Battery Passport Mandatory Fields — Annex XIII Reference

What Annex XIII Requires From Every Battery Passport

Annex XIII of the EU Battery Regulation (Regulation (EU) 2023/1542) defines the mandatory data fields that every battery passport must contain. This is not guidance. It is law. If your battery falls within scope, every field listed in Annex XIII must be populated, accurate, and accessible through the battery passport before you place the product on the EU market.

This reference guide walks through each category of mandatory data, explains what is required, and identifies the practical steps manufacturers must take to achieve compliance.

Which Batteries Are in Scope

The battery passport obligation applies to three categories of batteries placed on the EU market from 18 February 2027:

• Industrial batteries with a capacity above 2 kWh
• Electric vehicle (EV) batteries
• Light means of transport (LMT) batteries

Portable batteries and SLI batteries (starting, lighting, ignition) are excluded from the passport requirement, though they remain subject to other provisions of the Battery Regulation. If you manufacture or import batteries in any of the three in-scope categories, the Annex XIII data fields are non-negotiable.

The February 2027 date applies to batteries placed on the market from that date forward. Batteries already on the market before that date are not retroactively captured, but any new unit entering the EU market after the deadline must carry a compliant battery passport.

The Six Categories of Mandatory Data

Annex XIII organises the mandatory battery passport data into six categories. Each serves a distinct regulatory purpose, from basic product identification through to end-of-life management. Together, they create a comprehensive digital record of the battery across its entire lifecycle.

• Category A — General battery and manufacturer information
• Category B — Carbon footprint information
• Category C — Supply chain due diligence
• Category D — Material composition and hazardous substances
• Category E — Performance and durability parameters
• Category F — End-of-life information

Every field within every category must be completed. Partial compliance is not compliance. Market surveillance authorities will check for completeness, and incomplete passports will trigger enforcement action.

Category A — General Battery and Manufacturer Information

Category A establishes the identity of the battery and the economic operator responsible for it. These are the foundational fields that link every other data point to a specific product.

Manufacturer Identity

The passport must include the name and registered trade name of the manufacturer, along with their postal address, email address, and web address. If the economic operator placing the battery on the EU market is an importer or authorised representative rather than the manufacturer, their details must also be recorded.

Manufacturing Facility

The geographic location of the manufacturing plant where the battery was produced must be declared. This includes the country and, where applicable, the specific site. For manufacturers with multiple production facilities, the passport must identify the exact facility responsible for the specific battery unit.

Battery Model and Technical Identifiers

The battery model identifier, battery type, and the date of placing on the market are required. The battery weight in kilograms must be stated. Rated capacity in ampere-hours (Ah) must be provided. The battery chemistry type — the active materials used in the cathode and anode — must be declared.

Unique Identifier and QR Code

Each battery must carry a unique identifier that is globally unique and machine-readable. This identifier links directly to the battery passport. A QR code must be affixed to the battery, encoding the unique identifier so that any person with a standard smartphone can access the passport data. The QR code must comply with ISO/IEC 18004 and remain legible for the expected lifetime of the battery.

Category B — Carbon Footprint

The carbon footprint requirements are among the most technically demanding fields in Annex XIII. They require lifecycle carbon accounting at a level of rigour that many manufacturers have not previously been required to perform.

Carbon Footprint Value

The battery passport must declare the total carbon footprint of the battery, expressed in kilograms of CO2 equivalent per kilowatt-hour of total energy provided over the battery’s expected service life (kgCO2e/kWh). This figure must be calculated according to the methodology defined in the delegated act adopted under Article 7(1) of the Battery Regulation. The calculation covers the entire lifecycle: raw material extraction, manufacturing, transport, and end-of-life treatment.

Carbon Footprint Performance Class

Based on the declared carbon footprint value, each battery must be assigned a carbon footprint performance class. The performance classes are defined by the Commission and range from the most favourable (lowest carbon) to the least favourable. This classification enables direct comparison between batteries and will eventually support maximum carbon footprint thresholds that exclude the worst-performing products from the EU market.

