An earlier version of this post overstated the regulatory requirement for LMT battery passports. It presented Traceable’s own platform attribute coverage as though it were the mandatory minimum, and it described Annex XIII as being organised into lettered parts and numbered sections that do not exist in the Regulation. Both were wrong, and this rewrite corrects them rather than quietly adjusting the numbers.
On 28 July 2026 the European Commission published Digital Batteries Passport, data points by category (v1.0), which enumerates 71 data points across all battery categories and identifies 54 as mandatory for LMT batteries at 18 February 2027. This checklist has been rewritten against that document and against the text of Regulation (EU) 2023/1542 itself.
Update, 3 September 2026. The European Commission issued version 2.0 of that guidance on 15 August 2026. The four recovered content shares at Annex XIII point 1(e), for cobalt, lithium, nickel and lead, moved out of the set that must be filled at 18 February 2027 and into the set marked not to be filled or displayed at that date, pending the Article 8 methodology delegated act. The LMT count mandatory at 18 February 2027 is therefore 50 rather than the figure given above, the Point 1 subtotal is 30, and the list of entries not required at launch is twelve rather than eight. The counts, tables and citations in this checklist now reflect version 2.0.
If you are a compliance manager responsible for LMT (light means of transport) battery passports, covering e-bikes, e-scooters and e-cargo bikes, this is the list you actually have to fill.
How the 50 mandatory LMT data points map to Annex XIII
Annex XIII of Regulation (EU) 2023/1542 is organised as four numbered points. Each one is an access tier, not a subject grouping. This matters for implementation, because it determines who can see a given value, not just whether you have to collect it.
| Annex XIII point | Who can access it | Mandatory for LMT at 18 Feb 2027 |
|---|---|---|
| Point 1 | The public | 30 |
| Point 2 | Persons with a legitimate interest and the Commission | 5 |
| Point 3 | Notified bodies, market surveillance authorities and the Commission | 1 |
| Point 4 | Persons with a legitimate interest (individual battery data) | 14 |
A further 12 data points are listed in Annex XIII but are marked in the Commission guidance as not to be filled or displayed as of February 2027. Those are covered further down.
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Score Your ReadinessPoint 1: publicly accessible information relating to the battery model
Thirty of the 50 sit here. Point 1(a) does not list fields of its own. It incorporates Part A of Annex VI by reference, which is why thirteen of these data points cite Annex VI rather than Annex XIII.
From Annex VI Part A: manufacturer name and registered trade name or trade mark; manufacturer postal address with a single contact point; battery category; model identification and batch, serial or product number; place of manufacture; date of manufacture (month and year); weight; capacity; chemistry; hazardous substances present other than mercury, cadmium or lead; usable extinguishing agent; and critical raw materials present in a concentration of more than 0,1 % weight by weight.
From Annex XIII point 1 directly: the unique identifier and the identity of the party responsible for the passport (Article 77(3)); the recovered shares of cobalt, lithium, nickel and lead (point 1(e)); the share of renewable content (point 1(f)); minimal, nominal and maximum voltage (point 1(h)); original power capability and power limits (point 1(i)); expected lifetime in cycles and the reference test used (point 1(j)); the temperature range the battery withstands when not in use (point 1(l)); initial round trip energy efficiency and efficiency at 50 % of cycle life (point 1(n)); internal cell and pack resistance (point 1(o)); the c-rate of the relevant cycle life test (point 1(p)); the marking requirements in Article 13(4) (point 1(q)); the EU declaration of conformity under Article 18 (point 1(r)); and the waste battery information in Article 74(1)(a) to (f) (point 1(s)).
One point worth flagging: the capacity threshold for exhaustion at point 1(k) reads “only for electric vehicle batteries” in the Regulation itself. It is not an LMT obligation.
Point 2: information for persons with a legitimate interest and the Commission
Five data points, all relating to the battery model rather than an individual unit: detailed composition including the materials used in the cathode, anode and electrolyte; part numbers for components; contact details of sources for replacement spares; dismantling information (which the Regulation itself expands into exploded diagrams, disassembly sequences, fastening techniques, tools required, damage warnings, and cell count and layout); and safety measures.
