# What Goes in a Battery Passport When the Manufacturer Hasn't Published the Data?

Source: https://activatedigital.ai/knowledge/digital-product-passport/batteries/fields-no-maker-publishes-yet
Last verified: 7 November 2026
Summary: **Short answer:** Four public rows of the EU battery passport are blank on every real battery we have checked: the carbon footprint, the recycled content shares, the renewable content share and any statement of who stands behind the data. Three of the four are not legally due yet, so a blank is the lawful state as long as the passport says why. One, renewable content, is due on 18 February 2027 with no definition behind it. An estimate can sit beside a blank, clearly marked as ours, but it can never sit in the manufacturer's row. This page is the start of that journey; the four guides below take each field in turn.

- Carbon footprint and recycled content rows are marked **not to be filled or displayed as of February 2027** in the Commission guidance of 19 October 2026.
- Renewable content is due on **18 February 2027** with the passport and has no definition behind it.
- An estimate can sit beside a blank, labelled as ours. It can never sit in the manufacturer's row.

## Why are these four rows empty on real batteries?

We looked at the public documents behind 27 industrial and home storage batteries from makers including BYD, Pylontech, Victron, Huawei, Sungrow and TQ. Not one published a carbon footprint declaration, a recycled content share or a renewable content share in the form the Regulation asks for. That is not negligence. It is the state of the law.

Regulation (EU) 2023/1542 makes the passport mandatory from 18 February 2027 under [Article 77](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng), but the sustainability rows inside it hang off other articles with their own clocks. The carbon footprint declaration under Article 7 and the recycled content documentation under Article 8 each wait for a Commission act that has not been adopted. The Commission's own data point guidance, version 3.2 of 19 October 2026, marks the carbon footprint rows and the four recycled content rows "Not to be filled/displayed as of February 2027" ([Commission guidance, data points by category](https://single-market-economy.ec.europa.eu/document/download/cd1e5e6c-4a4a-4b99-995a-49eb6916187e_en?filename=Digital%20Batteries%20Passport%20-%20data%20point%20by%20category.pdf)). Its FAQ says the same in plain words: "Carbon footprint, recycled content and due diligence information will not yet be required" ([Commission FAQ on the battery passport](https://single-market-economy.ec.europa.eu/single-market/digital-product-passport/eu-digital-product-passport-faq-batteries_en)).

Renewable content is the odd one out. Annex XIII point 1(f) lists "the share of renewable content" among the public data. The guidance marks it mandatory for every category. Nothing in the Regulation or any act says what counts as renewable or how to work it out.

The fourth row is one we added. Nothing in the Regulation is called a "passport statement", but Article 77(4) puts the accuracy of the whole passport on the economic operator placing the battery on the market. A reader deserves to know which rows that operator has actually declared.

## The four fields at a glance

Status words follow the legend we use on [the EU product rules action radar](https://activatedigital.ai/knowledge/regulation/what-applies-today). Sources checked on 6 November 2026.

| Field | Legal state today | When it is due | Can it be estimated? | What a passport should show now | Guide |
|---|---|---|---|---|---|
| Carbon footprint, total and per life cycle stage | **FUTURE DUTY, DELEGATED MEASURE PENDING** | Later of the fixed date (industrial 18 Feb 2026, EV 18 Feb 2025, LMT 18 Aug 2028) or 18 months (12 for EV) after both the method act and the format act take effect. Neither is adopted | Yes, as a separate ActivateDigital estimate with a range. Never in the declared row | "Not yet required. Not declared by manufacturer", plus the estimate block if one exists | [Can you estimate a battery's carbon footprint?](https://activatedigital.ai/knowledge/digital-product-passport/batteries/carbon-footprint) |
| Recycled content: cobalt, lithium, nickel, lead | **FUTURE DUTY, DELEGATED MEASURE PENDING** | Later of 18 Aug 2028 or 24 months after the Article 8 act takes effect. Draft published 12 Aug 2026, not adopted. LMT from 18 Aug 2033 | No. The draft act defines it as a documented mass balance at the maker's plant. Chemistry can say which metals are absent | "Not yet required. Not declared by manufacturer", with "not present in active material" where the chemistry rules a metal out | [Is recycled content required in 2027?](https://activatedigital.ai/knowledge/digital-product-passport/batteries/recycled-content) |
| Renewable content share | **ADOPTED - APPLIES LATER** | 18 Feb 2027, with the passport itself | Partly. No definition exists. A bill of materials assessment can be stated as ours | "Not declared by manufacturer", or a labelled assessment where we hold the bill of materials | [What is renewable content?](https://activatedigital.ai/knowledge/digital-product-passport/batteries/renewable-content) |
| Who declared what | **NOT ESTABLISHED** as a field | With the passport, as our own practice | Not applicable. It is a statement, not a value | A provenance block: declared by the operator, estimated by us or not stated, per row | [Who is responsible for passport data?](https://activatedigital.ai/knowledge/digital-product-passport/batteries/passport-data-responsibility) |

## The journey through the four guides

Read them in this order if you own a battery passport. Or jump to the one that matches the row you are looking at.

- **Carbon footprint.** The only field with a calculation. Learn why the passport unit is per kilowatt hour of lifetime energy, not per kilowatt hour of capacity, why that turns a 74 kg figure into 0.02 and how an indicative estimate can be built from chemistry, capacity, factory country and warranty without pretending to be a declaration.
- **Recycled content.** The field that cannot be estimated. The share is a chain of custody figure per model, per year, per plant. What chemistry does tell you. What a maker has to send to turn a blank into a declared share.
- **Renewable content.** The field that is due first and defined least. What the Regulation says (one example about lignin), what the guidance says (mandatory) and how to avoid writing 0 % into a row the maker never answered.
- **Who is responsible.** The field we invented so the other three can be honest. How a passport row carries one of three states. Why an estimate must never look like the maker's number.

