Battery Passport Mandatory Fields — Annex XIII Reference

Battery Passport Data Point Directory

All 71 data points, filterable by battery type, what is required at February 2027, grouping, data type and free-text search. Every row cites its source in the Regulation.

Source: European Commission guidance, Digital Batteries Passport, data points by category, version 2.0, 15 August 2026 (DG GROW, Unit G2). That document is Commission guidance, not law: it states that it “should not be considered as representative of the European Commission’s official position” and “does not extend in any way the rights and obligations deriving from applicable legislation”. The binding legal source is Regulation (EU) 2023/1542, in particular Article 77 and Annex XIII, together with Annex VI Part A which Annex XIII point 1(a) incorporates by reference. Primary text: EUR-Lex.

How Annex XIII is organised: four numbered points, each one an access tier. Point 1 is publicly accessible, point 2 is restricted to persons with a legitimate interest and the Commission, point 3 to notified bodies and market surveillance authorities, and point 4 covers individual-battery data for persons with a legitimate interest. Annex XIII has no Parts A to F. The groupings in the Grouping column below are Traceable’s own, added to make this table readable; they are not the Regulation’s structure.

Counts: 71 data points in total. Mandatory and required at February 2027: 47 for EV, 50 for LMT, 32 for industrial above 2 kWh. These are data points. The Traceable platform stores them as a larger number of discrete attributes because it decomposes several of them per substance and per lifecycle stage; that attribute count is a property of our data model, not of the Regulation.

Search

Battery type All in-scope types Industrial > 2 kWh EV LMT

Required at February 2027 Show all Required at February 2027 Not required at February 2027

Grouping (Traceable) All groupings Identity and origin Physical and material characteristics Carbon, sourcing and circularity Performance and durability Marking, conformity and user information Repair, dismantling and end of life

Access tier All access tiers Public (Annex XIII point 1) Persons with a legitimate interest (points 2 and 4) Notified bodies and authorities (point 3)

Showing 71 of 71 data points.

