Annex XIII is organised by who may see the data. Point 1 is public. Point 2 (detailed composition, spare-part information, dismantling and safety information) is for persons with a legitimate interest and the Commission. Point 3 (test reports proving compliance) is for notified bodies, market surveillance authorities and the Commission. Point 4 (state of health and expected lifetime) is for persons with a legitimate interest.
The counts on this page come directly from the field definitions in the battery template, where each field cites the Annex XIII point or article that requires it (published as open data in the tracepass-dpp-schemas repository). "Required" means the field must appear in every passport of that sub-type from 18 February 2027. "Conditional" means the field applies when certain characteristics are present — for example whether the battery has a battery management system, is rechargeable or uses external storage. "Phased" means the field has its own later obligation date that overrides the February 2027 baseline. "Public" and "restricted" follow the Annex XIII point each field falls under. The counts are TracePass's reading of the Regulation; the field-by-field sources are public so you can check them.
Data points per battery sub-type
The table shows counts for the three in-scope battery sub-types. All counts are derived from the Annex XIII field definitions. The Phased column covers three separate obligations — due diligence, recycled content, and carbon footprint — that are not yet mandatory from day one.
| Required (18 Feb 2027) | Conditional | Phased (later) | Public | Restricted | |
|---|---|---|---|---|---|
| EV batteries | 55 | 3 | 15 | 37 | 17 |
| LMT batteries | 55 | 9 | 15 | 36 | 18 |
| Industrial >2 kWh | 40 | 24 | 15 | 31 | 8 |
Public = accessible to anyone; Restricted = persons with a legitimate interest.
Three obligations phase in after February 2027
The 15 phased data points in the table do not all become mandatory at the same time. They belong to three separate obligations, each governed by its own provision in the Battery Regulation and its own implementation date.
supply-chain due diligence report
Art. 48, Art. 52(3); Annex XIII 1(d)
recycled-content shares
Art. 8(1); Annex XIII 1(e)
LMT batteries: 18 August 2033
carbon footprint declaration, class and label
Art. 7; Annex XIII 1(c)
Public and restricted access
Annex XIII assigns each data point one of three access levels. Public fields are readable by anyone who scans the QR code or resolves the passport URL — no authentication required. Restricted fields are for persons with a legitimate interest and the Commission (Annex XIII points 2 and 4). Authority fields are for notified bodies, market surveillance authorities and the Commission (point 3). Of the 55 required fields for EV batteries, 37 are public and 17 are restricted; the one authority field is the test reports proving compliance (point 3). The split is similar for LMT (36 public, 18 restricted) and industrial >2 kWh (31 public, 8 restricted).
Public
Anyone with the QR code or passport URL. No authentication required.
Restricted
Authorised market participants — recyclers, repair operators, leasing companies, operators of end-of-life treatment.
Authority only
Notified bodies, market surveillance authorities and the Commission. One field: the test reports proving compliance (point 3).
Frequently asked questions
How many data points does an EU battery passport require?
It depends on the battery sub-type. EV batteries and LMT batteries each require 55 fields from 18 February 2027, plus 15 phased fields that enter later. Industrial batteries above 2 kWh require 40 fields immediately and also have 15 phased fields. All counts derive from Annex XIII of Regulation (EU) 2023/1542.
What is the difference between required and conditional data points?
Required fields must appear in every battery passport of that sub-type regardless of the battery's characteristics. Conditional fields apply only when the battery meets a specific criterion — for example whether the battery has a battery management system, is rechargeable or uses external storage. For EV batteries, 55 fields are required and 3 are conditional; for industrial batteries above 2 kWh, 40 are required and 24 are conditional.
When do the phased data points become mandatory?
Three groups of fields phase in after the February 2027 launch. Supply-chain due-diligence fields (Art. 48, Art. 52(3); Annex XIII 1(d)) become mandatory from 18 August 2027. Recycled-content share fields (Art. 8(1); Annex XIII 1(e)) become mandatory from 18 August 2028 for most batteries, and from 18 August 2033 for LMT batteries. Carbon-footprint fields (Art. 7; Annex XIII 1(c)) apply once the Commission's carbon-footprint acts are adopted and apply; no date is set yet.
Which battery passport data points are publicly accessible?
Annex XIII assigns each field an access level. Of the 55 required fields for EV batteries, 37 are publicly accessible to anyone with the passport URL, and 17 are for persons with a legitimate interest. Restricted fields cover detailed composition, spare-part, dismantling and safety information (point 2) and state of health (point 4). The test reports proving compliance (point 3) are for notified bodies, market surveillance authorities and the Commission.
Does the passport obligation apply to all battery types?
No. Article 77(1) of Regulation (EU) 2023/1542 limits the battery passport requirement to three sub-types: EV batteries, LMT batteries (light means of transport — e-bikes, scooters, e-mopeds), and industrial batteries with a capacity above 2 kWh. Portable batteries, SLI batteries and industrial batteries of 2 kWh or less are out of scope for the passport as it stands.
Build the battery passport — every field structured and sourced
TracePass reads your datasheets and reference databases to suggest values for the 55 required fields, with source and confidence for each. You approve, your suppliers fill the gaps, and TracePass publishes the passport once it is complete. The phased fields are already in the template — they stay blank or estimated until their obligation dates arrive.