Deferred Battery Passport Data Points: What You Do Not Have To File in February 2027

The European Commission’s guidance document Digital Batteries Passport, data points by category, version 2.0 of 15 August 2026, enumerates 71 data points for the battery passport. Not all of them have to be filled at February 2027. The guidance marks a subset as “not to be filled/displayed as of February 2027”, and for several of those it names the instrument that has to arrive first.

This page lists them. It exists because the distinction is easy to miss and expensive to get wrong in both directions: budgeting to produce a carbon footprint declaration that will not be displayed, or assuming a deferred data point will never be needed and building a schema that cannot hold it.

How many are deferred

Of the 71 data points, the number mandatory at 18 February 2027 differs by battery category. The number deferred to a later date or instrument does not: it is eight in every category. What differs is how many data points apply only in certain cases or do not apply to the category at all.

Each row totals 71. Conditional (“if applicable”) and optional data points are a different thing again: they apply at February 2027 where the stated circumstance holds. The guidance does not tie repetitions, or data points that do not apply to the category, to any later date or instrument.

Not filled at February 2027 in every battery category

Ten data points are not to be filled or displayed at February 2027 for electric vehicle, LMT and industrial batteries alike. Eight are deferred to a later date or instrument: the carbon footprint declaration and label, responsible sourcing, which the guidance marks as required from August 2027 under Article 48(1), the four recycled content shares, and instructions for use. The other two, material composition and the model-level rated capacity, repeat data declared under other data points.

Two things are worth noting about this table. The carbon footprint declaration and label are deferred for a reason that is independent of the guidance: under Article 7(1) and (2), each declaration and label date applies from the stated calendar date or 12 or 18 months after the relevant delegated act or implementing act enters into force, whichever is the latest. The methodology delegated act under Article 7(1) was due by 18 February 2024 for electric vehicle batteries and has not been adopted as of 26 September 2026, so the declaration obligation has not commenced.

The second is data point 44, the only one the guidance puts on hold “pending Omnibus adoption”. The Annex XIII point 1(t) it cites is not in the Regulation as consolidated on 13 August 2026. The point appears only in the Commission’s proposal COM(2025) 504 of 21 May 2025 on digitalisation and common specifications, part of a simplification package, which has not been adopted as of 26 September 2026 and would limit the entry to stationary battery energy storage systems. Its timing depends on the legislative procedure rather than on a technical specification.

Where the categories diverge: state of health

This is the part most likely to be got wrong, because the pattern is close to inverted between electric vehicle and LMT batteries. Applicability must not be flattened across categories.

An electric vehicle battery therefore carries one state of health data point at February 2027, and the other five do not apply to it. An LMT battery is the reverse: five are mandatory and state of certified energy does not apply. The split comes from the Regulation, not the guidance: Annex VII Part A sets state of certified energy for electric vehicle batteries and the other five parameters for stationary battery energy storage systems and LMT batteries. An industrial battery treats the same five as applicable only in certain cases, since Annex VII names stationary battery energy storage systems rather than every industrial battery.

If you build one state of health schema and apply it to all three categories, you will either over-collect for electric vehicles or under-collect for LMT.

One more difference: capacity threshold for exhaustion

Data point 33, the capacity threshold for exhaustion, is mandatory for electric vehicle batteries and does not apply to LMT or industrial batteries. This one is explained by the Regulation itself rather than the guidance: Annex XIII 1(k) reads “capacity threshold for exhaustion (only for electric vehicle batteries)”. The carve-out is in the legal text.

What this means for how you build

A deferred data point is not an absent one. Seven of the eight are listed in Annex XIII, and the guidance names what each is waiting for: a format implementing act for the carbon footprint declaration and label, the date of 18 August 2027 in Article 48(1) for responsible sourcing, and Article 8 with its delegated act for the four recycled content shares. The sensible reading is that these are obligations with a later or unresolved start date, not obligations that have gone away. The eighth, instructions for use, is different: it cites an Annex XIII point 1(t) that exists only in proposal COM(2025) 504, so it becomes an obligation only if that proposal is adopted with it.

• Collect what you can now, publish what is required. Carbon footprint data takes the longest to assemble because it depends on suppliers. Starting once the implementing act lands leaves very little room.
• Do not design a schema that cannot hold a deferred field. When an instrument adopts, the difference between adding a value and migrating a data model is the difference between a release and a project.
• Model applicability per battery category, not per field name. The state of health table above is the reason.
• Watch four instruments and one date. The Article 7 delegated and implementing acts for data points 17 and 18, the Article 8 recycled content delegated act for data points 20 to 23, the omnibus proposal COM(2025) 504 for data point 44, and 18 August 2027 for responsible sourcing under Article 48(1).

How Traceable handles deferred data points

In Traceable, the publish check does not block on the carbon footprint, recycled content and due diligence fields of a battery passport while those obligations are not yet in force, so a customer can fill them early where supply chain data allows, or leave them empty without the passport failing that check.

Because those fields already exist, the adoption of a pending instrument changes when they start to block publication, not the data model. See the full data point directory, which lets you filter by what is required at February 2027 for each battery category.

Sources

• European Commission, Guidance Document: Digital Batteries Passport, data points by category, version 2.0, 15 August 2026. DG GROW, Directorate G, Unit G2. This document is Commission guidance and states of itself 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”.
• Regulation (EU) 2023/1542, in particular Article 7, Article 14, Article 77 and Annex XIII. This is the binding legal source.

The applicability values on this page are transcribed from the guidance. Where the guidance gives a reason for a deferral, that reason is reproduced rather than paraphrased. Where it gives none, this page says so instead of inferring one.