The Final Technical Standard Is Published
The European Commission has adopted the delegated act that defines the precise technical requirements for battery passports. This is the document that transforms Annex XIII of the Battery Regulation from a policy framework into an implementable specification. Manufacturers now have the definitive reference for what their battery passports must contain, how the data must be structured, and who can access which fields.
What the Delegated Act Confirms
- Data format — Battery passport data must be structured as JSON-LD (JSON for Linking Data) using the W3C Verifiable Credentials Data Model 2.0 context. This ensures interoperability across platforms, registries, and verification systems.
- Field requirements — All fields specified in Annex XIII are confirmed as mandatory. The delegated act adds technical precision: data types (string, decimal, date), enumerated value lists (e.g., chemistry types), and unit specifications (kWh, kg CO2e, percentage).
- Data access tiers — Three tiers are defined:
- Public — Accessible to anyone scanning the QR code: general product information, environmental labels, basic sustainability data
- Authorised — Accessible to economic operators, recyclers, and repairers with verified credentials: detailed technical data, supply chain information
- Restricted — Accessible only to market surveillance authorities: full compliance documentation, audit trails, enforcement-relevant data
- Enforcement date — February 18, 2027 is reaffirmed with no transitional period
What Manufacturers Should Do Now
With 12 months remaining, this is the final call for preparation. Companies that have been waiting for the “final” specification now have it. The recommended actions are:
- Download the published JSON-LD schema and validate your existing passport data against it
- Verify that your DPP platform supports all three data access tiers
- Complete any remaining supplier data collection for Annex XIII fields
- Conduct an end-to-end test: create a passport, generate the QR code, scan it, and verify that the correct data appears for each access tier
- Prepare for EU Central Registry registration (launching July 2026)