# What Is Renewable Content in a Battery Passport and What Do You Show?

Source: https://activatedigital.ai/knowledge/digital-product-passport/batteries/renewable-content
Last verified: 7 November 2026
Summary: **Short answer:** Renewable content is the one sustainability row of the EU battery passport that is due on 18 February 2027 with the passport itself. Annex XIII point 1(f) of Regulation (EU) 2023/1542 lists "the share of renewable content" among the public data. The Commission's guidance marks it mandatory for every battery category. Nothing defines it. There is no article, no method, no delegated act and one example in a recital about lignin replacing graphite. The row should read "Not declared by manufacturer" unless the maker has declared a share or you hold the bill of materials and state an assessment as your own. Writing 0 % because the maker said nothing is the mistake to avoid.

- Renewable content is listed in Annex XIII point 1(f) and is due with the passport on **18 February 2027**.
- The Commission guidance marks data point 24 mandatory for every category and gives no definition.
- A zero is a declaration. Without a maker declaration or a documented assessment the row reads not declared.

## What the Regulation says, all of it

Annex XIII point 1, the publicly accessible information about the battery model, includes at (f) "the share of renewable content" ([Regulation (EU) 2023/1542, Annex XIII](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng)). That is the only operative mention. The one other place the idea appears is recital 118, which says the passport should show "whether renewable material, such as material produced from lignin to substitute graphite, is used".

So the row applies to every battery that needs a passport: industrial batteries over 2 kWh including home and commercial storage, electric vehicle batteries and light means of transport batteries, from 18 February 2027 under Article 77(1). It is provided by the economic operator placing the battery on the market, like every other row.

## What the guidance says

The Commission's data points guidance, version 3.2 of 19 October 2026, lists it as data point 24, "The share of renewable content [%]", with "As defined in: N/A", access "Public" and "Mandatory" for electric vehicle, light means of transport and industrial batteries ([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)). "N/A" under "as defined in" is the Commission saying there is no definition. The battery passport FAQ does not mention renewable content at all.

The industry guidance is no fuller. DIN DKE SPEC 99100, the German specification for passport data attributes, carries the row as a public percentage at model level and adds: "If the proportion of renewable content is greater than zero, specifications about which material is involved and its content shall be determined", with the example "Tree-based lignin can replace graphite in the anode as renewable material in batteries" ([DIN DKE SPEC 99100:2025-02](https://www.dinmedia.de/en/technical-rule/din-dke-spec-99100/385692321)). The Battery Pass consortium's earlier content guidance said plainly that "The larger scope of the data attribute is unspecified" and that "it should be specified whether all materials or only active materials are to be reported on" ([Battery Pass Content Guidance](https://thebatterypass.eu/assets/images/content-guidance/pdf/2023_Battery_Passport_Content_Guidance.pdf)). Neither resolves the denominator.

## Why 0 % is the wrong default

A mainstream lithium ion cell uses mined or synthetic graphite, PVDF or SBR binders, polyolefin separators and aluminium, steel or plastic casings. None of that is renewable in the recital's sense, so the temptation is to write 0 %. The problem is that 0 % is a declaration. It says the operator has checked the bill of materials and found nothing bio-based. If nobody has checked, the passport is asserting something nobody knows. Some cells do use a cellulose derived binder. A maker could reasonably count it.

The distinction the passport needs is between three states. The maker has declared a share, including a declared zero, in which case the row carries it. Nobody has declared and we hold no bill of materials, in which case the row reads "Not declared by manufacturer". Or we hold the bill of materials and have checked it, in which case the row can read "0 % (ActivateDigital assessment from the bill of materials, dated; no Commission definition published)", or a share with the material named if we found one.

