Battery passport: the day-one list is out

At a battery manufacturer, a spreadsheet has been sitting around for months with roughly 90 rows: one row per entry a battery passport could carry, from the chemistry to the state of health. To the right, a column highlighted in red and headed “mandatory 2027?”. Until this summer nobody could fill it in. The Batteries Regulation lists the content but not which of it is due on day one, and every team drew its own line between “due in February 2027” and “due later”.

Since 28 July 2026 there is an answer. The European Commission has published a guidance document that grades all 71 entries in the passport per battery category: mandatory, optional, applicable only in certain cases, or not to be filled as of February 2027. This article shows what has to be in the passport on 18 February 2027, what is explicitly allowed to wait, and what that means for your data.

One honest caveat before the numbers, because the document itself insists on it: this is non-binding guidance, not law. It is titled “Digital Batteries Passport - data points by category”, creates no new obligations and does not prejudge the Commission’s formal position. It is, however, the clearest signal yet of how the Commission reads its own regulation, and it deserves a close reading.

The honest numbers

For an electric vehicle (EV) battery, 51 of the 71 entries are mandatory on 18 February 2027. For light means of transport (LMT: e-bikes, e-scooters, e-mopeds), it is 54. For industrial batteries, 36, with most of the remainder applicable only in certain cases.

That is more than the “an identifier and a few specs” reading some were hoping for. And it is still meaningfully less than the full 90-attribute picture, because the exclusions are precise.

What the day-one core actually contains

You do not need to memorise 71 rows. The mandatory core falls into six groups, and most of it describes what the battery is, not how it was made:

• Identity and origin. The unique identifier, who is responsible for the passport, the manufacturer’s name, address and contact point, the place and date of manufacture, the battery category, the weight, the capacity.
• Composition and safety. The chemistry, hazardous substances beyond mercury, cadmium and lead, critical raw materials above 0.1 percent by weight, the usable extinguishing agent.
• Recycled and renewable content. The recovered shares of cobalt, lithium, nickel and lead, and the share of renewable content. These are on the day-one list, not deferred.
• Performance and durability. Minimum, nominal and maximum voltage, original power capability and power limits, expected lifetime in cycles with its reference test, round-trip energy efficiency initial and at half cycle-life, internal cell and pack resistance, the idle temperature range.
• Circularity and documents. Detailed composition down to cathode, anode and electrolyte, part numbers and spare-part sources, dismantling information, safety measures, the marking requirements, the EU declaration of conformity, waste-prevention information, and test reports for the authorities.
• The living values. The battery’s status (original, repurposed, re-used, remanufactured, waste) and the state-of-health readings, which update over the battery’s life rather than being written once.

What is explicitly not due

The guidance names what does not have to be filled or displayed in February 2027, and the pattern is instructive: everything excluded is exactly where the methodology is not settled yet.

• The carbon footprint declaration and label wait for the Commission’s implementing act that settles calculation and format.
• Responsible-sourcing information waits for the same reason.
• Instructions for use are on hold until the “Omnibus IV” package is adopted, with which the EU simplifies several rules at once.
• Supply-chain due-diligence reporting follows its own track and starts 18 August 2027, under Regulation (EU) 2025/1561.

So the sequencing is not a gap in enforcement; it is the intended shape of a phased regulation. Building carbon-footprint machinery before that act lands is still over-investing.

One list is actually three

The subtler finding, and the one we think matters most for data models: “mandatory” depends on the battery.

An EV battery reports its state of certified energy. An LMT battery instead reports the full state-of-health set: remaining capacity, remaining power capability, remaining round-trip efficiency, the evolution of self-discharge. An industrial battery carries most performance values only if applicable.

A single flat checklist therefore gets every category wrong: it either forces e-bike fields onto EV batteries or lets mandatory EV fields slip. The day-one requirement is not one list; it is three, and your data model has to know which one applies.

Mandatory does not mean public

One more nuance worth having clear before you design anything:

the mandatory list and the public list are not the same list.

The per-battery values - state of health, status, usage history - are mandatory, but the regulation reserves them for readers with a legitimate interest, such as repairers and refurbishers. Test reports go only to notified bodies and market surveillance. The passport a consumer scans shows the public tier; the rest must exist, verifiably, behind access control.

The one field that can turn personal

The day-one list makes the manufacturer’s details public: name, registered trade name, postal address with a single contact point, and optionally a web and an email address. For a company, that is legal-person data and sits outside the General Data Protection Regulation (GDPR). It turns personal in three realistic cases: a sole trader whose company name is their own name, a contact point filled with a named employee, and a personal mailbox in the email field.

The same details are printed on the battery label anyway. The passport raises the stakes: machine-readable, indexed, and, once registered, archived tamper-evident for at least ten years. A printed label fades; a signed version does not, and ours are deliberately built so they cannot be quietly edited.

The regulation itself points to the resolution. It asks for a contact point, not a contact person, and the web and email fields are optional. So the protection that actually works is minimisation at entry: a role-based contact, a role mailbox such as info@, and nothing more.

We built the passport form to steer exactly that way. The optional contact details are separate fields, each carrying its own field-level proof - the same verifiable selective disclosure that lets a restricted reader verify their slice - so any one of them can be corrected or dropped in a later version without touching the others, and the entry hints say it plainly: role contacts, never persons. For what the law mandates, publication rests on a legal obligation. For anything beyond it, the honest engineering answer is simpler than any erasure machinery: what never enters the bytes never needs erasing.

Where we stand

This is the part we cared most about getting right. Our battery data preset follows the guidance verdict for every entry, including the category split: a field that is mandatory for an e-bike battery is not forced onto an EV battery, and the carbon-footprint fields are there from the start, empty and optional until their act arrives. When the later rules land, you fill fields the passport already has, and each update is simply a new signed version on top of the last.

The guidance also announces its own future: later editions will add definitions, measuring units and reporting formats. We track those and will adjust as they land. Encoding the rules as data the platform enforces, rather than a hard-coded schema, is what makes that adjustment routine instead of a rebuild.

What to do in 2026

Three moves, in order.

First, collect the core. Most of the mandatory entries describe what the battery is: chemistry, voltages, mass, recycled content, dismantling information.

That data exists today, spread across your systems and your cell suppliers.

Second, secure the supplier part contractually. The recovered-content shares and the performance test results live with your cell suppliers, and you will not get them by asking nicely. A 2027 deadline is tight for negotiating data clauses into purchasing agreements.

Third, skip what the Commission itself has skipped. Carbon footprint and responsible sourcing are coming, with their own rules and their own dates. A data model with room for them loses nothing by waiting for the rules to settle.

For the wider timeline around the deadline, see our piece on the ESPR timeline 2027.

Everything the regulation asks of battery manufacturers, with the timeline, the roles, the required data, the official documents and a checklist per battery type, is in our reference on the Digital Product Passport for batteries.