EU Battery Passport Data Requirements: What to Collect and How to Work with Suppliers

A practical guide to Annex XIII data requirements, supplier collaboration, individual battery records and ongoing passport updates. Last reviewed: 27 October 2026.

What Data Is Required for an EU Battery Passport?

An EU Battery Passport must contain applicable information about the battery model and the individual battery, including relevant information arising during its use. Under Regulation (EU) 2023/1542, Annex XIII defines the information requirements, while the European Commission’s August 2026 guidance organises 71 data points by battery category and applicability.

However, identifying the required data fields is only the beginning.

For manufacturers and importers, the more difficult questions often come next:

• Where does the required information currently exist?
• Which information must come from suppliers or subcontractors?
• What can be reused across a battery model?
• What must be recorded for each individual battery?
• When does information need to be updated?

A Battery Passport is not simply a collection of technical specifications. It requires a reliable process for collecting, validating, sharing and maintaining product information.

Battery Passport Data Requirements: At a Glance

From 18 February 2027, the Battery Passport requirement applies to electric vehicle (EV) batteries, light means of transport (LMT) batteries and industrial batteries with a capacity greater than 2 kWh when placed on the EU market or put into service.

Are All 71 Battery Passport Data Points Mandatory in February 2027?

The Commission’s “Digital Batteries Passport – Data Points by Category”, updated on 15 August 2026, organises the information relevant to EV, LMT and qualifying industrial batteries.

For each battery category, the guidance indicates whether a data point is:

• Mandatory: Required for the relevant battery category and application date.
• Conditional: Required when specified conditions apply.
• Optional: Not legally mandatory in the indicated circumstances.
• Not required at the initial date: Not required to be completed or displayed as of February 2027.

The distinction matters because a field relevant to one battery category may have a different status for another.

Requirements associated with carbon footprint information, recycled content and responsible sourcing also need to be assessed against their own applicable provisions and implementation dates.

Which document should companies follow?

There are three important levels of information.

1. Binding legal requirements. Regulation (EU) 2023/1542, including Annex XIII and relevant delegated or implementing acts, establishes the legal obligations.
2. European Commission guidance. The Commission’s 71-point document helps businesses understand the requirements by battery category. It supports preparation but does not create additional legal obligations or constitute an authoritative interpretation of the legislation.
3. Internal implementation checklists. A company’s data inventory or a software provider’s field catalogue helps organise implementation. These tools are operational aids. They should not be presented as substitutes for the law.

Where Does Battery Passport Data Come From?

Battery Passport data is rarely stored in one place.

A manufacturer may already maintain battery model specifications in an ERP or product lifecycle management system. Production records may be stored elsewhere, while laboratory results, material information and supplier declarations may exist in separate documents.

Some information may not be held by the responsible economic operator at all.

This is where Battery Passport preparation becomes a data-management exercise.

Battery Passport Data Source Map

The following table illustrates how a company could map its information sources and responsibilities.

This is a suggested operational mapping framework, not an official list assigning legal responsibility to specific departments.

Each required field should also have an evidence source, validation status and designated data owner.

Without these elements, a company may have the required information somewhere in its organisation but still struggle to make it reliably available.

What Battery Passport Data Must Be Collected from Suppliers?

The responsible economic operator may need information originating from battery cell manufacturers, raw material suppliers, subcontractors, laboratories or other third parties.

However, providing information to a Battery Passport does not automatically make the supplier legally responsible for the finished battery’s passport.

Under Article 77, responsibility for ensuring the passport information is accurate, complete and up to date rests with the relevant economic operator placing the battery on the EU market.

Suppliers can nevertheless be essential contributors to the information-management process.

Why supplier data collection becomes difficult

In Collecta’s conversations with companies preparing for Battery Passport requirements, one recurring challenge is identifying how to request information that businesses have not previously needed to collect systematically.

A company may have worked with the same cell supplier for years without requiring every piece of documentation in the structure needed for a digital passport.

A subcontractor may hold test results that were previously exchanged only during production.

A raw material supplier may possess relevant composition or sourcing information but have no established process for sharing it with downstream manufacturers.