No.	Data point	Legal source	Access tier	Grouping	Industrial > 2 kWh	EV	LMT
1	Unique identifier	Article 77 (3)	Public (Annex XIII point 1)	Identity and origin	Mandatory	Mandatory	Mandatory
2	Identity of who is registering and/or is responsible for the battery passport	Article 77 (3)	Public (Annex XIII point 1)	Identity and origin	Mandatory	Mandatory	Mandatory
3	Manufacturer name, registered trade name or registered trade mark	Annex VI A (1)	Public (Annex XIII point 1)	Identity and origin	Mandatory	Mandatory	Mandatory
4	Manufacturer postal address, indicating a single contact point	Annex VI A (1)	Public (Annex XIII point 1)	Identity and origin	Mandatory	Mandatory	Mandatory
5	If available, manufacturer web and email address	Annex VI A (1)	Public (Annex XIII point 1)	Identity and origin	Optional	Optional	Optional
6	Battery category	Annex VI A (2)	Public (Annex XIII point 1)	Identity and origin	Mandatory	Mandatory	Mandatory
7	Model identification and batch or serial number, or product number or another element allowing their identification	Annex VI A (2)	Public (Annex XIII point 1)	Identity and origin	Mandatory	Mandatory	Mandatory
8	The place of manufacturer (geographical location of a battery manufacturing plant)	Annex VI A (3)	Public (Annex XIII point 1)	Identity and origin	Mandatory	Mandatory	Mandatory
9	The date of manufacturing (month and year)	Annex VI A (4)	Public (Annex XIII point 1)	Identity and origin	Mandatory	Mandatory	Mandatory
10	The weight	Annex VI A (5)	Public (Annex XIII point 1)	Physical and material characteristics	Mandatory	Mandatory	Mandatory
11	The capacity	Annex VI A (6)	Public (Annex XIII point 1)	Physical and material characteristics	Mandatory	Mandatory	Mandatory
12	The chemistry	Annex VI A (7)	Public (Annex XIII point 1)	Physical and material characteristics	Mandatory	Mandatory	Mandatory
13	The hazardous substances present in the battery, other than mercury, cadmium or lead	Annex VI A (8)	Public (Annex XIII point 1)	Physical and material characteristics	Mandatory	Mandatory	Mandatory
14	Usable extinguishing agent	Annex VI A (9)	Public (Annex XIII point 1)	Physical and material characteristics	Mandatory	Mandatory	Mandatory
15	Critical raw materials present in the battery in a concentration of more than 0,1 % weight by weight	Annex VI A (10)	Public (Annex XIII point 1)	Physical and material characteristics	Mandatory	Mandatory	Mandatory
16	The material composition of the battery, including its chemistry, hazardous substances present in the battery, other than mercury, cadmium or lead, and critical raw materials present in the battery	Annex XIII 1 (b)	Public (Annex XIII point 1)	Physical and material characteristics	Not required at launch	Not required at launch	Not required at launch
17	The carbon footprint declaration	Annex XIII 1 (c)	Public (Annex XIII point 1)	Carbon, sourcing and circularity	Not required at launch	Not required at launch	Not required at launch
18	The carbon footprint label	Annex XIII 1 (c)	Public (Annex XIII point 1)	Carbon, sourcing and circularity	Not required at launch	Not required at launch	Not required at launch
19	Information on responsible sourcing as indicated in the report on battery due diligence policy referred to in Article 52(3)	Annex XIII 1 (d)	Public (Annex XIII point 1)	Carbon, sourcing and circularity	Not required at launch	Not required at launch	Not required at launch
20	Percentage share of cobalt that is present in active materials and that has been recovered from battery manufacturing waste or post-consumer waste	Annex XIII 1 (e)	Public (Annex XIII point 1)	Carbon, sourcing and circularity	Not required at launch	Not required at launch	Not required at launch
21	Percentage share of lithium that is present in active materials and that has been recovered from battery manufacturing waste or post-consumer waste	Annex XIII 1 (e)	Public (Annex XIII point 1)	Carbon, sourcing and circularity	Not required at launch	Not required at launch	Not required at launch
22	Percentage share of nickel that is present in active materials and that has been recovered from battery manufacturing	Annex XIII 1 (e)	Public (Annex XIII point 1)	Carbon, sourcing and circularity	Not required at launch	Not required at launch	Not required at launch
23	The percentage share of lead that is present in the battery and that has been recovered from waste	Annex XIII 1 (e)	Public (Annex XIII point 1)	Carbon, sourcing and circularity	Not required at launch	Not required at launch	Not required at launch
24	The share of renewable content	Annex XIII 1 (f)	Public (Annex XIII point 1)	Carbon, sourcing and circularity	Mandatory	Mandatory	Mandatory
25	Rated capacity (in Ah)	Annex XIII 1 (g)	Public (Annex XIII point 1)	Performance and durability	Not required at launch	Not required at launch	Not required at launch
26	Minimal voltage, with temperature range when relevant	Annex XIII 1 (h)	Public (Annex XIII point 1)	Performance and durability	Mandatory	Mandatory	Mandatory
27	Nominal voltage, with temperature range when relevant	Annex XIII 1 (h)	Public (Annex XIII point 1)	Performance and durability	Mandatory	Mandatory	Mandatory
28	Maximum voltage, with temperature range when relevant	Annex XIII 1 (h)	Public (Annex XIII point 1)	Performance and durability	Mandatory	Mandatory	Mandatory
29	Original power capability (in Watts)	Annex XIII 1 (i)	Public (Annex XIII point 1)	Performance and durability	Mandatory	Mandatory	Mandatory
30	Power limits, with temperature range when relevant	Annex XIII 1 (i)	Public (Annex XIII point 1)	Performance and durability	Mandatory	Mandatory	Mandatory
31	Expected battery lifetime expressed in cycles	Annex XIII 1 (j)	Public (Annex XIII point 1)	Performance and durability	Conditional	Mandatory	Mandatory
32	Reference test used for expected battery lifetime expressed in cycles	Annex XIII 1 (j)	Public (Annex XIII point 1)	Performance and durability	Conditional	Mandatory	Mandatory
33	Capacity threshold for exhaustion	Annex XIII 1 (k)	Public (Annex XIII point 1)	Performance and durability	Not required at launch	Mandatory	Not required at launch
34	Temperature range the battery can withstand when not in use (reference test)	Annex XIII 1 (l)	Public (Annex XIII point 1)	Performance and durability	Mandatory	Mandatory	Mandatory
35	Period for which the commercial warranty for the calendar life applies	Annex XIII 1 (m)	Public (Annex XIII point 1)	Performance and durability	Conditional	Conditional	Conditional
36	Initial round trip energy efficiency	Annex XIII 1 (n)	Public (Annex XIII point 1)	Performance and durability	Conditional	Mandatory	Mandatory
37	Round trip energy efficiency at 50 % of cycle-life	Annex XIII 1 (n)	Public (Annex XIII point 1)	Performance and durability	Conditional	Mandatory	Mandatory
38	Internal battery cell and pack resistance	Annex XIII 1 (o)	Public (Annex XIII point 1)	Performance and durability	Mandatory	Mandatory	Mandatory
