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 1.0 of 28 July 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 deferred past February 2027 differs by battery category, as does the number mandatory at that date.

The remaining data points in each category are conditional (“if applicable”) or optional, which is a different thing again: they apply at February 2027 where the stated circumstance holds.

Deferred for every battery category

Six data points are deferred for electric vehicle, LMT and industrial batteries alike.

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: Article 7 makes every carbon footprint date conditional, applying from the stated calendar date or 12 to 18 months after the methodology delegated act and the format implementing act enter into force, whichever is the latest. That delegated act was due by 18 February 2024 for electric vehicle batteries and has not been adopted. The obligation has not commenced.

The second is data point 44, the only one the guidance attributes to Omnibus IV. That is a simplification package rather than a technical specification, so its timing is a political question rather than a drafting one.

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 defers five. An LMT battery does close to the opposite: five mandatory, one deferred. An industrial battery treats the same five as conditional, applying where the circumstance holds.

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 deferred for LMT and industrial. 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. It is listed in Annex XIII, it has a legal source, and in three cases the guidance names the instrument that will bring it into effect. The sensible reading is that these are obligations with an unresolved start date, not obligations that have gone away.

• 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 three instruments, not one. The Article 7 methodology delegated act, the format implementing act referenced by data points 17 to 19, and Omnibus IV for data point 44.

How Traceable handles deferred data points

Our battery templates carry every data point that is mandatory at February 2027 and every data point Annex XIII lists but defers. Deferred fields are present in the data model and marked as not required for publication, so a customer can populate them early if their supply chain data allows, and can leave them empty without the passport being treated as incomplete.

When one of the three instruments adopts, the change is a configuration update rather than a schema migration. 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 1.0, 28 July 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.