Point 3: test reports for notified bodies and market surveillance authorities
A single data point, and the narrowest access tier in the Annex: the results of test reports proving compliance with the Regulation or with any delegated or implementing act adopted under it.
Point 4: data relating to an individual battery
Fourteen data points, and the ones most likely to require a live data feed rather than a document. Point 4 covers performance and durability parameters under Article 10(1) (rated capacity, capacity fade, power, power fade, internal resistance, internal resistance increase, expected lifetime in cycles and in calendar years), state of health under Article 14, and the battery status of original, repurposed, re-used, remanufactured or waste.
State of health is where LMT and EV diverge most sharply, and it is the single most common modelling error we see. For LMT batteries, five state of health data points are mandatory at February 2027: remaining capacity, and where possible the remaining power capability, remaining round trip efficiency, evolution of self-discharging rates and ohmic resistance. For EV batteries the pattern is close to inverted. If you build one state of health schema and apply it across categories, you will under-collect for LMT.
The twelve LMT data points deferred past February 2027
The Commission guidance marks these as not to be filled or displayed as of February 2027. They remain in Annex XIII, so treat them as obligations with an unresolved start date rather than obligations that have gone away.
- Material composition of the battery (point 1(b))
- The carbon footprint declaration (point 1(c))
- The carbon footprint label (point 1(c))
- Information on responsible sourcing from the due diligence report under Article 52(3) (point 1(d))
- Rated capacity in Ah at model level (point 1(g))
- Capacity threshold for exhaustion (point 1(k), electric vehicle batteries only)
- Instructions for use in a printable and downloadable format (point 1(t)), which the guidance attributes to Omnibus IV
- State of certified energy (point 4(b))
- Recovered content share of cobalt (point 1(e)), which the guidance attributes to the Article 8 recycled content methodology delegated act
- Recovered content share of lithium (point 1(e)), same basis
- Recovered content share of nickel (point 1(e)), same basis
- Recovered content share of lead (point 1(e)), same basis
The two carbon footprint entries are deferred for a reason independent of the guidance. Article 7 makes every carbon footprint date conditional, applying from the stated calendar date or a set period after the methodology delegated act and the format implementing act enter into force, whichever is latest. That delegated act has not been adopted, so the obligation has not commenced. See our deferred data points reference for the full position by battery category.
What is most often missing at first assessment
- Recovered content shares for cobalt, lithium, nickel and lead. Listed at point 1(e). Under Commission guidance v2.0 these are not to be filled or displayed as of 18 February 2027, and apply in line with the Article 8 methodology delegated act, which has not yet been adopted. Suppliers do not routinely provide the underlying figures, so build the collection route now rather than when that act enters into force.
- State of health telemetry. Five of the point 4 data points are mandatory for LMT and cannot be filled from a datasheet. They need a battery management system feed or a defined measurement process.
- Round trip energy efficiency at 50 % of cycle life. Point 1(n) requires a value partway through cycle life, which means the test has to have been designed to capture it.
- Detailed cathode, anode and electrolyte composition. Point 2(a). Cell manufacturers treat this as proprietary, so it usually needs a commercial data sharing agreement rather than a technical fix.
- Dismantling information at the level the Regulation specifies. Point 2(c) is explicit about exploded diagrams, disassembly sequences, fastening techniques, tools, warnings and cell layout. A generic service manual does not satisfy it.
How Traceable handles LMT battery passports
Our LMT template carries all 50 data points that are mandatory at 18 February 2027, plus the eight that Annex XIII lists and the guidance defers. Deferred fields exist in the data model and are marked as not required for publication, so you can populate them early if your supply chain data allows and leave them empty without the passport being treated as incomplete.
You can filter the full enumeration by battery category in our battery passport data point directory, or see how Traceable handles LMT battery passports.
Sources
- Regulation (EU) 2023/1542, in particular Article 7, Article 10, Article 14, Article 77, Annex VI Part A and Annex XIII. This is the binding legal source.
- 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 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”.