39	C-rate of relevant cycle- life test	Annex XIII 1 (p)	Public (Annex XIII point 1)	Performance and durability	Conditional	Mandatory	Mandatory
40	The marking requirements laid down in Article 13(4)	Annex XIII 1 (q)	Public (Annex XIII point 1)	Marking, conformity and user information	Mandatory	Mandatory	Mandatory
41	The marking requirements laid down in Article 13(5)	Annex XIII 1 (q)	Public (Annex XIII point 1)	Marking, conformity and user information	Conditional	Conditional	Conditional
42	The EU declaration of conformity referred to in Article 18	Annex XIII 1 (r)	Public (Annex XIII point 1)	Marking, conformity and user information	Mandatory	Mandatory	Mandatory
43	The information regarding the prevention and management of waste batteries laid down in Article 74(1), points (a) to (f).	Annex XIII 1 (s)	Public (Annex XIII point 1)	Marking, conformity and user information	Mandatory	Mandatory	Mandatory
44	Clear, understandable and readable instructions for use in a format that makes it possible to print, download and save them on an electronic device so that the user can access them at all times, in particular during a breakdown of the battery	Annex XIII 1 (t)	Public (Annex XIII point 1)	Marking, conformity and user information	Not required at launch	Not required at launch	Not required at launch
45	Detailed composition, including materials used in the cathode, anode and electrolyte	Annex XIII 2 (a)	Persons with a legitimate interest (points 2 and 4)	Repair, dismantling and end of life	Mandatory	Mandatory	Mandatory
46	Part numbers for components	Annex XIII 2 (b)	Persons with a legitimate interest (points 2 and 4)	Repair, dismantling and end of life	Mandatory	Mandatory	Mandatory
47	Contact details of sources for replacement spares	Annex XIII 2 (b)	Persons with a legitimate interest (points 2 and 4)	Repair, dismantling and end of life	Mandatory	Mandatory	Mandatory
48	Dismantling information, including at least: -	Annex XIII 2 (c)	Persons with a legitimate interest (points 2 and 4)	Repair, dismantling and end of life	Mandatory	Mandatory	Mandatory
49	Safety measures	Annex XIII 2 (d)	Persons with a legitimate interest (points 2 and 4)	Repair, dismantling and end of life	Mandatory	Mandatory	Mandatory
50	Results of test reports proving compliance with the requirements laid down in this Regulation or any delegated or implementing act adopted pursuant to this Regulation	Annex XIII 3	Notified bodies and authorities (point 3)	Marking, conformity and user information	Mandatory	Mandatory	Mandatory
51	Rated capacity (in Ah)	Annex XIII 4 (a)	Persons with a legitimate interest (points 2 and 4)	Performance and durability	Conditional	Mandatory	Mandatory
52	Capacity fade (in %)	Annex XIII 4 (a)	Persons with a legitimate interest (points 2 and 4)	Performance and durability	Conditional	Mandatory	Mandatory
53	Power (in W)	Annex XIII 4 (a)	Persons with a legitimate interest (points 2 and 4)	Performance and durability	Conditional	Mandatory	Mandatory
54	Power fade (in %)	Annex XIII 4 (a)	Persons with a legitimate interest (points 2 and 4)	Performance and durability	Conditional	Mandatory	Mandatory
55	Internal resistance (in Ω)	Annex XIII 4 (a)	Persons with a legitimate interest (points 2 and 4)	Performance and durability	Conditional	Mandatory	Mandatory
56	Internal resistance increase (in %)	Annex XIII 4 (a)	Persons with a legitimate interest (points 2 and 4)	Performance and durability	Conditional	Mandatory	Mandatory
57	Where applicable, energy round trip efficiency (in %)	Annex XIII 4 (a)	Persons with a legitimate interest (points 2 and 4)	Performance and durability	Conditional	Conditional	Conditional
58	Where applicable, energy round trip efficiency fade (in %)	Annex XIII 4 (a)	Persons with a legitimate interest (points 2 and 4)	Performance and durability	Conditional	Conditional	Conditional
59	The expected life-time of the battery under the reference conditions for which it has been designed, in terms of cycles, except for non- cycle applications	Annex XIII 4 (a)	Persons with a legitimate interest (points 2 and 4)	Performance and durability	Conditional	Mandatory	Mandatory
60	The expected life-time of the battery under the reference conditions for which it has been designed, in terms of calendar years	Annex XIII 4 (a)	Persons with a legitimate interest (points 2 and 4)	Performance and durability	Conditional	Mandatory	Mandatory
61	Information on the state of health of the battery pursuant to Article 14: state of certified energy	Annex XIII 4 (b)	Persons with a legitimate interest (points 2 and 4)	Repair, dismantling and end of life	Not required at launch	Mandatory	Not required at launch
62	Information on the state of health of the battery pursuant to Article 14: remaining capacity	Annex XIII 4 (b)	Persons with a legitimate interest (points 2 and 4)	Repair, dismantling and end of life	Conditional	Not required at launch	Mandatory
63	Information on the state of health of the battery pursuant to Article 14: where possible, the remaining power capability	Annex XIII 4 (b)	Persons with a legitimate interest (points 2 and 4)	Repair, dismantling and end of life	Conditional	Not required at launch	Mandatory
64	Information on the state of health of the battery pursuant to Article 14: where possible, the remaining round trip efficiency	Annex XIII 4 (b)	Persons with a legitimate interest (points 2 and 4)	Repair, dismantling and end of life	Conditional	Not required at launch	Mandatory
65	Information on the state of health of the battery pursuant to Article 14: [where possible,] the evolution of self- discharging rates	Annex XIII 4 (b)	Persons with a legitimate interest (points 2 and 4)	Repair, dismantling and end of life	Conditional	Not required at launch	Mandatory
66	Information on the state of health of the battery pursuant to Article 14: where possible, the ohmic resistance	Annex XIII 4 (b)	Persons with a legitimate interest (points 2 and 4)	Repair, dismantling and end of life	Conditional	Not required at launch	Mandatory
67	Information on the status	Annex XIII 4 (c)	Persons with a legitimate interest (points 2 and 4)	Repair, dismantling and end of life	Mandatory	Mandatory	Mandatory
68	The number of charging and discharging cycles	Annex XIII 4 (d)	Persons with a legitimate interest (points 2 and 4)	Repair, dismantling and end of life	Conditional	Conditional	Conditional
69	Negative events, such as accidents	Annex XIII 4 (d)	Persons with a legitimate interest (points 2 and 4)	Repair, dismantling and end of life	Conditional	Conditional	Conditional
70	Periodically recorded information on the operating environmental conditions, including temperature	Annex XIII 4 (d)	Persons with a legitimate interest (points 2 and 4)	Repair, dismantling and end of life	Conditional	Conditional	Conditional
71	Periodically recorded information on the state of charge	Annex XIII 4 (d)	Persons with a legitimate interest (points 2 and 4)	Repair, dismantling and end of life	Conditional	Conditional	Conditional

