the guidance asks for on day one, what it defers, and the part that matters most for anyone quoting it: which of its verdicts come from the Regulation, and which are the guidance's own.
What does a battery passport need on 18 February 2027?
The date is fixed in the law. Article 77(1) of Regulation (EU) 2023/1542 says that from 18 February 2027, 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 "shall have an electronic record". Our EU battery passport guide covers who that catches and when.
What goes into that record on the day is a different question, and until recently nobody official had answered it field by field. In August 2026 the Commission's Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs (DG GROW) did. Its Guidance Document: Digital Batteries Passport – data points by category, version 2.0 dated 15 August 2026 and announced on 21 August, lists 71 data points and gives each one a separate verdict for EV, LMT and industrial batteries: mandatory, optional, applicable only in certain cases, or not to be filled or displayed as of February 2027. The data points are numbered 1 to 71 in a single table, and "row 24" below means that table's row 24 — the guidance's numbering, not the Regulation's.
Start with what is mandatory for all three categories at launch. Unless marked otherwise, these sit in point 1 of Annex XIII, the part the public reads.
| What | Rows | Where it comes from |
|---|---|---|
| Unique identifier | 1 | Article 77(3) — outside Annex XIII |
| Who registers or is responsible for the passport | 2 | The guidance says Article 77(3); outside Annex XIII, see below |
| Manufacturer identity and basic specification | 3–15 | Annex XIII 1(a) → Annex VI Part A |
| Share of renewable content | 24 | Annex XIII 1(f) |
| Voltages, original power capability and power limits | 26–30 | Annex XIII 1(h), 1(i) |
| Idle temperature range | 34 | Annex XIII 1(l) |
| Internal cell and pack resistance | 38 | Annex XIII 1(o) |
| Article 13(4) marking | 40 | Annex XIII 1(q) |
| EU declaration of conformity | 42 | Annex XIII 1(r) |
| Waste-battery information, Article 74(1)(a) to (f) | 43 | Annex XIII 1(s) |
| Everything in Annex XIII points 2 and 3 | 45–50 | Annex XIII 2(a)–(d), 3 |
| Battery status | 67 | Annex XIII 4(c) |
The identifier sits outside Annex XIII, and so does row 2, which the guidance also sources to Article 77(3). For the identifier: Article 77(3) says the passport is reached through a QR code linking to a unique identifier that the economic operator placing the battery on the market assigns to it. The rows 3 to 15 block covers name and postal address with a single contact point, battery category, model and batch or serial number, place and date of manufacture, weight, capacity, chemistry, hazardous substances other than mercury, cadmium and lead, usable extinguishing agent, and critical raw materials present above 0.1 % by weight. Who reads the restricted parts, and what that means for the tool you pick, is the subject of our breakdown of the Annex XIII contents list.
Two entries in that table are not what they look like. Row 2 asks who registers or is responsible for the passport, and the guidance sources it to Article 77(3). The Regulation does not use that phrase anywhere. What it does say, at Article 77(4), is that the economic operator placing the battery on the market must keep the passport information accurate, complete and up to date. And row 5, the manufacturer's web and email address, is the one optional entry inside the rows 3 to 15 block — "to be filled if such data is available". That condition is the statute's own: Article 38(7) asks a manufacturer to indicate "and, if available, web and email address".
The share of renewable content is worth a second look for the opposite reason. Annex XIII 1(f) asks for it bare, with no delegated act and no date behind it, unlike 1(c) and 1(e), which point at Articles 7 and 8. The guidance marks it mandatory in February 2027 for all three categories.
One field people expect to be mandatory is not. The commercial warranty period (row 35) is conditional for every category: "if applicable (if commercial warranty envisaged)".
Which battery passport data points are left blank in February 2027?
Ten point 1 data points are marked not to be filled or displayed for every battery category, and they fall into six groups. Two groups are duplicates. The other four are deferrals, and each has a different reason.
