Who sees what in the battery passport? Public, regulator and recycler access explained

From 18 February 2027, every EV battery, LMT battery and industrial battery above 2 kWh placed on the EU market must carry a QR code linking to its digital passport. Anyone can scan that code. Not everyone sees the same record. Regulation 2023/1542 sorts the 90+ data attributes of Annex XIII into access tiers: public sustainability facts, compliance evidence reserved for market surveillance authorities and the Commission, and dismantling and health data for "persons with a legitimate interest" such as recyclers and second-life operators. This article maps who sees what, why the split exists, and what it means for anyone building or buying a passport system.

Why does the passport restrict who sees what?

Because the passport asks manufacturers to publish, in structured and machine-readable form, information they have spent decades guarding. Detailed composition data describes the cathode, anode and electrolyte. Disassembly sequences describe how the pack is engineered, fastener by fastener. A fully public record would amount to reverse-engineering documentation shipped free with every unit sold, and no manufacturer would fill it in honestly.

The regulation resolves the tension by differentiating rather than diluting. Data that serves buyers and markets is public. Data that serves enforcement goes to authorities. Data that serves the circular economy goes to the operators who handle the battery after its first life. Each audience gets what its job requires, and nothing more.

The practical consequence is easy to miss: access control is not a feature bolted onto the passport later. It is written into Annex XIII itself. Every attribute in the annex comes with an audience attached, so the access model is part of the specification, exactly like the data model.

What can anyone see by scanning the QR code?

The public tier is the battery's sustainability face, the information a buyer, journalist or competitor can read without any credentials:

• Identity: manufacturer, battery category and model, place and date of manufacture, weight, chemistry.
• Carbon footprint: the declared product carbon footprint, mandatory for EV batteries since 18 February 2025, including the breakdown by lifecycle stage.
• Recycled content: the shares of recovered cobalt, lithium, nickel and lead in active materials. Public visibility here previews the binding minima that apply from 18 August 2031 (16% cobalt, 6% lithium, 6% nickel, 85% lead).
• Substances: hazardous substances present beyond mercury, cadmium and lead, and the critical raw materials contained.
• Performance and durability as designed: rated capacity, voltage, power capability, expected cycle life, applicable temperature range, warranty terms.
• Conformity and end of life: the EU declaration of conformity and the separate-collection and waste-prevention information owed to consumers.

The logic of this tier is comparability. When every battery on the EU market publishes the same attributes in the same structure, a fleet buyer can compare carbon footprints across suppliers and a green claim becomes checkable rather than rhetorical.

What do recyclers and second-life operators get to see?

The second tier belongs to persons with a legitimate interest, a group that expressly includes recyclers, repurposers and second-life operators. It contains the data the public tier deliberately withholds, in two blocks.

The first block is dismantling and safety information: detailed composition including cathode, anode and electrolyte materials, part numbers and sources for spare parts, exploded diagrams of cell and module layout, disassembly sequences, the types of fastenings used, the tools required, and the safety measures and warnings that go with them. This is precisely the information whose absence makes today's recycling intake dangerous and slow: packs arrive undocumented, get triaged by hand, and valuable units are shredded because verifying them costs more than the recovered material is worth.

The second block is the battery's life record: state of health and expected lifetime, with the parameters defined in Annex VII, plus negative events such as accidents and the operating conditions the pack has seen. Unlike most passport data, this block must be kept up to date through the battery's whole life. It is what lets a second-life operator tell a reusable pack from a write-off, which matters commercially: a verified high-fidelity health history is worth about 30% more on the secondary market.

The tier also carries hard targets downstream. Recyclers must reach 65% recycling efficiency by weight for lithium-based batteries by the end of 2025 and 70% by 2030, and recover 50% of lithium and 90% of cobalt, copper, lead and nickel by the end of 2027. Meeting those numbers on an undocumented pack is guesswork; meeting them with the dismantling tier open is process engineering.

What is reserved for authorities and the Commission?

The most restricted tier serves enforcement. Notified bodies, market surveillance authorities and the Commission get access to the results of test reports demonstrating that the battery meets the regulation's performance, durability and safety requirements. Authorities and the Commission can also reach the legitimate-interest data when an investigation requires it.

This tier is what turns the passport into an audit interface. Regulation 2023/1542 is directly applicable in all Member States with no national transposition, and enforcement runs through market surveillance: a battery whose passport is missing, wrong or inaccessible can be kept off the market. For the manufacturer, the restricted tier is also a protection. Test evidence and compliance detail flow to the authority that needs them without being exposed to competitors reading the public record.

One open item is worth tracking. The regulation left the fine print of access rights, including exactly who qualifies as a person with a legitimate interest and which attributes each group may read, to secondary legislation the Commission was due to adopt by 18 August 2026. Anyone specifying a passport system now should treat the tier boundaries as firm in principle and adjustable in detail.

How do you implement one record with three views?

The access model has direct consequences for system design, and they are stricter than they first appear:

• Access is per attribute, not per document. A PDF with sections is not a passport. Each of the 90+ attributes needs its own audience tag, enforced at the data layer.
• Roles must be verifiable. "Recycler" is a claim someone has to authenticate before the dismantling tier opens. Role-based access control against the EU taxonomy of readers is core infrastructure, not an admin screen.
• There is still only one record. Publishing separate copies per audience fails the moment data changes: state of health updates continuously, and forked records drift apart. The workable architecture is a single source of truth serving filtered views.
• Confidentiality needs proof, not trust. The recycled-content shares are public while the exact chemistry stays restricted, so the system must be able to substantiate a public claim without leaking the restricted data behind it.

Get this right and the access tiers stop being a compliance burden. The same mechanism that keeps the chemistry confidential is what lets a manufacturer share dismantling data with the recyclers who dismantle its packs, including direct competitors' service networks, without a bilateral NDA per relationship.

Conclusion: one record, three windows

The battery passport is not one disclosure but three, cut from a single record: sustainability facts for the market, compliance evidence for the authorities, and a working manual for the operators who give the battery its second life or recover its materials. The tiering is what makes honest data possible, because manufacturers will only feed a record that protects them while it informs everyone else.

Passoria's passport engine structures all Annex XIII attributes to the EU access taxonomy from day one, so public, authority and recycler views are filtered from one live record. To see the three views running on your own battery data, join our pilot program.