Welcome back to this week’s Battery Business Insights article on the EU battery passport. On 21 August 2026 the European Commission published an updated guidance document. It answers a question the industry has been asking for two years: what actually has to be in a battery passport on day one?
The answer is 71 data points. Ten of them you do not fill in at all in February 2027. And the three battery categories do not get the same passport, which is the part most coverage has missed.
Two weeks ago we argued that manufacturers face a fixed deadline governed by rules that had not arrived. This is the Commission filling in part of that gap. It is worth an hour of your time for two reasons. The job is smaller than you were told, and it is not the same job for every battery.
By the Numbers: What the Battery Passport Actually Requires
- 71 — data points in the Commission’s list, replacing the “80+” figure common in trade coverage
- 10 — fields nobody fills in for February 2027
- 2 — of those ten are duplicates, the same data written into two annexes
- 56 — fields an EV battery actually has to address
- 59 — fields an LMT battery actually has to address
- 5 vs 1 — state-of-health parameters for an LMT battery, against one for an EV battery
- 0 — fields those two sets share
- 18 February 2027 — the passport obligation starts, and this date carries no conditions
What the Commission Published
The document is called Digital Batteries Passport – data points by category. It is now at version 2.0, dated 15 August 2026, and it comes from DG GROW. It does something genuinely useful. It takes two overlapping annexes of the Batteries Regulation and turns them into a single numbered list of 71 data points. Next to each one sit three columns, for EV, LMT and industrial batteries. Each column says one of four things: mandatory, optional, only in certain cases, or not to be filled in.
That last option is the new part. It is the first time the Commission has put in writing which fields you can leave alone.
One thing to be clear about before you build anything on it. This is guidance, not law. The document says so twice — it is not the Commission’s official position, and it creates no new obligations. Everyone will work from it anyway, because there is nothing better to work from.
It will also change. The Commission says future versions may add units and reporting formats. Those are the things you need before one company’s number can be compared with another’s. Today, two manufacturers can both comply and still produce figures nobody can line up side by side.
The Ten Fields That Stay Empty
Ten of the 71 are not filled in by anyone in February. They fall away for three different reasons, and the reasons matter, because they come back at different times.
Two are duplicates. Point 16 asks for material composition, which points 12, 13 and 15 already collect. Point 25 asks for rated capacity, which point 11 already collects. This one is worth sitting with. Part of the compliance burden the industry has been budgeting for was never work at all. It was the same data written into two annexes, and it took the Commission’s own tidying exercise to notice.
Seven are obligations that have not started yet. Carbon footprint and its label wait on an implementing act. The four recycled-content shares wait on a delegated act. Neither act exists. The due-diligence report is a slightly different case: it is coming, but from August 2027, not February.
One is on hold for political reasons. Point 44, instructions for use, is parked pending the environmental omnibus — the simplification package tabled in December 2025, not the one already adopted that delayed due diligence. Worth knowing, but it is one field, not a stop-the-clock.
And one field here is easy to miss. Point 24, the share of renewable content, is mandatory for all three categories while the four recycled-content fields sitting right next to it fall away. Work down the list quickly and you will carry the momentum one row too far.
State of Health Is Not One Thing
This is the part that changes how you build.
For an EV battery, state of health is one number: State of Certified Energy. The five fields after it — remaining capacity, remaining power, round-trip efficiency, self-discharge and ohmic resistance — are all marked not to be filled in.
For an e-bike or e-scooter battery it is the exact reverse. Those five are mandatory, and State of Certified Energy is not to be filled in. The two sets do not share a single field. Industrial batteries sit in a third position again, marked “if applicable” across the whole block, with the judgement left to you.
So if you have built one state-of-health block and pointed all three categories at it, you have collected too much for EV and too little for LMT. The second one is what a conformity check finds.
The same pattern runs elsewhere in the list. The capacity threshold for exhaustion is EV-only. Several cycle-life and efficiency fields apply to industrial batteries just where lifetime can sensibly be measured in cycles.
Add it up and an EV battery faces 56 fields. An LMT battery faces 59. Nobody fills all 71, so any burden estimate quoting that number is describing a battery that does not exist.
What Did Not Get Easier
None of this makes the passport a lighter job. The fields that fell away were mostly ones nobody could have filled anyway. The two hardest did not move.
Point 45 is detailed composition — the materials in your cathode, anode and electrolyte. Point 48 is the dismantling manual: exploded diagrams, the disassembly sequence, fastenings, tools, damage warnings and cell layout. Both are mandatory for all three categories.
These are the same two fields the Lin’gang pilot with CATL, BMW and Catena-X could not move from China to Europe. That project is reported to have transferred around 80 per cent of the static requirements in a form that complied with China’s data law. Composition and the disassembly manual were in the portion that stayed behind. If you build packs from Chinese cells, you have a mandatory field with a supply route that has been publicly shown not to work.
There is a second problem stacked on top. Both fields sit in the tier reserved for people with a legitimate interest, and nobody has defined who those people are. The implementing act was due on 18 August. It has not arrived. So you are being asked to prepare data you cannot fully source, for readers nobody has named yet.
A Necessary Risk?
The access question is where the real argument is happening, and it is further along than most people realise. EUROBAT, the European automotive and industrial battery association, published its feedback on the draft act this month. It wants the framework to stay “proportionate, purpose-limited and protective of commercially sensitive information”, with access based on “a clear and verified need”.
Its paper also shows something not otherwise reported. The draft contains two competing options for who can reach the restricted fields, and EUROBAT backs the narrower one. Letting anyone who bought a battery see the full composition and dismantling data would, it argues, “create an overly broad access route”.
The reasoning is practical rather than defensive. Many recyclers handle batteries from several manufacturers. Give them broad access to composition data and one manufacturer’s process detail ends up in front of a competitor’s recycler. EUROBAT wants applicants to show documentary evidence that they actually repair, repurpose, remanufacture, treat or recycle the battery in question.
That is the second-life and recycling sector’s access being decided right now, six months before the rules apply. Which option wins is not settled.
Which ten are not populated in February
Applicability per battery category
State-of-health split between EV and LMT
Due-diligence report due August 2027
Who holds a legitimate interest (Art. 77(9))
Outcome of Omnibus VIII and data point 44
Carbon footprint and recycled-content acts
Whether a version 3 changes any of it
Bottom Line
The passport got smaller in August. It did not get easier. Ten fields drop out in February, and eight of those were obligations nobody could have met yet. Two were the Commission’s own duplication.
What is left still includes your full electrode chemistry and your dismantling manual. Mandatory everywhere, hard to source, and headed for readers the law has not named.
If you do one thing this quarter, open whatever data model you or your vendor have built and look at how it handles state of health. If there is one shared block covering all three categories, it is modelling a battery that does not exist.
Battery Business Insights is an independent industry publication. All specifications cited reflect company-reported data as of the publication date. Independent third-party verification of cell-level performance figures has not been confirmed at time of writing.
References: European Commission, Guidance to support preparations for the Digital Batteries Passport (21 August 2026); Guidance Document: Digital Batteries Passport — data points by category, version 2.0 (15 August 2026); Regulation (EU) 2023/1542 (Batteries Regulation); Regulation (EU) 2025/1561 (due-diligence postponement); EUROBAT feedback on the draft Implementing Act on Article 77(9) (11 August 2026); Catena-X, cross-border China–Europe automotive data ecosystem (22 July 2026).