Read the wording carefully, because the guidance uses one phrase for three different situations. "Not to be filled/displayed as of February 2027" means deferred in time. "Not to be filled/displayed — repetition" means you have already given the value elsewhere. And the same phrase with no suffix at all means the field never applies to that battery category: row 33 for LMT and industrial, row 61 for LMT and industrial, rows 62 to 66 for EV. The table below carries the first two kinds, and its middle column says which is which. The third kind is a matter of battery category, and the section after next deals with it.
| Data point | Verdict at 18 February 2027 | Why, and what happens later |
|---|---|---|
| Carbon footprint declaration and carbon footprint label (rows 17, 18) | Not to be filled or displayed as of February 2027 | Format "still to be specified in the upcoming implementing act". Annex XIII 1(c) points at Article 7, whose declaration applies from a calendar date or 12 to 18 months after the supporting acts enter into force, whichever is later, and neither act exists |
| Recycled cobalt, lithium, nickel and lead shares (rows 20 to 23) | Not to be filled or displayed as of February 2027 | "To be applied in line with Article 8 and the relevant delegated act". Article 8(1) itself sets the documentation duty at the later of 18 August 2028 or 24 months after that act, and 18 August 2033 for LMT batteries |
| Information on responsible sourcing (row 19) | Not to be filled or displayed as of February 2027 | "As provided in Article 48(1), required from August 2027". Article 48(1) starts battery due diligence on 18 August 2027. One route out of that chapter needs both of Article 47's first conditions: net turnover under EUR 40 million in the financial year before last, and not being part of a group that exceeds EUR 40 million on a consolidated basis. That exemption removes the Article 52(3) report this row draws on. The passport duty itself is unaffected: Article 77(1) has no small-business threshold. But this row's source is gone, not merely postponed |
| Instructions for use (row 44) | Not to be filled or displayed as of February 2027 | "Application provisions on hold pending Omnibus adoption". The guidance does not say which Omnibus |
| Material composition (row 16) | Not to be filled, repetition | The same information is already collected by rows 12, 13 and 15 |
| Rated capacity in Ah, in point 1 (row 25) | Not to be filled, repetition of row 11 | Asked again in point 4 as row 51, where it is wanted, this time as live in-service data |
Two of them are the fields most preparation checklists lead with.
The carbon footprint and the recycled-content shares are not being dropped. They are waiting on acts that do not exist yet. The recycled-content methodology in particular is close: the Commission published a draft delegated act on 12 August 2026, with feedback closing on 9 September 2026 (initiative 14858). Even after it lands, Article 8(1) attaches the obligation to a date years out.
Deferred is not cancelled, and the timing is awkward. A brand that stops collecting carbon footprint and recycled-content data because it is blank in February 2027 will be caught out later, when both become real obligations. What changes is the deadline you are working to, not whether the work is needed.
One row sources itself to a provision that does not exist. The guidance cites the instructions-for-use row to "BR Annex XIII 1 (t)". Annex XIII point 1 runs from (a) to (s) and stops. There is no (t), which fits the guidance's own note that those provisions are waiting on the Omnibus. If you quote that row, cite the guidance for it, not the Regulation.
Is the Commission's guidance actually law?
No, and the document is unusually direct about it. It says it "should not be considered as representative of the European Commission's official position", that the information in it "does not extend in any way the rights and obligations deriving from applicable legislation nor introduce any additional requirement", and that its views "are not authoritative and cannot prejudge any future actions the European Commission may take, including potential positions before the Court of Justice of the European Union".
So why read it at all? Because it comes from the directorate-general that owns the Digital Product Passport policy file, and because it is the only field-by-field statement of the February 2027 obligation we have found from an official source. A market surveillance officer opening a passport in 2027 will not be applying this document. But a brand deciding what to build this autumn has nothing better to work from.
Treat it the way you would treat a well-informed regulator's view of an unsettled question: worth following, and not a defence on its own.
Which battery passport data points depend on the battery category?
This is where quoting the guidance gets dangerous. Three different things are going on and they look identical on the page.
The principle is law. Article 77(2), fourth subparagraph, says the Annex XIII information "shall be included in the battery passport to the extent applicable to the category or sub-category of battery concerned". Category-conditional inclusion is lawful.
The Regulation makes only two mappings by battery category itself.
The first is Annex XIII 1(k), which asks for the "capacity threshold for exhaustion (only for electric vehicle batteries)". The carve-out is in the Annex's own words. It is the only one in the whole of point 1: 1(j), 1(n) and 1(p) state expected lifetime, round-trip efficiency and the C-rate flatly, with no category limit at all.
