What Are the 71 Battery Passport Data Points, and Which Are Actually Required?

The EU Battery Passport guidance lists 71 data points, but they are not 71 universal mandatory fields. See what comes from law, what is conditional and what to map.

Last verified: 1 September 2026

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Direct answer
What is a Battery Passport?
Where does the number 71 come from?
Is the 71-point document legally binding?
Are all 71 data points mandatory for every covered battery?
A structured explanation of the 71 points
A particularly important 2026 example: data point 44
Model-level information versus individual-battery informatio
Public versus restricted information
What should businesses map now?
Common misreadings of the 71-point list
How this differs from a universal DPP field list
High-value questions
Sources and legal basis

Direct answer

The European Commission's 71 Battery Passport data points are an implementation map, not 71 new standalone legal obligations.

The binding requirements come from the EU Batteries Regulation and the legal provisions it incorporates by reference. The Commission's August 2026 guidance takes those requirements, breaks them into 71 practical rows and shows how each row applies to electric-vehicle batteries, light means of transport batteries and industrial batteries above 2 kWh.

That distinction matters. The guidance itself says that some rows are mandatory, some are optional where information is available, some apply only in particular circumstances and some do not need to be filled or displayed as of February 2027. It also says that it does not extend the rights or obligations created by legislation or introduce additional requirements.¹²

So the safe way to use the number 71 is:

71 is the Commission's current structured view of Battery Passport data points. It is not a universal 71-field checklist that every covered battery must populate in the same way on 18 February 2027.

For a business building its data model, the practical job is therefore not simply to create 71 empty boxes. It is to map each relevant information territory to its legal source, battery category, applicability rule, access class, lifecycle level, owner and effective date.

What is a Battery Passport?

Regulation (EU) 2023/1542 creates the Battery Passport for specified battery categories. From 18 February 2027, each:

light means of transport (LMT) battery
industrial battery with a capacity greater than 2 kWh
electric-vehicle (EV) battery

placed on the EU market or put into service must have an electronic battery passport.³

The passport is not just a model specification sheet. Article 77 says it contains both:

information relating to the battery model, and
information specific to the individual battery, including information resulting from its use.³

That is one reason a flat 71-field spreadsheet can be misleading. Some information belongs to a model and may remain relatively stable. Other information belongs to the specific battery and can change during its life.

The passport is accessed through a QR code linked to a unique identifier for the battery. The identifier is not automatically synonymous with a GTIN, and the QR code is the data carrier, not the passport itself.³

Where does the number 71 come from?

The number comes from the European Commission's Guidance Document: Digital Batteries Passport – data points by category, version 2.0 dated 15 August 2026. The Commission announced the updated guidance on 21 August 2026.¹²

The document turns the legal information requirements into 71 numbered implementation rows. For each row it records:

the data point name
the legal source cited by the guidance
the position for EV batteries
the position for LMT batteries
the position for industrial batteries above 2 kWh.

The applicability labels are deliberately not all the same. The document uses positions including:

mandatory
optional, where the information is available
if applicable or equivalent category-specific wording
not to be filled/displayed as of February 2027.¹

This is useful operationally because the Batteries Regulation is not written as a software schema. Requirements are distributed across Article 77, Annex XIII, Annex VI and other provisions incorporated into Annex XIII by reference. The guidance reorganises that legal architecture into something a product-data or compliance team can work with.

But organisation is not the same thing as legislation.

Is the 71-point document legally binding?

No.

The Commission describes the document as guidance intended to help economic operators and other stakeholders prepare for implementation. It says the document should be read with Regulation (EU) 2023/1542 and relevant delegated or implementing acts. It also says that the guidance does not introduce additional legal requirements, is not an authoritative interpretation of the legislation and should not be treated as representing an official Commission position.¹²

That gives the guidance an important but limited role:

Question	Safe answer
Does the guidance help identify and organise Battery Passport data?	Yes.
Does it show the Commission's current implementation view by battery category?	Yes.
Is every one of its 71 rows a newly created legal obligation?	No.
Can it replace reading the Batteries Regulation and later implementing/delegated acts?	No.
Can the document change as implementation develops?	Yes. The Commission expressly says it may be developed further.

