EU Battery Passport Checklist — Annex XIII Mandatory Fields

EU Battery Passport Checklist — Annex XIII Mandatory Fields

The EU Battery Regulation (EU) 2023/1542 mandates a digital battery passport for every industrial battery above 2 kWh, every electric vehicle battery, and every light means of transport (LMT) battery placed on the EU market from 18 February 2027. Annex XIII of the regulation defines the exact data fields that must be recorded and made accessible through the battery passport. This checklist translates those requirements into a practical, line-by-line verification tool for manufacturers preparing for compliance.

If you manufacture, import, or place any of these battery categories on the EU single market, every item below applies to you. There are no exemptions for small production volumes. There are no grace periods beyond the stated deadline. The data must be complete, accurate, and machine-readable at the point of placing on the market.

Use this checklist to audit your current data readiness against every mandatory field in Annex XIII. Any gap you identify now is a gap you can close before enforcement begins.

Category A — General Battery and Manufacturer Information

Annex XIII, Part A requires foundational identification data for the battery and the economic operator responsible for placing it on the market. This data anchors the passport and links every subsequent field to a specific, traceable product.

Manufacturer Identity

• Manufacturer name and registered trade name are recorded exactly as they appear in the EU business register.
• Manufacturer postal address, including street, city, postal code, and country, is documented in full.
• Manufacturer contact details (email, telephone) are current and reachable.
• Authorised representative details (if applicable) are recorded with name, address, and contact information.

Manufacturing Facility

• Geographic location of the manufacturing plant is recorded, including country and city at minimum.
• If multiple facilities contribute to final assembly, the principal manufacturing site is identified.

Battery Identification

• Battery model name or commercial designation is recorded.
• Battery category is declared: industrial battery (>2 kWh), EV battery, or LMT battery, as defined under Article 3 of Regulation (EU) 2023/1542.
• Battery chemistry is specified (e.g., NMC, LFP, NCA, solid-state) using standard nomenclature.
• Nominal voltage (V) is documented.
• Battery weight (kg) is recorded, including the tolerance range if applicable.
• Rated capacity (Ah) is stated as determined under the conditions specified in the regulation.
• Date of manufacture is recorded in a standardised date format (ISO 8601 recommended).
• Place of manufacture is captured (country and facility).

Unique Identifier

• A unique battery identifier has been assigned in accordance with the standards referenced in Article 77 of Regulation (EU) 2023/1542.
• The identifier is encoded in a data carrier (QR code) affixed to the battery.
• The data carrier links to the battery passport and is scannable throughout the battery lifecycle.
• The unique identifier is registered or ready for registration in the forthcoming EU battery passport system.

Category B — Carbon Footprint Declaration

Annex XIII, Part B addresses the carbon footprint of the battery across its lifecycle. The Commission delegated act under Article 7 of Regulation (EU) 2023/1542 establishes the methodology. From the compliance date, the carbon footprint declaration is mandatory, followed by performance class labelling.

• The carbon footprint of the battery has been calculated in kg CO2 equivalent per kWh of total energy provided over the expected service life of the battery, following the methodology laid down in the delegated act adopted pursuant to Article 7(1).
• The carbon footprint value is broken down by lifecycle stage: raw material extraction, manufacturing, distribution, and end-of-life processing.
• The carbon footprint performance class has been determined and labelled in accordance with Article 7(2) and the corresponding delegated act.
• The share of the carbon footprint attributable to the manufacturing stage is separately identified and disclosed.
• A web-accessible link to the full carbon footprint study, including the methodology, data sources, and assumptions used, is included in the passport.
• The carbon footprint declaration has been verified by a notified body or through the conformity assessment procedure specified in the regulation.
• If thresholds are set via delegated acts under Article 7(3), the battery carbon footprint is confirmed to fall below the maximum lifecycle carbon footprint threshold.