The problem is not always that the information is unavailable.

How to organise supplier data requests

A practical process can begin with five questions.

1. What information do we need? Identify the applicable fields before requesting documents. Avoid asking suppliers to provide an undefined collection of compliance information.
2. Who is the appropriate data provider? Map each information requirement to the supplier, laboratory or internal system that holds the relevant evidence.
3. What evidence should accompany the information? Determine whether a value requires a test report, technical specification, calculation or other supporting document.
4. Who validates the response? Receiving supplier information does not necessarily establish its accuracy. Assign an internal reviewer and define how incomplete or inconsistent submissions are handled.
5. How will changes be communicated? Agree on a process for relevant changes to supplied information, including the contact responsible for notifications and the product records potentially affected.

This approach turns supplier collaboration into a defined workflow rather than a series of disconnected emails.

An example: An LMT battery manufacturer

Consider a hypothetical company producing 10,000 e-bike battery packs annually.

Its engineering team maintains battery specifications. Its production system records manufacturing information. Cell suppliers provide technical documentation, while certain test results are held by external partners.

To prepare for Battery Passports, the company needs to connect these sources.

It may not need to request the same model-level information from a supplier separately for every physical battery.

But it does need to determine which information applies to the model, which information identifies each individual battery, and whether later changes affect existing records.

The key question becomes:

Model-Level vs Individual Battery Data: What’s the Difference?

Under Article 77(2), the Battery Passport contains both information relating to the battery model and information specific to the individual battery, including data resulting from its use.

Understanding this distinction is essential for companies manufacturing multiple units of the same model.

Model-level data

Model information describes characteristics shared by relevant batteries of the same model.

Depending on the applicable requirements, examples include:

• Battery chemistry and relevant material composition.
• Technical characteristics and specifications.
• Rated capacity and voltage information.
• Applicable performance documentation.
• Relevant safety and dismantling information.

Where the same validated information applies to multiple batteries, a company can manage it as shared model data rather than manually recreating the source information for every unit.

Individual battery data

Individual-level information identifies and describes a particular physical battery.

It may include:

• Its unique identifier.
• Applicable individual production or performance values.
• Its lifecycle status.
• Relevant state-of-health information.
• Applicable information arising during use.

The Battery Passport is required for each individual battery in the covered categories.

Why this matters operationally

Imagine a company manufacturing 10,000 batteries of the same model.

The model specifications may be common across the production run.

But each battery needs its own identity, and some information will relate specifically to that individual unit.

A practical data architecture can connect individual records to validated model information while maintaining battery-specific values separately.

This avoids unnecessary duplication without confusing model-level information with individual-battery obligations.

How Often Must Battery Passport Data Be Updated?

The applicable obligation depends on the information concerned and the battery’s circumstances.

The European Commission’s battery-specific FAQ explains that dynamic information must, at a minimum, be updated when a change in the battery’s status occurs or is being considered.

More frequent updates may be necessary where relevant information must support state-of-health monitoring and where such updates are technically feasible and proportionate.

Real-time transmission is not automatically required for every battery.

Static information vs dynamic information

For implementation purposes, it is useful to distinguish three types of information.

• Model information: Information that generally remains consistent across the model unless the relevant specification, evidence or documentation changes.
• Individual production information: Information recorded for a specific battery at manufacture or market placement.
• Dynamic lifecycle information: Applicable information that may evolve during use, servicing, repurposing, remanufacturing or other relevant lifecycle events.

These are practical data-management categories. The legal requirements must still be checked against Annex XIII.

What if a company manufactures once and sells throughout the year?

This is a recurring question in Collecta’s conversations with battery businesses.

Consider a manufacturer producing a large batch of batteries during one production period and distributing those batteries over the following twelve months.

Does every sale require every passport field to be updated?

Not necessarily.

The passage of time or an additional sale does not automatically mean that every existing technical value has changed.

However, companies must still ensure that their records satisfy the applicable requirements when the batteries are placed on the market or put into service, and that relevant lifecycle information is maintained afterward.

A change to an applicable data field, a correction to an inaccurate record or a relevant change in battery status may require action.

