---
title: EU battery passport data points — the official list and template fields per type
description: "The Commission lists 71 battery passport data points. TracePass's template requires 56 fields for EV/LMT and 41 for industrial >2 kWh from 18 Feb 2027."
canonical: "https://www.tracepass.eu/regulatory/battery-passport-data-points"
locale: en
source: "https://www.tracepass.eu/regulatory/battery-passport-data-points"
---

# EU battery passport data points — the official list and template fields per type

> The Commission lists 71 battery passport data points. TracePass's template requires 56 fields for EV/LMT and 41 for industrial >2 kWh from 18 Feb 2027.

Annex XIII of Regulation (EU) 2023/1542 sets what an EU battery passport must carry. The Commission's guidance (v3.2) breaks it into 71 data points, of which 46 are mandatory for EV batteries, 49 for LMT batteries and 31 for industrial batteries. The TracePass template models them as 142 fields, because one data point can span several fields and the template also carries optional ones, so the two counts are not directly comparable. From 18 February 2027 the template requires 56 fields for EV and LMT batteries and 41 for industrial batteries above 2 kWh; 15 more phase in under separate obligations with their own dates.

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](https://github.com/malinoto/tracepass-dpp-schemas)). "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.

## Template fields per battery sub-type

The table counts TracePass template fields for the three in-scope battery sub-types, not the Commission's data points. Each field cites the Annex XIII point or article behind it. 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 | 56 | 9 | 15 | 38 | 17 |
| LMT batteries | 56 | 15 | 15 | 37 | 18 |
| Industrial >2 kWh | 41 | 30 | 15 | 32 | 8 |

## 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)): 18 August 2027
- recycled-content shares (Art. 8(1); Annex XIII 1(e)): 18 August 2028; LMT: 18 August 2033
- carbon footprint declaration, class and label (Art. 7; Annex XIII 1(c)): date not yet set

## 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 56 required fields for EV batteries, 38 are public and 17 are restricted; the one authority field is the test reports proving compliance (point 3). The split is similar for LMT (37 public, 18 restricted) and industrial >2 kWh (32 public, 8 restricted).

## Frequently asked questions

### How many data points does an EU battery passport require?

It depends on the battery sub-type. The Commission's guidance (v3.2) lists 71 data points: 46 are mandatory for EV batteries, 49 for LMT batteries and 31 for industrial batteries, and the rest are optional, apply only in certain cases or are not to be filled for that type. The TracePass template splits these into smaller fields, so its counts differ. It requires 56 fields each for EV and LMT batteries from 18 February 2027, plus 15 phased fields that enter later, and 41 fields for industrial batteries above 2 kWh, which also have 15 phased fields. The template holds 142 fields in total across all sub-types.

### 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, 56 fields are required and 9 are conditional; for industrial batteries above 2 kWh, 41 are required and 30 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 56 required fields for EV batteries, 38 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.