The second arrives through a cross-reference. Annex XIII 4(b) asks for state of health "pursuant to Article 14"; Article 14 sends you to Annex VII; and Annex VII Part A splits it by battery type in its own text: state of certified energy for electric vehicle batteries, and for stationary battery energy storage systems and LMT batteries, the remaining capacity, the remaining power capability and round trip efficiency where possible, the evolution of self-discharging rates, and the ohmic resistance where possible. The EV-versus-LMT state of health split is statutory. Guidance rows 61 to 66 carry it across. Read the LMT column together with the row name, though: rows 63, 64 and 66 keep the Annex's "where possible" inside the data point name itself — "where possible, the remaining power capability", and the same for the remaining round trip efficiency and the ohmic resistance. So "Mandatory" in the LMT column marks the row as in scope for LMT batteries, as against "not to be filled" for EV. It does not turn a qualified parameter into an unconditional one.
The Regulation also carries conditionals that have nothing to do with battery category at all, and the guidance copies those into its row names the same way. They are easy to mistake for the guidance's own softening, because they surface as the same words: "if applicable". Annex XIII 4(a) asks for the performance and durability values "referred to in Article 10(1)", Article 10(1) sends you to Annex IV Part A, and Annex IV Part A says "Where applicable, energy round trip efficiency and its fade (in %)" at point 4 and "in terms of cycles, except for non-cycle applications, and calendar years" at point 5. The guidance copies those qualifiers straight into its row names: row 57 is titled "Where applicable, energy round trip efficiency (in %)", and row 59 carries "except for non-cycle applications". Row 5 works the same way: Article 38(7) already says a manufacturer indicates "if available, web and email address". So the condition behind the point 4 "if applicable" on rows 57 and 58 is Annex IV Part A's "Where applicable", not a judgement DG GROW made.
The guidance says as much about itself. Its footnote on "if applicable" defines the term as "to take into account the applicable provisions of Regulation 2023/1542 and relevant implementing legislation and to consider if the technical parameter in question is relevant for the battery" — a pointer back to the Regulation, not a dispensation.
What is left over is the guidance's own allocation, and it is the per-category columns. In point 1, expected lifetime in cycles and its reference test (rows 31, 32), initial round-trip efficiency and the same at 50 % of cycle life (36, 37) and the C-rate (39) are mandatory for EV and LMT batteries but "only applicable for some industrial batteries", and for the two lifetime rows only those "where lifetime can be expressed in cycles". Annex XIII 1(j), 1(n) and 1(p) state all three flatly. No provision of the Regulation narrows them to some industrial batteries. DG GROW does.
There is one row that splits down the middle, and it is easy to get wrong in both directions. Row 61, state of certified energy, is "not to be filled" for LMT and industrial batteries, and that follows from Annex VII Part A giving it to electric vehicle batteries alone. But on rows 62 to 66 the guidance marks the industrial column "if applicable", and that part is the guidance's own rendering. Annex VII Part A names stationary battery energy storage systems, not industrial batteries, and Article 3, point (15) defines a stationary system as one kind of industrial battery. So the law splits EV from LMT, and the guidance maps that split onto a category the law did not use.
Do not tell an industrial battery maker they owe nothing on state of health. That is true of row 61 only. Rows 62 to 66 are marked "if applicable" for industrial batteries, which is not the same as absent.
The practical consequence: when you write down why a field does not apply to your battery, name the right source, and check which point you are in. "Article 77(2) exempts us" is wrong for the round-trip efficiency rows in point 1 — Article 77(2) makes that kind of exemption possible, but it does not make that one, and the guidance is what narrows those rows to some industrial batteries. On the point 4 performance rows the same words have a different owner: there, "where applicable" is Annex IV Part A's own, and citing the Regulation for it is correct. The state of health rows further down point 4 are a separate case again — see the note above.
Why does the same data point appear twice with different answers?
Annex XIII point 1 is public. Point 4 is restricted to persons with a legitimate interest. Five values appear in both, under near-identical names, and one under exactly the same name. Their verdicts do not match.
| Data point | Point 1, public | Point 4, legitimate interest |
|---|---|---|
| Round trip energy efficiency | Rows 36, 37: mandatory for EV and LMT, some industrial | Rows 57, 58: "if applicable" for all three — the law's own "where applicable", Annex IV Part A |
| Expected lifetime | Rows 31, 32: mandatory for EV and LMT, some industrial | Rows 59, 60: mandatory for EV and LMT, "if applicable" industrial |
| Internal resistance | Row 38: mandatory for all three | Rows 55, 56: mandatory for EV and LMT, "if applicable" industrial |
| Rated capacity (in Ah) | Row 25: "not to be filled", repetition of row 11 | Row 51: "same as data point 11 (capacity). but now dynamic"; "if applicable" for industrial |
| Power | Row 29, "original power capability (in Watts)": mandatory for all three | Row 53, "Power (in W)": mandatory for EV and LMT, "if applicable" industrial |
Rated capacity is the clearest trap. Read row 25 on its own and you conclude the passport does not want rated capacity in amp-hours. It does, in point 4, as a value that moves over the battery's life alongside capacity fade. Row 25 is only saying do not type the same static number twice on the public page.