Manufacturing Carbon Footprint Share

The passport must separately declare the share of the total carbon footprint attributable to the manufacturing phase. This isolates the factory-gate emissions from the wider lifecycle and gives visibility into manufacturing efficiency. It also supports the EU’s objective of incentivising low-carbon manufacturing within Europe.

Link to Carbon Footprint Study

A web-accessible link to the full carbon footprint study or supporting documentation must be provided. This enables verification by market surveillance authorities and supports the due diligence expectations placed on downstream economic operators.

Category C — Supply Chain Due Diligence

Category C addresses the responsible sourcing of raw materials. The Battery Regulation places mandatory supply chain due diligence obligations on economic operators, and the passport must contain evidence of compliance.

The passport must include information on the supply chain due diligence policy of the economic operator, including a reference to or link to the due diligence report. The due diligence requirements apply specifically to cobalt, lithium, nickel, and natural graphite — the four critical raw materials identified by the regulation.

The information must demonstrate alignment with recognised international due diligence standards, including the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. This is not a box-ticking exercise. Market surveillance authorities will assess whether the due diligence is substantive and whether identified risks have been addressed through measurable steps.

Category D — Material Composition and Hazardous Substances

Category D requires full transparency on what is inside the battery. This serves environmental, health, and circular economy objectives.

Hazardous Substances

The passport must declare the presence of any substances of very high concern (SVHCs) as listed under the REACH Regulation (Regulation (EC) 1907/2006) and any hazardous substances classified under the CLP Regulation (Regulation (EC) 1272/2008). The declaration must include the name, concentration, and location within the battery of each hazardous substance present above the applicable threshold.

Material Composition

The full material composition of the battery must be declared, including the chemistry of the cathode, anode, and electrolyte. The weight percentages of critical raw materials — cobalt, lithium, nickel, manganese, and lead — must be specified. This data feeds directly into the EU’s critical raw materials strategy and supports the recycled content targets that come into force in later phases of the Battery Regulation.

Recycled Content

The passport must declare the share of recycled content for cobalt, lithium, nickel, and lead, expressed as a percentage of the total weight of each material in the battery. From 18 August 2031, minimum recycled content thresholds apply: 16% for cobalt, 6% for lithium, 6% for nickel, and 85% for lead. These thresholds increase again from 18 August 2036. The passport must track and report recycled content from the outset to establish baselines.

Category E — Performance and Durability

Category E ensures that buyers, users, and second-life operators have access to the performance data they need to make informed decisions about the battery.

Initial Performance Parameters

At the point of placing on the market, the passport must declare: rated capacity (Ah), nominal voltage (V), expected lifetime expressed in both cycles and calendar years under reference conditions, round-trip energy efficiency at 50% cycle life, internal resistance (in ohms), and C-rate capability for both charging and discharging. These values are determined through standardised testing protocols defined in the delegated acts.

State of Health Over Time

For EV batteries and industrial batteries equipped with battery management systems, the passport must also support dynamic data updates. The state of health (SOH) must be recorded and updated over the battery’s operational life. SOH is expressed as a percentage of remaining capacity relative to rated capacity. This dynamic data requirement transforms the passport from a static product sheet into a living digital record.

The state of health data enables second-life applications. A battery removed from an EV with 80% SOH may be entirely suitable for stationary energy storage. Without transparent SOH data, the second-life market cannot function efficiently. The passport provides this transparency by design.

Category F — End-of-Life Information

Category F closes the loop. It ensures that the information needed for safe handling, collection, and recycling is embedded in the passport from day one.

Dismantling Instructions

The passport must include or link to detailed dismantling instructions specific to the battery model. These instructions must enable safe removal of the battery from the product in which it is installed. They must cover the sequence of operations, required tools, safety precautions, and any components that require special handling.

Safety Information

Safety information for handling end-of-life batteries must be provided, including fire safety protocols, chemical hazard information, and first aid measures. This applies to waste operators, recyclers, and anyone involved in the collection and transport of spent batteries.

Collection and Recycling Information

The passport must include information on collection schemes and take-back programmes applicable to the battery. It must identify the producer responsibility organisation (PRO) responsible for the battery, where applicable. Recycling information must specify the appropriate recycling processes and identify any components that must be removed before recycling.

Data Access Tiers

Not all Annex XIII data is public. The Battery Regulation establishes three tiers of data access, each with different visibility rules.