This is why the phrase "71 required Battery Passport fields" is too blunt unless the speaker also explains the battery category, date, underlying legal trigger and access/lifecycle context.

Are all 71 data points mandatory for every covered battery?

No.

There are at least five different reasons why a row in the 71-point structure may not translate into a universally populated value.

1. Battery category

The legal rules differ between EV, LMT and industrial batteries. A clear example is the capacity threshold for exhaustion, which Annex XIII identifies for EV batteries. The Commission guidance therefore marks that point as mandatory for EV batteries but not to be filled/displayed for LMT and industrial batteries.¹³

Industrial batteries also contain several technical parameters that the guidance treats as applicable only for some industrial batteries, depending on whether the parameter is relevant to that battery.

2. A legal condition has to be true

Some requirements apply only if a factual or legal condition exists. A commercial-warranty field, for example, is relevant where a commercial warranty is envisaged. The cadmium or lead marking requirement applies where that marking is legally applicable.¹

Conditional does not mean optional. If the trigger applies, the obligation may apply. If it does not, the value should not be fabricated merely to make a checklist look complete.

3. The underlying obligation starts later or depends on another act

The guidance marks several sustainability-related rows as not needing to be filled/displayed in February 2027 because the underlying legal timing or implementing framework is not yet at that point.

Examples include:

carbon-footprint declaration and label rows, whose reporting format still depends on implementing measures
responsible-sourcing information, with the relevant battery due-diligence obligations applying from 18 August 2027 following Regulation (EU) 2025/1561
recycled-content rows, to be applied in line with Article 8 and the relevant delegated act.¹⁵

These are not simply "optional fields". They are legal territories whose population depends on the applicable legal timetable and supporting acts.

4. The row may organise or de-duplicate information

The Commission guidance marks its material-composition row 16 and rated-capacity row 25 as not to be filled/displayed because the same information is already captured through earlier rows in its structure.¹

This is an important clue about what the 71 number actually is. A count of guidance rows is not the same thing as a count of independent facts.

5. Some information is dynamic individual-battery information

The later part of the guidance covers performance, state-of-health, status and use-history information for the individual battery. These values are not simply static product-master data entered once at model creation.¹³

A structured explanation of the 71 points

The most useful way to understand the 71 points is by function, legal level and access, rather than by treating all rows as identical.

The ranges below are an original implementation classification. They summarise the Commission's 71-row organisation without reproducing its table.

Guidance range	What it mainly covers	Legal / operational character	What to do with it
1–16	Identity, responsible party, manufacturer details, battery category, model/serial identification, manufacturing plant, manufacture date, weight, capacity, chemistry, substances, extinguishing agent, critical raw materials and composition	Mostly public model information. Several items come from Annex VI Part A. Row 5 is available-if-present; row 16 is treated by the guidance as a duplicate grouping	Map core identity and model facts. Preserve conditions and provenance. Do not interpret the row count as independent obligations
17–24	Carbon footprint, responsible sourcing, recycled content and renewable content	Public model sustainability/circularity territory, but several points have staged or dependent application	Build data ownership and evidence pathways now. Activate publication when the underlying legal trigger and format apply
25–44	Capacity, voltage, power, expected life, warranty, efficiency, resistance, markings, declaration of conformity, waste information and the guidance's instructions-for-use row	Mainly public model technical/compliance information, with category-specific and conditional treatment. Row 25 is a duplicate in the guidance. Row 44 is not currently an adopted Annex XIII requirement; see below	Map adopted requirements and conditions. Treat the instructions row as a tracked legislative development, not current adopted law
45–49	Detailed composition, component/spare information, dismantling information and safety measures	Restricted model information associated with Annex XIII point 2	Store as governed data with access metadata. Do not publish by default
50	Results of compliance test reports	Restricted conformity evidence under Annex XIII point 3	Keep separate from the public record and govern authority/notified-body access
51–71	Dynamic performance, state of health, battery status, cycles, negative events, operating conditions and state of charge	Individual-battery and lifecycle information under Annex XIII point 4, with category/applicability differences	Design for serialised identity, updates over time, provenance and permission-aware access

This classification reveals three very different layers inside the headline number:

stable or slowly changing model information
conditional and staged regulatory information
dynamic information about the individual battery through its life.