This is not a quirk of the guidance. It follows from the structure of the law: point 1 describes the battery model as sold, point 4 describes an individual battery in service. The same quantity has a different meaning in each. If you are mapping fields into a system, carry the Annex point with the field name or you will eventually publish one of these with the wrong verdict.
What is still missing before 18 February 2027?
Three gaps, all of them the Commission's or the standards bodies' to close, not yours — and one contradiction inside the Regulation that nobody has said they will fix.
Who counts as a person with a legitimate interest is undefined. Point 4 of Annex XIII may be read only by "persons with a legitimate interest" — for instance a repairer, a remanufacturer, a second-life operator or a recycler, and also the purchaser of a battery, or someone acting on the purchaser's behalf, making that battery available to an independent energy aggregator or an energy market participant. Who actually qualifies, and how much they may download, share, publish and re-use, is left to the Commission in an implementing act. That act is the one that missed its deadline: Article 77(9) required it by 18 August 2026. The initiative has been public since 23 January 2026 (16473), and as of 1 September 2026 it is still at the planning stage, with no draft text published and the Commission's own planned adoption window running to the end of 2026. So a passport built today has to lock parts of itself to a group whose membership nobody has defined.
The recycled-content methodology is a draft. Initiative 14858, published 12 August 2026, with feedback closing 9 September 2026. It is the act the four recycled-content rows are waiting on.
Two of the eight DPP standards are not published. Six CEN/CENELEC JTC 24 standards were published in May 2026 and cited in the Official Journal by Commission Implementing Decision (EU) 2026/1736. FprEN 18239, on access-rights management, and FprEN 18246, on data authentication, were not yet published as of 1 September 2026; publication is expected around September 2026, and we could not confirm a publication date for either against CEN's own catalogue. One caution if you are counting on them: publishing is not the trigger. A follow-on Commission implementing decision has to cite them in the Official Journal first, and that citation route belongs to the Ecodesign Regulation (EU) 2024/1781 rather than the Batteries Regulation, which runs its own at Article 15(3). Our piece on the standards and test environment sets out what that means for a battery maker.
And the Regulation does not agree with itself about who else reads point 2. Article 77(2)(c) gives points 2 and 4 to persons with a legitimate interest. Article 77(2)(b) gives points 2 and 3 to notified bodies, market surveillance authorities and the Commission. Annex XIII point 2's own sentence says that information "shall be accessible only to persons with a legitimate interest and the Commission", naming neither notified bodies nor market surveillance authorities. And Article 78(f), the rule that governs how a passport restricts access, makes the right to read, add or change the information in a passport subject to the access rights specified in Annex XIII and to the implementing act under Article 77(9) — not to Article 77(2). That act will not resolve it either: it runs only to Article 77(2)(c). Treat the question as open. Building point 2 so that notified bodies and market surveillance authorities can read it is the safer answer to a market surveillance demand, Article 78(f) is the argument against it, and the decision is worth writing down either way.
What should a battery brand do in the next six months?
The guidance does not reduce the work. It moves it.
- Finish the mandatory list first. Manufacturer identity, category, model, place and date of manufacture, weight, capacity, chemistry, hazardous substances, extinguishing agent, critical raw materials, the renewable content share, voltages, power, temperature range, internal resistance, marking, the declaration of conformity and the waste information. All of it is due on 18 February 2027 for every category, and none of it is waiting on an act.
- Do not stop collecting carbon footprint and recycled-content data. Blank in February 2027 is not blank forever, and both need supplier engagement that takes longer than the deadline they eventually carry.
- Build the per-unit plumbing now. Point 4 wants values that change while the battery is in service: capacity, power, internal resistance, fade, state of health, status, cycle counts. That is a data feed, not a form, and it is the piece that cannot be assembled in the last quarter. Our guide to what data a passport actually needs covers the collection side.