Category C — Supply Chain Due Diligence

Annex XIII, Part C mandates transparency on supply chain governance. Article 48 of Regulation (EU) 2023/1542 requires economic operators to implement supply chain due diligence policies aligned with internationally recognised standards, specifically the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

• A supply chain due diligence policy is in place, published, and referenced in the battery passport.
• The due diligence policy covers all raw materials listed in Annex X of Regulation (EU) 2023/1542, including but not limited to cobalt, lithium, nickel, and natural graphite.
• A third-party audit of the due diligence policy and its implementation has been completed by a recognised conformity assessment body.
• The third-party audit report, or a summary thereof, is accessible through the battery passport.
• A responsible sourcing policy is documented and addresses risk identification, mitigation, and monitoring for each raw material supply chain.
• The due diligence covers social and environmental risks, including child labour, forced labour, environmental degradation, and conflict financing.
• Supplier-level traceability data has been collected for cobalt, lithium, nickel, and natural graphite, identifying at minimum the country of origin of each raw material.
• Grievance mechanisms are in place and referenced in the due diligence documentation.
• The due diligence report is updated annually, and the most recent version is linked in the battery passport.

Category D — Materials Composition and Hazardous Substances

Annex XIII, Part D requires a full accounting of the materials in the battery, including hazardous substances and recycled content. This connects directly to the circular economy objectives of the regulation and to the recycled content targets set out in Article 8.

Material Composition

• A detailed bill of materials for the battery is available, listing all component materials by weight percentage.
• The battery chemistry and the specific active materials used in the cathode, anode, and electrolyte are documented.
• Critical raw materials present in the battery are identified and quantified, in line with the EU Critical Raw Materials list.

Hazardous Substances

• All substances of very high concern (SVHCs) present in the battery above 0.1% weight by weight are declared, consistent with Article 33 of REACH Regulation (EC) No 1907/2006.
• Any hazardous substances present in the battery are identified by name, CAS number, and concentration.
• A declaration confirming compliance with the substance restrictions set out in Article 6 of Regulation (EU) 2023/1542 is included.

Recycled Content

• The percentage of recycled cobalt in the battery active material is calculated and documented, using the methodology established by the delegated act under Article 8.
• The percentage of recycled lead in the battery is calculated and documented.
• The percentage of recycled lithium in the battery active material is calculated and documented.
• The percentage of recycled nickel in the battery active material is calculated and documented.
• The recycled content data has been verified through third-party documentation or supplier declarations supported by auditable evidence.
• If the battery is placed on the market after 18 August 2031, the recycled content meets the minimum targets specified in Article 8(1): 16% cobalt, 85% lead, 6% lithium, 6% nickel. If placed after 18 August 2036, the higher targets apply: 26% cobalt, 85% lead, 12% lithium, 15% nickel.

Category E — Performance and Durability

Annex XIII, Part E covers the electrochemical performance characteristics of the battery. These fields allow downstream users, repair operators, and second-life operators to assess the battery’s condition and remaining useful life. Article 10 of Regulation (EU) 2023/1542 sets the foundation for these requirements.

Rated Performance

• Rated capacity (Ah) is declared at beginning of life under reference conditions.
• Nominal voltage (V) and minimum/maximum voltage are stated.
• Original power capability (W) is documented.
• Expected battery lifetime expressed in cycles under reference conditions is provided.
• Expected battery lifetime expressed in calendar years under reference conditions is provided.
• The reference test conditions used (temperature, charge/discharge rate, depth of discharge) are documented.

Energy and Efficiency

• Round-trip energy efficiency at 50% state of charge is measured and recorded.
• Internal resistance (ohms) is measured and recorded at beginning of life.
• The C-rate capability for both charge and discharge is specified.
• Self-discharge rate is documented.

State of Health Parameters (for in-use tracking)

• The battery management system (BMS) is configured to provide state of health (SoH) data.
• State of certified energy (remaining energy vs. rated energy) is accessible.
• Capacity fade data (or capacity throughput) is tracked and accessible through the passport.
• Power fade data is tracked.
• Internal resistance increase is monitored.
• The methodology for SoH determination is documented and aligned with the standards referenced in the regulation.

Temperature and Operating Conditions

• The temperature range within which the battery can safely operate is specified.
• If a temperature management system is integrated, its specifications are documented.

