Annex XIII of EU Battery Regulation 2023/1542: Every Data Field Manufacturers Must Provide

What Annex XIII Is and Why It Matters

Annex XIII of EU Battery Regulation 2023/1542 is the definitive list of data points that must appear in every battery passport. It is not a general framework or a set of principles. It is a structured inventory of specific fields, organised into six parts. If a field is listed in Annex XIII, you must provide it. If your battery passport is missing any of these fields, it does not comply.

This article goes through each part in order, states exactly what data you must supply, and identifies the Article numbers and deadlines that apply to each section.

Part A: General Information

Part A covers the foundational identity data for the battery and the company placing it on the market. You must provide the following:

• Manufacturer identity: the legal name and registered address of the company that manufactured the battery
• Authorised representative in the EU: required when the manufacturer is based outside the European Union
• Battery model and type: the specific product designation
• Chemistry: the electrochemical system used (for example, lithium iron phosphate, nickel manganese cobalt)
• Nominal voltage: expressed in volts
• Capacity: expressed in ampere-hours
• Dimensions: physical measurements of the battery
• Weight: expressed in kilograms

These fields establish the basic product record. Without them, the battery cannot be identified or traced through the supply chain. Part A data must be present in the battery passport from the date the passport requirement enters into force for your battery category.

Part B: Carbon Footprint

Part B requires you to declare the lifecycle carbon footprint of the battery, expressed in kilograms of CO2 equivalent per kilowatt-hour of total energy delivered over the battery’s expected service life. This declaration is made under Article 7 of Regulation (EU) 2023/1542.

The methodology you use to calculate the carbon footprint must follow the delegated act adopted under Article 7(1). The Commission has the power to adopt this delegated act to specify the calculation rules, data sources, and system boundaries. Until that delegated act is in force, manufacturers should monitor the Commission’s published timeline, as the exact calculation methodology is not yet confirmed in the regulation text itself.

Article 7 sets out a phased approach. The first phase requires disclosure of the carbon footprint value and the declaration class. Later phases introduce mandatory performance thresholds. The specific dates for each phase depend on the battery category and the adoption of the relevant delegated acts. Confirm the applicable timeline for your product category directly against the regulation text and any Commission implementing measures published after the regulation entered into force on 17 August 2023.

Part C: Recycled Content

Part C requires you to state the percentage of recycled material used in the battery’s active materials, broken down by four specific substances: cobalt, lithium, nickel, and lead. These percentages are expressed as a share of the total active material content for each substance.

Under Article 8 of Regulation (EU) 2023/1542, the recycled content requirements apply in two stages.

Disclosure-only phase: From 18 August 2028, manufacturers of electric vehicle (EV) batteries, starting, lighting, and ignition (SLI) batteries, and specified industrial batteries must disclose their recycled content percentages in the battery passport. No minimum percentage is required at this stage. You must report the figure, whatever it is. Light means of transport (LMT) batteries enter the disclosure-only phase later, from 18 August 2033.

First mandatory minimums, from 18 August 2031:

• Cobalt: 16% recycled content
• Lithium: 6% recycled content
• Nickel: 6% recycled content
• Lead: 85% recycled content

Second mandatory minimums, from 18 August 2036:

• Cobalt: 26% recycled content
• Lithium: 12% recycled content
• Nickel: 15% recycled content
• Lead: 85% recycled content (unchanged)

LMT batteries become subject to mandatory minimums at the 2036 stage. From 2028 to 2031, your obligation is to report accurately. From 2031 onward, your reported figure must also meet the minimum threshold.

If you source materials from multiple suppliers with different recycled content levels, you must calculate and report a weighted average that reflects your actual production inputs. Inaccurate reporting is a compliance failure, not just a data quality issue.

Part D: Performance and Durability

Part D covers the technical performance characteristics of the battery over its operational life. You must provide:

• Rated capacity: the total charge the battery can deliver under specified conditions, expressed in ampere-hours
• State of health: a measure of the battery’s current condition relative to its original specification, expressed as a percentage
• State of charge: the current charge level relative to rated capacity, expressed as a percentage
• Expected cycle life under reference conditions: the number of full charge-discharge cycles the battery is designed to complete before its capacity falls below a defined threshold

State of health and state of charge are dynamic values. They change as the battery ages and is used. The battery passport must be capable of reflecting updated values, which is one reason the regulation requires the passport to be a digital record rather than a static document. The technical system supporting your battery passport must be able to receive and display updated performance data throughout the battery’s life.

