Inside the battery passport: the 90+ mandatory data attributes explained

From 18 February 2027, every EV battery, LMT battery and industrial battery above 2 kWh placed on the EU market must carry a digital product passport, reachable through a QR code and tied to a unique identifier. Annex XIII of Regulation 2023/1542 defines what goes inside: more than 90 mandatory data attributes, some fixed per battery model, some recorded per individual unit and kept up to date through its life. Very few of these attributes are exotic. The compliance problem is not inventing data; it is that the data is scattered across an ERP, an MES, a LIMS, a BMS and a folder of supplier spreadsheets, and some of it belongs to companies three tiers upstream.

What are the seven data categories in Annex XIII?

The 90+ attributes cluster into seven groups. Reading the annex as a list of categories, rather than a wall of line items, makes the collection work much easier to plan:

• Identity and traceability: manufacturer identity and address, battery category, model, the unique identifier behind the QR code, manufacturing date and place, weight, and the battery's status (original, repurposed, remanufactured or waste).
• Chemistry and composition: the battery chemistry, critical raw materials present above 0.1% weight by weight, hazardous substances beyond mercury, cadmium and lead, and the materials used in cathode, anode and electrolyte.
• Recycled content: the share of cobalt, lithium, nickel and lead in active materials that was recovered from waste, per model, per plant, per year. From 18 August 2031 these shares become binding minima: 16% cobalt, 85% lead, 6% lithium, 6% nickel.
• Carbon footprint: total lifecycle emissions in kg CO2e per kWh, the split per lifecycle stage, the carbon footprint performance class, and a link to the public study. The carbon-footprint declaration has been mandatory for EV batteries since 18 February 2025.
• Performance and durability: rated capacity, power capability, round-trip efficiency, internal resistance, expected lifetime in cycles, and expected capacity fade over time.
• State of health and usage: the dynamic record. Annex VII defines the parameters, including remaining capacity, remaining round-trip efficiency, evolution of internal resistance, and negative events such as accidents.
• Dismantling and safety: disassembly sequences, fastener types and required tools, the location and part numbers of components, safety measures, and suitable extinguishing agents.

One battery, seven categories, and, as the next sections show, at least five different source systems.

Which attributes are per unit, and which must stay live?

Most of the annex is model-level and static: chemistry, rated performance, dismantling instructions and the carbon footprint are declared once per model (or per model and plant) and change only with an engineering revision. A second layer is unit-level but written once, such as the manufacturing date, place and serialised identifier of each pack.

The third layer is what makes the passport more than a datasheet. State-of-health and usage data are per unit and must be kept up to date throughout the battery's life, which implies a standing data pipeline from the field back into the passport, not an annual reporting exercise. Access is tiered accordingly: part of the record is public to anyone who scans the QR code, part is reserved for persons with a legitimate interest such as recyclers and second-life operators, and part is for market-surveillance authorities and the Commission. The tiering matters commercially, because it lets a manufacturer publish compliance data without publishing its cell recipe.

Where does this data live in your organisation today?

Almost every Annex XIII attribute already exists inside a battery maker's operations. It just was never designed to leave its silo. A typical mapping looks like this:

• ERP: master data and logistics. Model references, weights, plant addresses, supplier records, purchased-material certificates. Identity attributes mostly start here.
• PLM and engineering files: bills of materials, component part numbers, fastener specifications, disassembly geometry. This is the raw material for the dismantling and safety category.
• MES: the shop floor. Serial numbers, manufacturing date and line, batch genealogy linking a finished pack to its cell lots. The per-unit identity layer lives here.
• LIMS and test benches: laboratory chemistry results, hazardous-substance screening, and the type-test data behind rated capacity, resistance and cycle life.
• BMS and telematics: the only source that can feed the dynamic layer. Capacity fade, cycle counts, temperature extremes and fault events accumulate here, usually in a proprietary format.
• Supplier spreadsheets and PDFs: recycled-content attestations, upstream emission factors, raw-material provenance. The least structured source, and unfortunately the one several mandatory fields depend on.

No single system owns the passport. Treating the passport schema as a new target data model, with a named source and a named owner for every attribute, is the first concrete step of any compliance project.

Which fields are hardest to collect?

The internal fields are an extraction problem: tedious, but solvable with connectors and a mapping table. The hard fields are the ones your own systems cannot produce because the truth sits in the supply chain:

• Recycled-content shares require an unbroken chain of custody from the recycler through the precursor and cathode makers to your cell line. A percentage without documented lineage will not survive verification, and from 2031 that percentage carries legal minima.
• The upstream carbon footprint is dominated by materials and cell production. Moving from generic database values to supplier-specific data changes the result materially, and each supplier data point needs collection, plausibility checks and an audit trail.
• Provenance of critical raw materials feeds both composition reporting and the due-diligence obligations for cobalt, lithium, nickel and natural graphite, now expected in 2027 after the postponement from August 2025.

These fields share two traits: lead times measured in months of supplier negotiation, and a confidentiality tension, since suppliers must substantiate claims without disclosing recipes to their customers' customers. That is why supply-chain fields should be started first, even though they sit last in most project plans.

How do you close the gaps before 18 February 2027?

The deadline applies to batteries placed on the market from that date, so packs shipping in early 2027 are built, and their data assembled, during 2026. A workable sequence: map all 90+ attributes to source systems and owners; open the supplier data requests immediately, since they have the longest lead time; automate the static extractions from ERP, PLM, MES and LIMS; and stand up the BMS feed for the dynamic layer last, but design for it from day one. Importers should note that for non-EU manufacturers, the obligation lands on them at the moment of import, with exactly the same annex behind it.

Conclusion: an integration project, not a form

Annex XIII looks like a form with 90+ boxes. It behaves like a data model for the battery's entire life, spanning six internal systems and several tiers of suppliers. Manufacturers who treat it as an integration project in 2026 will fill it routinely; those who treat it as paperwork in late 2026 will discover that supplier data does not arrive on demand.

Passoria's passport engine structures every Annex XIII field to the EU taxonomy, with a BMS-to-passport bridge for the live state-of-health layer and a recycled-content chain of custody for the supplier-dependent fields. Manufacturers, resellers and recyclers can join our pilot program ahead of the 2027 deadline.