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Public vs Restricted Passport Data: Who Sees What Under Annex XIII

Annex XIII splits battery passport data into tiers: a public layer anyone can read via the QR code, a legitimate-interest layer for verified parties, and layers reserved for national authorities and the Commission — all enforced server-side, never client-side.

Last updated 1 June 2026

Not all battery passport data is public. Annex XIII of Regulation (EU) 2023/1542 organises the information into access tiers so that anyone scanning the QR code sees the public layer, while more sensitive data is reserved for verified parties, national authorities and the Commission. The defining requirement is that this gating must be enforced on the server — the restricted data must never be sent to a public client and then hidden in the interface.

Access tierWho can read itExample dataHow accessed
PublicAnyone scanning the QR codeBattery type, manufacturer, basic specsOpen passport URL
Legitimate interestVerified parties with a legitimate interestDetail supporting repair and repurposingAuthenticated access
AuthoritiesNational market surveillance authoritiesCompliance and due-diligence detailAuthenticated access
CommissionThe European CommissionData reserved to the CommissionAuthenticated access
Access tiers must be enforced server-side. Sending restricted fields to the browser and hiding them with the interface is non-compliant — the public endpoint must only ever return public-tier data.

Why the public layer is deliberately small

The public layer is meant to let a customer, repairer or recycler identify and understand the battery, not to expose commercially sensitive or regulator-only information. The more detailed compliance, due-diligence and life-cycle data sits behind the higher tiers, released only to parties the regulation entitles to it.

  • Public: open via the QR code, identity and basic technical data.
  • Legitimate interest: released to verified parties for purposes such as repair and repurposing.
  • Authorities: available to national market surveillance authorities.
  • Commission: data reserved to the European Commission.

Frequently asked

Is all battery passport data public?

No. Annex XIII of Regulation (EU) 2023/1542 defines tiers: a public layer anyone can read via the QR code, plus restricted layers for parties with a legitimate interest, national authorities and the Commission.

Can I just hide restricted fields in the front-end?

No. Access tiers must be enforced server-side. The public endpoint must return only public-tier data; sending restricted data to the browser and hiding it in the interface does not satisfy Annex XIII.

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