A useful Battery Passport architecture needs to preserve those differences.

A particularly important 2026 example: data point 44

The Commission's version 2.0 guidance includes a row numbered 44 for electronic instructions for use and cites "Annex XIII 1(t)". It marks the point as not to be filled/displayed as of February 2027 because the application provisions are on hold pending Omnibus adoption.¹

That row needs careful legal treatment.

As verified on 1 September 2026, the current consolidated text of Regulation (EU) 2023/1542 contains Annex XIII point 1(a) to 1(s). It does not yet contain point 1(t).³⁴

The source of the proposed change is the Commission's Omnibus IV digitalisation proposal, COM(2025) 504. The Commission's current simplification tracker describes the regulation proposal as provisionally agreed by the co-legislators, not adopted legislation.⁶⁷

So for publication and system design on 1 September 2026:

Treat guidance data point 44 as a tracked implementation/legislative-development row, not as an already adopted Annex XIII obligation.

This does not make the Commission guidance wrong. The guidance itself flags the dependency. It demonstrates why the 71-row document must be used as an implementation aid alongside the current legal text, rather than converted into a green-tick list of adopted law.

Model-level information versus individual-battery information

Article 77 is explicit that a Battery Passport combines model information and information specific to the individual battery.³

Model-level information

Annex XIII points 1, 2 and 3 are principally model-oriented. They cover territories such as:

manufacturer and battery identification
manufacturing location
composition and chemistry
technical performance characteristics
sustainability information where the underlying rule applies
dismantling, spare-part and safety information
conformity test results.³

The same model-level fact may therefore be relevant to many individual passports for batteries of that model, although the technical implementation still has to meet the passport and identifier requirements.

Individual-battery and lifecycle information

Annex XIII point 4 is different. It covers data relating to the individual battery, including:

performance and durability values
state-of-health information
battery status, such as original, repurposed, re-used, remanufactured or waste
charging/discharging cycles where applicable
negative events such as accidents where applicable
recorded operating conditions where applicable
state of charge where applicable.¹³

These are not merely extra columns on a product catalogue. They imply an updateable lifecycle record attached to the individual battery.

The Regulation also requires a new battery passport when a battery is prepared for re-use, repurposed or remanufactured, with the new passport linked to the original passport or passports.³

Public versus restricted information

The 71 data points also cross different access classes. Not all Battery Passport information is public.

In broad terms:

Annex XIII point 1 contains public model information
point 2 contains restricted model information such as detailed composition, spare-part and dismantling information
point 3 contains compliance test-report results for the specified regulatory actors
point 4 contains individual-battery performance, health, status and use information associated with legitimate-interest access.³

The detailed rules for legitimate-interest access are still implementation-dependent as of 1 September 2026. Article 77(9) required the Commission to adopt an implementing act by 18 August 2026 specifying who qualifies, what they can access and the extent to which information can be downloaded, shared, published or reused. The Commission's current DPP roadmap instead places that act in Q4 2026.³⁸

For the full Battery-specific access analysis, see Which Battery Passport Data Is Public, Restricted or Limited to Legitimate-Interest Users?.

What should businesses map now?

The safest preparation approach is rules-first, not checklist-first.

Definitely map now

For covered batteries, create governed data objects for adopted information territories that are relevant to your products. At minimum this means knowing where core data come from, who owns them and what evidence supports them.

Typical examples include:

unique battery identity and responsible economic operator
manufacturer identity and contact data
battery category and model/serial or equivalent identifying information
manufacturing-plant location and manufacturing date
weight, capacity and chemistry
relevant hazardous-substance and critical-raw-material information
technical performance values that apply to the battery category
declarations, markings and waste information required by the Regulation
restricted composition, dismantling, spare-source and safety information
compliance test evidence
the individual-battery lifecycle values that apply.¹³

This does not mean publish every one of those facts to everyone. Data collection and data access are separate design questions.

Map conditionally

Your schema should be able to express the reason a field applies or does not apply. Useful states include:

applicable to this battery category
not applicable to this category
applies if a technical parameter is relevant
applies if a commercial warranty exists
applies if the relevant substance marking is triggered
applies from a later legal date
awaiting a delegated or implementing act
dynamic value to be updated during use.

