On 21 August 2026 the Commission published version 2.0 of a guidance document called Digital Batteries Passport, data points by category. It takes Annex XIII and Annex VI of the battery regulation, numbers every data point from 1 to 71, and says for each of the three passport categories whether the field is mandatory, optional, applicable only in some cases, or not to be filled on 18 February 2027. We read it line by line. The headline is not the 71. It is the ten fields that the Commission says should stay empty for everyone, because the acts that define them do not exist yet.
What the document is, and what it is not
The file is fifteen pages, dated 15 August 2026, signed electronically on the 16th and announced on the 21st. The first edition came out at the end of July. It comes from Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, and it is explicit about its status: it does not represent the Commission's official position, it does not extend rights or obligations, and it does not introduce any requirement. It also promises future editions with definitions, units and formats for individual data points.
What it does is simpler and, for anyone building a passport this winter, more valuable than a legal act: it puts three columns next to the law. Electric vehicle batteries, light means of transport batteries, and industrial batteries above 2 kWh. Every row cites its source, either Article 77(3), Annex VI Part A or a specific point of Annex XIII.
The counts
We classified every row in each column. The guidance uses four labels: mandatory, optional, applicable only in certain cases, and not to be filled or displayed as of February 2027. Counting them:
- Electric vehicle batteries: 47 mandatory, 15 not to be filled, 1 optional, 8 conditional.
- LMT batteries (e-bikes, scooters): 50 mandatory, 12 not to be filled, 1 optional, 8 conditional.
- Industrial batteries above 2 kWh: 32 mandatory, 12 not to be filled, 1 optional, 26 conditional.
The single optional field is the manufacturer's web and email address. The conditional ones are mostly performance parameters that depend on chemistry and use, and for industrial batteries almost the entire state-of-health block is marked applicable only where the parameter makes sense for the battery. An LMT battery, by contrast, has the longest mandatory list of the three. If you assemble e-bike packs, the guidance is telling you that your passport is the fullest one.
Ten fields that stay empty for everyone
Ten rows carry the same label in all three columns: not to be filled or displayed. They fall into two groups.
Two are repetitions. Field 16, material composition, duplicates fields 12, 13 and 15 (chemistry, hazardous substances, critical raw materials). Field 25, rated capacity in Ah, duplicates field 11. The guidance says so directly and tells you to leave them out. This is the Commission choosing readability over the letter of an annex that lists the same thing twice.
Eight are waiting for other acts. Fields 17 and 18, the carbon footprint declaration and label, wait for an implementing act on the format. Field 19, responsible sourcing from the due diligence report, is required from August 2027 under Article 48(1), not February. Fields 20 to 23, the recycled shares of cobalt, lithium, nickel and lead, follow Article 8 and its delegated act, which missed its own 18 August 2026 deadline. Field 44, printable instructions for use, is marked on hold pending Omnibus adoption. That field is worth a second look: it cites point 1(t) of Annex XIII, and the consolidated text of the regulation as of 31 July 2025 has no point (t). The guidance is listing a field from a proposal that Parliament and Council have not adopted, and telling you not to fill it. Correct advice, unusual provenance.
The practical reading: on 18 February 2027 a compliant passport has empty slots, and the emptiness is the compliant state. A provider who tells you the carbon footprint field must be filled in February is wrong. A provider whose template has no such field at all will have a problem within the year.
Where the three categories differ
Most rows are identical across the columns. The differences are concentrated in the state-of-health block and they are exact mirrors of Article 14 and Annex VII.
- EV only: field 33, the capacity threshold for exhaustion, and field 61, state of certified energy. Both are marked not to be filled for LMT and industrial batteries.
- LMT and industrial only: fields 62 to 66, remaining capacity, remaining power capability, remaining round-trip efficiency, evolution of self-discharge and ohmic resistance. Mandatory for LMT, applicable where relevant for industrial, not to be filled for EV.
- Industrial softening: expected lifetime in cycles, round-trip efficiency and C-rate (fields 31, 32, 36, 37, 39) are mandatory for EV and LMT but only for some industrial batteries where lifetime can be expressed in cycles.