## What counts as renewable, as far as anyone can tell

Pending a definition, the only safe reading is material content made from renewable biological sources, matching the recital: lignin derived hard carbon replacing graphite, cellulose based binders such as carboxymethyl cellulose, bio-based polymers in separators or casings, bio-based electrolyte solvents. Renewable electricity used in manufacturing is not content and does not belong in this row; it belongs in the carbon footprint, if anywhere. Recycled content is a different row with its own article. It is not renewable.

| Material in a typical cell | Renewable? | Note |
|---|---|---|
| Graphite anode, mined or synthetic | No | Lignin derived hard carbon would be the renewable alternative named in recital 118 |
| PVDF, SBR binders | No | Carboxymethyl cellulose is cellulose derived and a maker could count it |
| Polyethylene or polypropylene separator | No | Bio-based polymer separators exist but are rare |
| Aluminium, copper, steel | No | Metals are not renewable; recycled share is a different question |
| Plastic casing or module housing | Usually no | Bio-based polymer housings would count if used |

## What the passport should show today

Default: "Not declared by manufacturer. Due 18 February 2027 (Annex XIII 1(f)); no Commission definition or method published." Where the maker has declared a share, including zero, the row carries it with the material named if above zero. Where we hold the bill of materials, the row can carry our assessment, labelled as ours and dated. A share is never inferred from chemistry, from recycled content or from a green electricity claim.

## What a maker has to send

A bill of materials or material declaration for the model that lists any bio-based material, its mass and its share. It should say which denominator was used, all materials or active materials only, since the Regulation does not say. A declared zero is welcome: it is the maker's declaration and it closes the row.

Read [the four passport fields no maker publishes yet](https://activatedigital.ai/knowledge/digital-product-passport/batteries/fields-no-maker-publishes-yet) for the other three rows and the rule that keeps them honest. The [71 data points guide](https://activatedigital.ai/knowledge/digital-product-passport/batteries/71-data-points) for where data point 24 sits in the Commission's numbering.

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## What would change this page

- A Commission definition of renewable content, a calculation method or a revised edition of the data points guidance that sets a denominator.
- A harmonised standard or a revision of DIN DKE SPEC 99100 that fixes the scope.
- A manufacturer declaring a renewable content share for a battery model we hold a passport for.

## Frequently asked questions

### Is renewable content mandatory on the battery passport from February 2027?

Yes. It is listed in Annex XIII point 1(f) and the Commission guidance marks data point 24 mandatory for every category. It is the only one of the sustainability rows that is not deferred.

### What is the definition of renewable content for batteries?

There is none. The guidance says "As defined in: N/A". The only pointer in the Regulation is recital 118's example of material produced from lignin replacing graphite.

### Can we write 0 % if the maker hasn't said anything?

No. A zero is a declaration that the bill of materials was checked. Without a maker declaration or your own documented assessment, the row should say "Not declared by manufacturer".

### Does renewable electricity in the factory count?

No. The row is about material content. Electricity used in manufacturing belongs to the carbon footprint calculation.

### Is recycled content the same as renewable content?

No. Recycled content is material recovered from waste, under Article 8, with its own dates and method. Renewable content is material from renewable biological sources. The two rows are separate and both can be zero.

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## Get a free passport check

Bring one battery model and any material declaration you hold. We'll show what the renewable content row should say for it today and what would let it carry a share. [Request a free passport check](https://activatedigital.ai/about#contact).

## Keep exploring

The questions this page usually raises next.

- [CompareNext questionWhat Goes in a Battery Passport When the Manufacturer Hasn't Published the Data?Carbon footprint, recycled content, renewable content and who declared what are blank on every real battery passport.→](https://activatedigital.ai/knowledge/digital-product-passport/batteries/fields-no-maker-publishes-yet)
- [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 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

- [Regulation (EU) 2023/1542, Annex XIII](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)
- [DIN DKE SPEC 99100:2025-02](https://www.dinmedia.de/en/technical-rule/din-dke-spec-99100/385692321)
- [Battery Pass Content Guidance](https://thebatterypass.eu/assets/images/content-guidance/pdf/2023_Battery_Passport_Content_Guidance.pdf)