Do not collapse these into a single blank/null state. A blank value cannot tell you whether evidence is missing, the legal trigger has not started or the field genuinely does not apply.

Map access separately

Attach an access class to the information object rather than building a second uncontrolled copy of the same data for each audience.

At minimum distinguish:

public
notified-body / market-surveillance / Commission access where established
legitimate-interest controlled access
internal supporting evidence that is not itself a passport field.

Track implementation dependencies

The current 71-point guidance is useful partly because it identifies rows that should not be treated as February 2027 population requirements. Track those dependencies as controlled regulatory states rather than deleting the data territories from your model.

Keep provenance

For each material fact, retain:

source system
source document or evidence
responsible owner
battery model or individual unit to which it applies
effective date
last update
legal basis or requirement mapping
access class.

A Battery Passport is a regulated information system, not just a front-end page.

For the wider preparation question, see What Product Data Should Businesses Prepare Now for DPPs?.

Common misreadings of the 71-point list

"There are 71 mandatory fields from February 2027"

No. The Commission's own guidance uses different applicability states and identifies several rows that do not need to be filled/displayed at that date.¹

"If a field is conditional, it is optional"

No. A conditional requirement applies when its legal or factual trigger is satisfied. That is different from a genuinely optional value.

"If a row is not displayed in February 2027, the legal topic has disappeared"

No. Some rows sit in legal territories whose application is staged or depends on further measures. Track the legal dependency instead of treating the subject as permanently irrelevant.¹⁵

"All 71 points are public"

No. The Regulation creates different access classes. Public model information is only one part of the architecture.³

"All 71 points are product-master data"

No. A substantial part of Annex XIII point 4 concerns the individual battery and data resulting from use.³

"The guidance can change the Regulation"

No. The guidance is an implementation aid. It cannot itself extend legal rights or obligations. The current treatment of instructions for use is a good example of why the adopted text and guidance need to be read together.¹⁴⁶

How this differs from a universal DPP field list

The Battery Passport is the most detailed adopted EU DPP regime currently approaching application, but it is not a universal template for every Digital Product Passport.

Different product laws can set different:

information requirements
granularity
access rights
identifiers and carrier arrangements
dates and implementation dependencies.

So the Battery Regulation can tell a battery business what it must prepare for batteries. It cannot safely be used to claim that every future textile, toy, detergent, construction or other DPP must contain the same 71 data points.

For the cross-category position, see Digital Product Passport Requirements by Product Category.

For identifiers and carriers, see Digital Product Passport Identifiers: UPI, GTIN, QR Codes and GS1 Digital Link.

High-value questions

Are all 71 Battery Passport data points mandatory?

No. The 71-row Commission guidance includes mandatory, optional, conditional and not-to-be-filled/displayed positions, with differences between EV, LMT and industrial batteries. The binding requirement comes from the applicable law, not from the number 71 itself.¹²

Is the 71-point list legally binding?

No. It is Commission implementation guidance. The document expressly says that it does not create additional requirements and is not an authoritative interpretation of the legislation.¹²

Does every battery need a Battery Passport?

No. Article 77 covers LMT batteries, industrial batteries with capacity greater than 2 kWh and EV batteries placed on the market or put into service from 18 February 2027.³

Are Battery Passport data points model-level or item-level?

Both concepts are present. The passport includes model information and information specific to the individual battery, including data resulting from use.³

Which Battery Passport fields are public?

Annex XIII point 1 is the public model-information territory. Other information sits behind authority/notified-body or legitimate-interest access classes. The detailed legitimate-interest implementation act remains pending as of 1 September 2026.³⁸

When must Battery Passport information be available?

The passport obligation starts on 18 February 2027 for covered batteries, but that does not mean every legal information territory is populated on that date. Underlying obligations and implementation acts can have their own timing.¹³

What should companies prepare before February 2027?

Build a governed mapping between the applicable legal information, source systems, evidence, model or individual-battery level, lifecycle update rules and access permissions. Track staged and implementation-dependent fields explicitly rather than forcing them into a universal checklist.

Keep exploring

The questions this page usually raises next.

Does this reach your products?

Give ActivateDigital one product and it works out which obligations apply from the product's own character, and says which it cannot decide.

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Help someone else make sense of product passports.