The correct workflow is therefore based on data responsibilities and update triggers, not on an arbitrary universal calendar.

Does a Battery Management System need to update the passport continuously?

Not in every case.

Battery Management Systems (BMS) may be important sources of applicable state-of-health and usage information.

However, the Commission’s FAQ makes clear that real-time or very frequent communication is not universally necessary.

For an offline e-bike battery, obtaining relevant updates during servicing may be appropriate, depending on the information and circumstances.

The Commission also distinguishes batteries without a BMS: certain state-of-health requirements are linked to the presence of a BMS, but that does not create a general exemption from all individual-battery information requirements.

Companies should therefore avoid assuming that continuous BMS-to-DPP connectivity is mandatory for every battery.

How Can Companies Build a Reliable Battery Passport Data Workflow?

A practical implementation process should connect legal requirements to identifiable data sources, responsibilities and review activities.

Step 1: Build a category-specific requirements list

Start with Annex XIII and the latest Commission data-point guidance.

Determine which requirements apply to your battery category and at the relevant date.

Record whether each field is mandatory, conditional, optional or not yet required.

Step 2: Create a data inventory

For each applicable field, identify the current source.

This may be an internal system, a document, an external supplier or an individual battery record.

Use a consistent inventory format:

Illustrative entries; determine applicability separately for each battery category.

Step 3: Resolve missing information

Separate genuinely missing data from information that exists but has not yet been collected or validated.

Establish supplier requests, evidence requirements and internal review responsibilities.

Step 4: Define update triggers

Determine which events require information to be reviewed.

Examples may include:

• A relevant change to model specifications.
• Correction of inaccurate information.
• A change in applicable lifecycle status.
• New or revised evidence affecting a required field.
• Relevant service, repurposing or remanufacturing events.

Not every trigger will require the same response. Define the affected fields, responsible parties and applicable rules.

Step 5: Test the workflow with one battery model

Before scaling, test the complete process using a representative product.

Confirm that the company can identify required fields, obtain supporting information, create individual records, manage access rights and maintain applicable data.

Record the gaps revealed by the pilot.

Battery Passport Data Readiness Checklist

Before launching your implementation, ask:

• Have we identified the applicable battery category?
• Have we checked the relevant requirements against Annex XIII?
• Have we distinguished mandatory, conditional and later-applicable fields?
• Do we know where each required data field originates?
• Have we identified supplier and subcontractor dependencies?
• Is someone responsible for validating the information?
• Can we distinguish model data from individual battery data?
• Have we identified applicable restricted-access information?
• Do we know which lifecycle events may require updates?
• Can we test the complete process with one representative battery?

A data-readiness assessment should reveal what is already available, what remains missing and where responsibilities need to be clarified.

Use our [Battery Passport Readiness Checklist](/guides/battery-passport-checklist) to plan your next steps.

From Required Data Fields to a Working Process

For many battery manufacturers and importers, the challenge is not limited to understanding what Annex XIII requires.

It is transforming information from internal systems, suppliers, production records and lifecycle stakeholders into a manageable process.

Collecta DPP is designed to help businesses organise battery information, collaborate on required data and manage digital Battery Passports.

By clarifying data sources, ownership and update responsibilities early, companies can move from scattered records toward a more structured approach to passport preparation.

Explore Collecta DPP → https://www.collectadpp.com/

Official Sources and Further Reading

1. Regulation (EU) 2023/1542 — Batteries and Waste Batteries — Particularly Articles 14, 77 and 78, and Annex XIII.
2. European Commission — Digital Product Passport for Batteries — Including the August 2026 guidance “Digital Batteries Passport – Data Points by Category”.
3. European Commission — Battery Passport FAQ — Particularly Section 8 on dynamic data and updates.
4. European Commission — Guidance to Support Preparations for the Digital Batteries Passport — Published 21 August 2026.
5. Collecta — What Is a Battery Passport?
6. Collecta — Battery Passport Compliance Checklist

Disclaimer: This guide provides general information about EU Battery Passport requirements and does not constitute legal advice. Data requirements, applicability and update obligations should be assessed against the applicable legislation and current official guidance.