## Three rules that hold across all four

**A blank with a reason is compliant. A blank with no reason looks like a failure.** The Commission expects these rows to be empty in February 2027. The passport should say so in words, with the article and the date that will change it.

**An estimate is ours, not theirs.** Annex II point 5 says company specific data must be used for the main production stage of the carbon footprint and "no default activity data shall be used". A number built from public averages can never satisfy that, so it lives in its own block, with its method, inputs, date and range, under a heading that says it is an ActivateDigital estimate. The manufacturer's row stays "Not declared".

**A market average is not a battery's value.** Secondary cobalt is around 5 % of global supply and recycled lithium under 1 % of battery production. Those are facts about the market. The passport row asks for this model from this plant in this year. Context can sit in a note. It cannot sit in the row.

## What this means for a business placing batteries on the EU market

If you import or brand batteries, you are usually the economic operator under Article 77(4), so the passport is yours to get right even when the cell maker is on the other side of the world. The practical sequence is short. Confirm the battery category, because the dates differ for industrial, EV and light means of transport batteries. Check the chemistry, because it settles which recycled content metals apply at all. Ask the maker for the four things listed in each guide. Record the answer, including "we have not calculated this yet", which is itself a fact worth holding. Then let the passport say which rows are declared, which are estimated and which are not stated.

Our [71 data points guide](https://activatedigital.ai/knowledge/digital-product-passport/batteries/71-data-points) shows where these rows sit in the Commission's numbering (rows 17, 18 and 20 to 24). [Where battery passport data comes from](https://activatedigital.ai/knowledge/digital-product-passport/batteries/data-origins) covers the evidence behind every other row.

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## What would change this page

- Adoption and publication of the delegated act on the carbon footprint method for electric vehicle batteries (draft of April 2024) or for industrial batteries (no draft yet). Adoption of the implementing act on the declaration format.
- Adoption of the delegated act on recycled content calculation and verification (draft of 12 August 2026, feedback closed 9 September 2026).
- A Commission definition or method for renewable content. A revised edition of the data points guidance.
- A manufacturer publishing a carbon footprint declaration, a recycled content share or a renewable content share for a battery we hold a passport for.

## Frequently asked questions

### Is an empty carbon footprint row a compliance failure in February 2027?

No. The Commission guidance marks the carbon footprint declaration and label "Not to be filled/displayed as of February 2027" because the format is still to be set by an implementing act. The Article 7 dates run from the later of a fixed date and a lag after that act. The row should say it is not yet required rather than sit silently blank.

### Can we put an estimated carbon footprint on the passport?

Only as a separate, labelled estimate. The declared value under Article 7 must come from a study that uses the maker's own production data, with a public link to that study. A benchmark figure can be shown as an ActivateDigital estimate with its method and range, never as the manufacturer's declaration.

### Why can't recycled content be estimated the way carbon can?

Because the draft delegated act defines the share as a plant level mass balance "based exclusively on documentation". There is no physical test and no public average that describes a specific model from a specific plant. The only honest states are declared or not declared.

### Renewable content is mandatory from February 2027. What do we write?

"Not declared by manufacturer" unless the maker has declared a share or you hold a bill of materials that lets you state one as your own assessment. Writing 0 % because the maker said nothing is the error to avoid.

### Who is responsible for these rows being right?

The economic operator placing the battery on the market, under Article 77(4). It can authorise someone else to publish the passport, but the Commission FAQ is clear that this does not transfer the legal responsibility.

No code? [Request access](https://activatedigital.ai/about#contact)

## Get a free passport check

Bring one battery model and the documents you already hold. We'll show which of these four rows can be declared, which can only be estimated and what to ask the maker for. [Request a free passport check](https://activatedigital.ai/about#contact).

## Keep exploring

The questions this page usually raises next.

- [CompareNext questionCan You Estimate a Battery's Carbon Footprint for the EU Battery Passport?The passport carbon footprint is per kWh of lifetime energy, not capacity. No maker has declared one.→](https://activatedigital.ai/knowledge/digital-product-passport/batteries/carbon-footprint)
- [CompareNext questionIs Recycled Content Required on a Battery Passport in 2027?Recycled cobalt, lithium, nickel and lead shares are not due before August 2028 and cannot be estimated.→](https://activatedigital.ai/knowledge/digital-product-passport/batteries/recycled-content)
- [CompareNext questionWhat Is Renewable Content in a Battery Passport and What Do You Show?Renewable content is due on the battery passport from 18 February 2027 with no definition behind it.→](https://activatedigital.ai/knowledge/digital-product-passport/batteries/renewable-content)
- [CompareNext questionWho Is Responsible for the Data in a Battery Passport and How Do You Show Where It Came From?Article 77(4) puts passport accuracy on the operator placing the battery on the market.→](https://activatedigital.ai/knowledge/digital-product-passport/batteries/passport-data-responsibility)

## Primary sources

- [Article 77](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng) EU law
- [Commission guidance, data points by category](https://single-market-economy.ec.europa.eu/document/download/cd1e5e6c-4a4a-4b99-995a-49eb6916187e_en?filename=Digital%20Batteries%20Passport%20-%20data%20point%20by%20category.pdf)
- [Commission FAQ on the battery passport](https://single-market-economy.ec.europa.eu/single-market/digital-product-passport/eu-digital-product-passport-faq-batteries_en)