If you’ve been asked to comply with Regulation (EU) 2023/1542 and you’re wondering what does a battery passport look like in practice, this article gives you a concrete answer. Not a summary of the regulation — a field-by-field walkthrough of what data must appear, who can see it, and how the record works. This covers industrial batteries above 2 kWh, electric vehicle (EV) batteries, and light means of transport (LMT) batteries, which are the three categories the regulation targets.
The Physical Entry Point: QR Code on the Battery
Under Article 77 of Regulation (EU) 2023/1542, every battery in scope must carry a QR code or other data carrier directly on the product. Scanning that code takes the user to the battery passport — a live digital record held in a system connected to the EU’s central Battery Passport Registry.
The QR code is not a link to a PDF. It is not a certificate you print once and file. The regulation requires the passport to be a live, updatable record. If the battery changes hands, gets repurposed, or reaches end of life, the relevant data fields must reflect that. The record follows the physical battery through its entire lifecycle.
The data carrier must be durable enough to survive the battery’s operational life. Article 77(3) specifies that the data carrier must be placed on the battery itself, not only on packaging or documentation.
What Does a Battery Passport Look Like: The Mandatory Data Categories
Annex XIII of the regulation sets out the mandatory data categories. Here is what each one contains and what it means for your operations.
1. General Battery Information
This section identifies the battery as a physical object and as a regulated product. It includes:
- A unique battery identifier — a unique string that links the physical battery to its digital record
- The battery model identifier
- The manufacturer’s name, registered trade name, and contact address
- The date and place of manufacture
- The battery category (industrial, EV, or LMT)
- Battery mass in kilograms
- Battery chemistry — for example, lithium iron phosphate (LFP) or nickel manganese cobalt (NMC)
This data is public. Any person scanning the QR code can read it.
2. Carbon Footprint Data
Article 7 of the regulation requires a carbon footprint declaration for EV batteries from February 2025, and for industrial batteries above 2 kWh from a date to be confirmed by delegated act — expected around 2027, pending Commission adoption. The battery passport must carry this declaration as a data field, not as a separate document.
The carbon footprint field includes:
- Total carbon footprint of the battery, expressed in kg CO₂ equivalent per kWh of total energy provided over the battery’s expected lifetime
- Carbon footprint broken down by lifecycle stage: raw material extraction, manufacturing, transport, and end of life
- The carbon footprint performance class, once the Commission establishes the class thresholds by delegated act
- A reference to the study or calculation methodology used
This data is public. It is one of the fields any consumer or business partner can read by scanning the QR code.
3. Battery Composition and Material Information
Annex XIII requires disclosure of the materials that make up the battery. This is one of the most detailed sections in a battery passport example from a real manufacturer.
The composition fields include:
- Active cathode and anode materials, identified by chemical name and CAS number
- Hazardous substances present in the battery, with concentration levels
- Substances of concern, as defined under the regulation
- Recycled content for cobalt, lithium, nickel, and lead — expressed as a percentage of the total content of each material in the battery
Article 8 sets minimum recycled content targets that apply from 2030 and 2035. The passport must show the actual recycled content figure so that authorities and recyclers can verify compliance against those thresholds.
Some composition data is public. Recycled content percentages and the presence of hazardous substances are accessible to any user. Detailed material specifications may be restricted to economic operators and authorities with a legitimate interest, depending on how the Commission defines access tiers in the delegated acts still under development.
4. Supply Chain Due Diligence Information
Article 52 requires manufacturers to carry out supply chain due diligence for cobalt, natural graphite, lithium, and nickel. The battery passport must contain a summary of that due diligence, including:
- The due diligence policy the manufacturer applies
- The risk management measures in place for the supply chain
- A summary of third-party verification, including the name of the auditor and the audit scope
This is not a field where you can write “we comply with OECD guidelines” and stop. The passport must link to or contain verifiable evidence. Authorities and notified bodies can access the full due diligence report. The public-facing version shows a summary and the verification status.