Public Access

Certain fields are accessible to any person, including consumers, via the QR code. These include the manufacturer identity, battery model, chemistry type, rated capacity, carbon footprint performance class, recycled content shares, collection information, and the unique identifier. The public tier is designed to support informed purchasing decisions and basic end-of-life handling.

Persons of Legitimate Interest

A second tier of data is accessible only to persons with a legitimate interest, such as repairers, second-life operators, recyclers, and researchers. This tier includes detailed performance data, state of health history, dismantling instructions, and detailed material composition. Access is controlled through authentication and must be granted in accordance with data protection requirements.

Authorities Only

Certain commercially sensitive data — including detailed supply chain due diligence reports and the full carbon footprint study — may be restricted to market surveillance authorities and customs authorities only. This tier protects trade secrets while ensuring that enforcement bodies have the information they need to verify compliance.

Data Format and Interoperability Requirements

Annex XIII data must be machine-readable. The Battery Regulation explicitly requires that passport data be structured in a format that supports automated processing and interoperability between systems. This means standardised data schemas, consistent units of measurement, and API-accessible endpoints.

The unique identifier must be encoded in the QR code in a format that resolves to the passport data when scanned. The QR code serves as the data carrier — the physical link between the battery and its digital passport. It must comply with ISO/IEC 18004 and remain scannable throughout the expected service life of the battery.

Interoperability is a core design principle. The data must be accessible to authorised systems across the EU, including the national market surveillance systems of each Member State and the EU customs systems. Proprietary formats that cannot be read by standard systems will not satisfy the interoperability requirement.

How Traceable Maps to Annex XIII

Traceable is purpose-built to map directly to the Annex XIII data schema. Every mandatory field has a corresponding input in the platform, organised by the same six categories defined in the regulation. The compliance scoring feature evaluates each battery passport against the full Annex XIII field list and identifies gaps before submission — so you know exactly what is missing and where to focus your data collection efforts.

The platform generates the unique identifier, produces the QR code in the required format, and manages the three-tier access control model natively. When market surveillance authorities request data, it is available immediately in the required machine-readable format.

Practical Guidance — Starting Your Annex XIII Data Collection

The February 2027 deadline is closer than it appears. Collecting the data required by Annex XIII is not a task that can be completed in weeks. It requires engagement across your supply chain, internal process changes, and in many cases, new testing and measurement capabilities.

Conduct a Gap Analysis

Start by mapping the data you already hold against the full Annex XIII field list. Most manufacturers have Category A data readily available. Category E performance data is typically generated during quality testing. Categories B, C, and D are where the largest gaps appear. Carbon footprint calculations require lifecycle assessment expertise. Supply chain due diligence requires engagement with raw material suppliers, often several tiers deep. Material composition data at the granularity required may not be available from current suppliers without specific requests.

Engage Your Suppliers Early

Your suppliers must provide data that you cannot generate internally. This includes raw material sourcing information, recycled content certificates, and detailed chemical composition data. Start the conversation now. Build data requirements into new supplier contracts and purchase orders. Suppliers who cannot provide the required data by the deadline create a compliance risk for your entire product line.

Establish Your Carbon Footprint Methodology

The carbon footprint declaration requires a lifecycle assessment conducted according to the methodology specified in the delegated act under Article 7. Engage an LCA specialist or build internal capability now. The first calculation cycle will be the most time-intensive. Subsequent updates will be faster once the methodology is established and data collection processes are embedded.

Do Not Wait for Final Implementing Acts

While some technical details are still being finalised through delegated and implementing acts, the core data requirements in Annex XIII are already law. The categories, the fields, and the scope are defined. Waiting for every last specification to be published before starting is a strategy that leads to non-compliance. Begin collecting data against the published Annex XIII structure now. Adjust for technical details as they are clarified.

Regulatory Status and Updates

This guide reflects the regulatory position as of March 2026 and is based on Regulation (EU) 2023/1542 as published in the Official Journal of the European Union. Delegated and implementing acts continue to be developed and may refine specific technical requirements. Subscribe to Regulatory Radar on traceable.digital for updates as new acts are adopted and compliance deadlines approach.