Category F — End of Life Information

Annex XIII, Part F ensures that the battery passport carries forward the information needed for safe handling, dismantling, and recycling. Articles 59 to 62 of Regulation (EU) 2023/1542 establish the collection, treatment, and recycling obligations that this data supports.

• Dismantling instructions for the battery are included or linked in the passport, covering the sequence of steps required to safely remove the battery from the product and disassemble it into recyclable components.
• Safety information for handling the battery at end of life is provided, including precautions for damaged, defective, or recalled batteries.
• Information on the collection and take-back scheme for the battery is included, identifying the responsible producer or producer responsibility organisation (PRO) and collection points.
• Recycling information is provided, including the recommended recycling process and any material-specific considerations for recovering cobalt, lithium, nickel, and other critical raw materials.
• Information on the potential for second-life use, including criteria for assessing suitability, is included where applicable.
• The role and responsibilities of the waste holder, collector, and recycler are outlined in the passport or linked documentation.

Data Collection Readiness

Populating the battery passport is not a one-time documentation exercise. It requires functioning data pipelines from suppliers, manufacturing systems, and quality assurance processes. Verify the following to assess your readiness to collect and maintain the required data.

• Supplier data collection processes are established for raw material composition, country of origin, recycled content declarations, and due diligence documentation.
• Data request templates have been sent to all tier 1 and tier 2 suppliers involved in cathode, anode, and electrolyte material supply.
• Internal manufacturing execution systems (MES) capture production data including date of manufacture, facility identifier, and batch-level traceability.
• Carbon footprint calculation tools or services are in place and aligned with the methodology established under the Article 7 delegated act.
• Battery management system (BMS) data feeds are configured to export state of health parameters in a format compatible with passport requirements.
• A Digital Product Passport platform such as Traceable is selected and configured to ingest, validate, store, and serve the required data fields in machine-readable format.
• Data quality procedures are documented, including validation rules, error handling, and audit trails.
• Data retention policies are in place to maintain passport data for the full lifecycle of the battery.

Compliance Verification

Before 18 February 2027, every economic operator placing in-scope batteries on the EU market should complete a thorough compliance verification. This is not optional preparation. It is the foundation of the conformity assessment required under Chapter VIII of Regulation (EU) 2023/1542.

• A gap analysis has been performed comparing current data availability against every field in Annex XIII.
• Each data field has been mapped to a specific internal or external data source, with a named owner responsible for accuracy and timeliness.
• Data quality has been tested by populating a sample battery passport with real production data and verifying completeness and accuracy.
• The data carrier (QR code) has been tested to confirm it resolves to the correct battery passport record.
• Access controls have been verified: public data is accessible without authentication, restricted data is limited to authorised parties (market surveillance authorities, notified bodies, second-life operators) as specified in Article 77.
• The conformity assessment procedure for the battery passport has been reviewed and the appropriate module (as referenced in Chapter VIII) has been identified.
• A notified body has been engaged (where required) to verify the battery passport and carbon footprint declaration.
• An internal audit schedule has been established to review passport data accuracy on a recurring basis.
• Legal and compliance teams have reviewed the penalty and enforcement provisions under national transpositions of the regulation to understand the consequences of non-compliance.

Timeline and Next Steps

The 18 February 2027 deadline applies to all industrial batteries above 2 kWh, EV batteries, and LMT batteries placed on the EU market from that date forward. Batteries manufactured before the deadline but placed on the market after it must still carry a compliant passport.

The practical lead time for data collection, supplier engagement, system integration, and testing means that manufacturers who have not begun preparation by mid-2025 face significant compliance risk. Annex XIII contains over 90 discrete data points when all sub-fields are counted. Each requires a verified source, a data pipeline, and a quality control process.

Platforms like Traceable are purpose-built to structure and automate this data collection, mapping each Annex XIII field to the correct data source and serving the passport through a compliant data carrier and access control layer. The earlier you begin populating real data, the more time you have to close gaps and resolve data quality issues before enforcement.

Do not wait for the delegated acts to be finalised on every sub-point. The core Annex XIII fields are already defined in the regulation text. Start there. Build the data infrastructure now. Refine as delegated acts provide additional specificity.

This checklist reflects the regulatory position as of March 2026.