5. Performance and Durability Data
This section covers how the battery performs over its life. Annex XIII requires:
- Original capacity in ampere-hours (Ah)
- Minimum and expected battery lifetime, expressed in cycles and in calendar years
- Capacity fade — the reduction in capacity relative to the original capacity, at defined points in the battery’s life
- Power fade
- Internal resistance and its increase over time
- Temperature range the battery is designed to operate within
For EV batteries, Article 10 sets specific minimum values for capacity retention that must be met at the point of sale. The passport records the actual measured values, not just the design targets.
This data is public for the headline figures (original capacity, expected lifetime). Detailed state-of-health data at a given point in time may be restricted to economic operators and repairers, as the regulation allows differentiated access by user type.
6. State of Health and Remaining Useful Life (for Second-Life Batteries)
When a battery is repurposed — for example, moved from an EV to stationary energy storage — the passport must be updated to reflect its current state of health. This is where the live, updatable nature of the record becomes operationally significant.
The updated fields include:
- Current state of health (SoH), expressed as a percentage of original capacity
- Number of full charge-discharge cycles completed
- The date of the most recent SoH assessment
- The entity that carried out the assessment
Recyclers and second-life operators need access to this data to assess whether a battery is suitable for reuse. Article 77(5) confirms that access to specific data fields can be restricted to persons with a legitimate interest, which includes recyclers, repair operators, and competent authorities.
7. End-of-Life and Recycling Information
The battery passport must include information to support safe handling and recycling at end of life. This includes:
- Disassembly instructions and safety precautions
- The location of all hazardous materials within the battery
- Information on collection and take-back schemes available in the member state where the battery is placed on the market
- Waste prevention and management information
This section is primarily aimed at professional recyclers and waste management operators. It is restricted to those with a legitimate interest under Article 77(5), not publicly visible to all consumers.
Who Can See What: The Access Tier Structure
One of the most misunderstood aspects of the battery passport is that it is not a single public document. The regulation creates differentiated access levels.
Public access (any person scanning the QR code) includes: battery identification, carbon footprint declaration, recycled content percentages, performance headline figures, and collection scheme information.
Restricted access (economic operators, notified bodies, market surveillance authorities, and recyclers with a legitimate interest) includes: detailed material composition, full due diligence reports, state-of-health data, and disassembly instructions.
The Commission will define the exact access rules in delegated acts. As of mid-2025, those delegated acts are still under development. The regulation sets the framework; the detailed access matrix is expected to be confirmed before the passport requirements enter into force for each battery category.
When Do These Requirements Apply?
The battery passport requirement under Article 77 applies from 18 February 2027 for industrial batteries above 2 kWh and LMT batteries. For EV batteries, the date is also 18 February 2027. These dates are set in the regulation itself. However, some data fields — particularly those tied to recycled content thresholds and carbon footprint performance classes — depend on delegated acts that have not yet been adopted. Those specific field requirements will apply from dates to be confirmed after the delegated acts are published.
If you want to see how this works in a live system before the deadline, Traceable runs a battery passport pilot program that lets manufacturers test data ingestion, QR code generation, and access tier configuration against real product data.
What This Means for Your Data Infrastructure
A battery passport is only as accurate as the data feeding it. The fields described above come from multiple sources: your manufacturing execution system, your supply chain, third-party auditors, and in-field measurement systems. None of that data arrives in one place automatically.
For a detailed digital product passport walkthrough of how this works end to end, see a practical walkthrough of how a European battery manufacturer uses Traceable, which covers data collection, passport generation, and ongoing updates across the battery lifecycle.
The key operational point is this: the passport is not a one-time compliance task. It is a live record that must be maintained, updated, and kept accurate for the battery’s entire life. That requires a system, not a spreadsheet.
To start building your battery passport infrastructure now, visit traceable.digital/pricing to begin a free trial. Traceable supports all mandatory Annex XIII data categories and connects directly to the EU Battery Passport Registry format. You can have a working passport for a test battery within days.