What Annex XIII Requires From Every Battery Passport

Annex XIII of the EU Battery Regulation (Regulation (EU) 2023/1542) defines what the battery passport must contain. This is not guidance. It is law. What it does not do is require every entry at once: the European Commission guidance enumerates 71 data points, of which 47 are mandatory for electric vehicle batteries at 18 February 2027, 50 for LMT and 32 for industrial above 2 kWh, with the rest conditional, optional, or deferred past that date. Whatever applies to your battery must be populated, accurate and accessible through the 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.

How Annex XIII Is Organised

Annex XIII is organised as four numbered points, and each point is an access tier rather than a subject area. This is the most commonly misunderstood thing about the battery passport: the structure answers who may see this, not what kind of data is it. Annex XIII has no Parts A to F.

• Point 1, sub-points (a) to (t): publicly accessible information relating to the battery model. Point 1(a) incorporates the information specified in Part A of Annex VI, which is why manufacturer identity, battery category, chemistry, weight and capacity sit here.
• Point 2, sub-points (a) to (c): model information accessible only to persons with a legitimate interest and the Commission. Detailed cathode, anode and electrolyte composition, part numbers, and dismantling information.
• Point 3: results of test reports, accessible only to notified bodies, market surveillance authorities and the Commission.
• Point 4, sub-points (a) to (d): data relating to an individual battery, accessible only to persons with a legitimate interest. Performance values, state of health, battery status, and usage data.

Not every data point must be filled at February 2027. The European Commission guidance marks several as not to be filled or displayed at that date, including the carbon footprint declaration and the carbon footprint label, both waiting on the format-specifying implementing act. Use the launch-status filter in the directory below to separate what you must file now from what you should capture but need not publish yet.

General Battery and Manufacturer Information

These data points establish 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.

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.

Supply Chain Due Diligence

These data points address 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.

Material Composition and Hazardous Substances

These data points require 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.

Performance and Durability

These data points ensure 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.

End-of-Life Information

These data points close 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 data point has a corresponding input in the platform. Our groupings are presentational and are ours, not the Regulation, which organises Annex XIII by access tier. 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 already hold the identity and physical characteristics data. Performance data is typically generated during quality testing. The largest gaps are usually carbon footprint, supply chain due diligence and recycled content. 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.