The half of the table nobody can fill from a spreadsheet
Fields 1 to 50 describe the battery model: who makes it, what it is made of, how it performs when new, what documents stand behind it. Fields 51 to 71 come from Annex XIII point 4 and describe the individual battery over its life: capacity fade, power fade, resistance increase, the status word (original, repurposed, re-used, remanufactured, waste), the number of cycles, negative events, recorded temperatures and state of charge. The guidance marks the first of them, rated capacity, as the same as field 11 but now dynamic.
That word is the design brief. A model-level passport with static values covers rows 1 to 50. Rows 51 to 71 require a record per battery that changes after the sale, fed by the battery management system or by whoever services the pack. For an EV manufacturer this is a data pipeline they already have. For a small LMT assembler it is the difference between a web page and a system. We wrote earlier about choosing between model, batch and item as the level of your passport; for batteries the guidance answers it for you. The item level is not optional.
Three tiers of access, and the act that is still missing
Fields 45 to 50 are the restricted ones. Detailed composition including cathode, anode and electrolyte, part numbers, spare part sources, dismantling diagrams, safety measures, test reports. Annex XIII assigns them to persons with a legitimate interest, to notified bodies and market surveillance authorities, and to the Commission. All six are mandatory in every column.
The implementing act that was supposed to define who has a legitimate interest and how they prove it was due on 18 August 2026 and has not been drafted. So the guidance now asks you to prepare six mandatory fields for an audience the law has not yet described. The data still has to exist on 18 February; what is undecided is the door. Build the fields and the tier, and leave the authentication method open.
What this is not
This is not law. Page three says so twice. A market surveillance authority can read Annex XIII differently, and the next edition of the guidance can change a label.
This is not a data format. The document numbers fields and says whether to fill them; it does not say in what units, in what structure, or through which API. The Commission says future updates may add that. Until then the six EN 1822x standards are where the structure comes from.
This is not a portable battery document. Portable batteries have no passport, as we explained last month, and the guidance does not mention them.
How to check this yourself
The guidance is a public PDF linked from the Commission news item of 21 August 2026 at https://single-market-economy.ec.europa.eu/news/guidance-support-preparations-digital-batteries-passport-2026-08-21_en. The table starts on page five. The regulation it annotates is free at https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng; the parts cited are Article 77(3), Annex VI Part A and Annex XIII points 1 to 4. Our counts are ours: we sorted every row by the label in each column and they add up to 71 in each case. If you count a conditional field as mandatory you will get higher numbers, which is what some summaries did.
What to do this week
- Print the table, mark your column, and cross out the ten rows the Commission tells you to leave empty. What remains is your field list for February.
- Check fields 51 to 71 against your data sources. If a value changes after sale, you need a place that receives updates per battery, and someone responsible for sending them.
- Put fields 45 to 50 in a restricted tier now, even though the access act is missing. The content is mandatory; only the audience is undefined.
- Ask your provider which of the eight waiting fields exist in their template as empty slots. The answer tells you whether they read the annex or the guidance.
FAQ
Does the guidance change what the regulation requires?
No, and it says so. It sorts and labels; it does not add or remove. The ten empty fields are empty because other acts or dates say so, not because the guidance says so.
Why does my provider say 51 mandatory fields and you say 47 or 50?
Because the labels overlap. Some rows say if applicable; whether you count that as mandatory depends on your battery. Our numbers count only rows marked mandatory without qualification, per column.
I make e-bike batteries. Which column is mine?
LMT, if the battery is sealed, weighs 25 kg or less and is designed to power a wheeled vehicle. That column has the longest mandatory list.
What about the carbon footprint? I have a declaration ready.
Keep it. The field exists; the format act does not. The guidance says not to display it in February, not that you will not need it.
Will there be a version 3.0?
The document says future updates may include definitions, units and formats. Expect one, and expect it to change labels on a few rows.
Łukasz Głuch
Builds DPPera, a digital product passport tool for small and medium-sized companies. Reads the delegated acts so you do not have to. Writes about what he checked in the registry, not about what vendors promise.
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