Part E: Supply Chain Due Diligence

Part E requires documented evidence that you have met the supply chain due diligence obligations set out in Chapter VII of Regulation (EU) 2023/1542, specifically Articles 48 to 52. The obligations run in sequence, and each one generates evidence the passport must carry:

• Due diligence policy (Article 48): a written policy setting out your approach to identifying and managing social and environmental risks in your supply chain. It must be adopted by management and communicated to suppliers. Article 48 also fixes the scope: the obligations apply to economic operators whose net turnover exceeds EUR 40 million, including where that threshold is met at consolidated group level.
• Management system and traceability (Article 49): internal systems and a chain-of-custody mechanism that let you track the four raw materials through your supply chain, together with a grievance mechanism.
• Risk assessment and mitigation (Article 50): a documented assessment of supply chain risks for four specific raw materials: cobalt, natural graphite, lithium, and nickel. The assessment must identify countries and mines of origin where possible, and set out a strategy to mitigate the risks it finds.
• Independent third-party verification (Article 51): your due diligence policy must be verified by a notified body. This is an external check, not a self-declaration.
• Reporting and disclosure (Article 52): you must publish a report on your due diligence policy, covering the actions taken, the findings, and the steps taken in response.

If you are an assembler who purchases cells from a supplier, you are still responsible for obtaining and verifying the due diligence documentation from your supply chain and including it in the passport. The battery passport must contain evidence that these steps have been completed, not merely a declaration that they have been.

One date has moved, and it is worth confirming against the current text rather than older guidance. Regulation (EU) 2025/1561, adopted on 18 July 2025 and published in the Official Journal on 30 July 2025, amended Article 48(1) to replace the date 18 August 2025 with 18 August 2027. The due diligence obligations in Chapter VII therefore apply from 18 August 2027, not 2025. The same amendment moved the deadline for the Commission’s due diligence guidelines from 18 February 2025 to 26 July 2026. Economic operators whose net turnover falls below the EUR 40 million threshold in Article 48(2) sit outside these obligations entirely.

Part F: Hazardous Substances

Part F requires you to identify every substance of very high concern (SVHC) present in the battery above a concentration of 0.1% weight by weight.

Two separate provisions of REACH Regulation (EC) No 1907/2006 sit behind this. The criteria that make a substance an SVHC are set out in Article 57 of REACH: carcinogens, mutagens, substances toxic to reproduction, persistent bioaccumulative and toxic substances, and substances of equivalent concern. The 0.1% weight by weight threshold, and the duty to communicate SVHC content in an article down the supply chain, come from Article 33 of REACH. The European Chemicals Agency (ECHA) publishes and updates the Candidate List of SVHCs. You must check the current Candidate List against every substance present in your battery above the 0.1% threshold.

For each SVHC you identify, the battery passport must state:

• The name of the substance
• Its concentration in the battery (expressed as a percentage w/w)
• Its location within the battery, where this can be specified

This information is required so that waste operators and recyclers can handle end-of-life batteries safely and comply with their own obligations under waste legislation. It is also accessible to consumers and professional users under the REACH supply chain communication requirements.

You must update Part F if ECHA adds a new substance to the Candidate List and that substance is present in your battery above the threshold. A battery passport is not a one-time filing. It must remain accurate throughout the product’s life on the market.

How the Six Parts Work Together

Annex XIII is structured so that each part addresses a different audience and a different regulatory purpose. Part A serves market surveillance authorities. Part B serves climate policy. Part C serves circular economy targets. Part D serves end users and second-life operators. Part E serves import controls and responsible sourcing enforcement. Part F serves waste management and chemical safety.

All six parts must be present and accurate for the battery passport to be valid. A passport that contains Parts A through E but omits Part F is non-compliant. A passport that reports Part C figures that do not reflect actual recycled content is non-compliant. Each field carries its own legal obligation.

What You Need to Do Now

1. Map every Annex XIII field against your current product data. Identify which fields you can populate today and which require new data collection processes.
2. Work back from 18 February 2027. Article 77 of Regulation (EU) 2023/1542 sets that date directly in the regulation for EV batteries, LMT batteries, and industrial batteries above 2 kWh. It is not a date left to a future delegated act, and there is no transitional grace period.
3. Build or procure a digital system capable of storing, updating, and exposing battery passport data via a QR code or equivalent data carrier as required by Article 77.
4. Start your Article 50 risk assessment for cobalt, natural graphite, lithium, and nickel now. This process takes time and requires supplier engagement that cannot be completed quickly.
5. Check the ECHA Candidate List against every substance in your battery bill of materials. Set up a process to recheck whenever ECHA publishes an updated list.

If you want to see how Traceable maps Annex XIII data fields to a compliant battery passport, visit traceable.digital/pricing to start a free trial. The platform covers all six parts of Annex XIII and updates automatically as your product data changes.