- Record the source of every "not applicable". The Regulation for Annex XIII 1(k), for the EV-versus-LMT state of health split, and for the "where applicable" and "except for non-cycle applications" qualifiers that Annex IV Part A puts on the point 4 performance rows. The guidance for the per-category columns it added on top. A file that cannot tell the two apart will not survive a challenge.
- Watch two files. Initiative 16473 for access rights and 14858 for recycled content. Both change what a passport must show, and neither is settled.
- Decide who else reads point 2, and write down why. Article 77(2)(b) gives it to notified bodies, market surveillance authorities and the Commission; Article 77(2)(c) gives it to persons with a legitimate interest; Annex XIII point 2's own sentence names only the latter and the Commission; and Article 78(f) ties access to Annex XIII. The Regulation does not settle it, and the Article 77(9) act reaches only who qualifies under (c), so make the call deliberately and record it.
If you are choosing software, the field-level question is whether it can hold the Annex XIII list at all, and whether it separates the public part from the restricted parts. We signed in to four tools and checked. And if you sell something other than batteries, the DPP timeline shows how far behind batteries your own category sits.
Start free with PassportCraft and draft a battery passport, so you can see what you still have to collect before the date arrives.
Frequently Asked Questions
Does the battery passport need a carbon footprint in February 2027?
No. The Commission's August 2026 guidance marks both the carbon footprint declaration and the carbon footprint label "not to be filled/displayed as of February 2027", because the format is still to be specified in an implementing act that has not been adopted. The obligation arrives later, once the supporting acts under Article 7 of Regulation (EU) 2023/1542 are in force. The guidance is not law, so treat it as the Commission's current view rather than a permission.
Which battery passport data points are mandatory on 18 February 2027?
For all three categories: the unique identifier, which Article 77(3) places outside Annex XIII, and the identity of who registers or is responsible for the passport, which the guidance also sources to Article 77(3), and then in the public part of Annex XIII the manufacturer identity and address, battery category, model and serial or batch number, place and date of manufacture, weight, capacity, chemistry, hazardous substances, extinguishing agent, critical raw materials above 0.1 % by weight, the share of renewable content, the voltages, original power capability and power limits, the idle temperature range, internal cell and pack resistance, the Article 13(4) marking, the EU declaration of conformity and the Article 74(1)(a) to (f) waste information. Expected lifetime, round-trip efficiency and the C-rate are mandatory for EV and LMT batteries and conditional for industrial ones. In the restricted parts, the whole of Annex XIII points 2 and 3 and the battery status (row 67) are mandatory as well.
Is the Commission's battery passport guidance legally binding?
No. The document states that it "should not be considered as representative of the European Commission's official position", that it does not extend rights or obligations, and that it cannot prejudge future Commission action. It carries weight because it comes from DG GROW, which owns the Digital Product Passport policy file, and because it is the only field-by-field statement of the February 2027 obligation we have found. It is not a defence in itself.
Do industrial batteries need state of health data in the battery passport?
Partly. State of certified energy (row 61) is for electric vehicle batteries only, which follows from Annex VII Part A of Regulation (EU) 2023/1542. The Commission's guidance marks the five remaining values — remaining capacity, remaining power capability, remaining round trip efficiency, evolution of self-discharging rates and ohmic resistance — Mandatory for LMT batteries and "if applicable" for industrial ones. Three of those five carry the Annex's own "where possible" inside the data point name, so Mandatory there marks the row as applying to LMT batteries rather than making the parameter unconditional. Annex VII Part A names stationary battery energy storage systems rather than industrial batteries, and Article 3, point (15) makes a stationary system one kind of industrial battery, so that industrial verdict is the guidance's reading rather than the Regulation's text.
When does responsible sourcing information have to appear in a battery passport?
Not in February 2027. The guidance marks it "not to be filled/displayed as of February 2027 — as provided in Article 48(1), required from August 2027". Article 48(1) of Regulation (EU) 2023/1542 starts the battery due diligence obligations on 18 August 2027, so the report that feeds the passport row does not exist before then.
About the author
Irina Aguiar is a co-founder of PassportCraft, where she translates EU product-compliance law into practical guidance for the companies that place products on the EU market. Her work covers the Digital Product Passport across ESPR product groups — textiles, batteries, electronics, and furniture — alongside GS1 Digital Link data carriers, recyclability and substance-of-concern reporting, and the delegated-act timelines brands need to plan around. She focuses on turning dense regulatory text into checklists a founder can actually act on.
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