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The Battery Passport: 71 data points and rules on differentiated access

On 18 February 2027 the battery passport becomes reality for electric-vehicle and industrial batteries. The European Commission’s DG GROW has released updated guidance detailing 71 specified data points alongside strict rules for differentiated, role-based access control.

27 September 2026

With under five months remaining before the first binding DPP deadline in the EU (18 February 2027), the technical details for the battery passport are falling into place. Regulation (EU) 2023/1542 imposes comprehensive requirements on batteries for electric vehicles (EV), light means of transport (LMT), and industrial batteries exceeding 2 kWh.

71 data points across the product lifecycle

DG GROW’s technical guidance categorizes the battery passport’s information into 71 unique data points across several key areas:

  • General product and manufacturer information: Model, serial number, manufacturing location, and date of manufacture.
  • Performance and durability: Rated capacity, voltage, power, expected lifetime, and initial internal resistance.
  • Carbon footprint: Lifecycle assessment, carbon footprint performance classes, and third-party verification reports.
  • Material composition and chemistry: Critical raw materials and recycled content percentages for cobalt, lithium, and nickel.
  • Supply chain due diligence: Environmental and social risk management documentation for raw material sourcing.

Differentiated access – not all data is public

A crucial clarification in the Commission’s draft delegated acts is the principle of differentiated (tiered) access. The battery passport is not an open webpage where all internal data is visible to anyone.

Access is structured into three tiers:

  1. Public access: Consumers and commercial buyers can view basic technical specifications, model details, and the certified carbon footprint.
  2. Restricted access (Legitimate Interest): Qualified professionals – such as certified dismantlers, recyclers, and second-life operators – gain authenticated access to cell-level chemistry, disassembly instructions, and safety parameters.
  3. Authority access: Market surveillance authorities and customs inspect compliance verification documents and conformity declarations.
This places strict technical demands on the manufacturer's software. You cannot satisfy the Batteries Regulation with a static PDF behind a QR code. Your platform must support role-based authentication and secure APIs.

How to prepare

Manufacturers and importers should immediately audit which of the 71 data points currently exist in ERP and PLM systems, and where new data-sharing agreements are required with tier-1 and tier-2 battery cell suppliers.

Read more in our battery guide or book a consultation with our team to see how Original Creation automates differentiated access for battery passports.