European Commission updates Digital Batteries Passport guidance: 71 data points

What changed

On 21 August 2026 the European Commission published an updated version of its guidance document "Digital Batteries Passport - data points by category", which the Commission's own page records as last updated on 15 August 2026. The document brings together 71 data points, shows the legal source of each one, and sets out how they apply to each battery category: electric vehicle batteries, light means of transport (LMT) batteries and industrial batteries. For each category it indicates whether a data point is mandatory, optional, applicable only in specific circumstances, or does not have to be completed or displayed as of February 2027. This is preparatory guidance: it is not legislation, it was not published in the Official Journal, and it creates no obligation beyond those already flowing from Regulation (EU) 2023/1542. The legal requirement itself is unchanged. Under Article 77(1), from 18 February 2027 each LMT battery, each industrial battery with a capacity greater than 2 kWh and each electric vehicle battery placed on the market or put into service must have an electronic record, the battery passport.

Who is affected

Manufacturers, importers and distributors placing electric vehicle batteries, light means of transport batteries or industrial batteries above 2 kWh on the European Union market, and the suppliers along the chain who have to hand those operators the underlying data: material composition, recycled content, carbon footprint, performance and durability, and the due diligence documentation on raw material sourcing.

What to do

Do not treat the 71 data points as a single mandatory list: applicability varies by battery category, and not every field is required at the first stage. The useful work now is to determine which category applies to each product, map which data points follow from it, identify the source document behind each attribute, and separate what already has evidence from what does not. It is also worth preparing persistent product and economic operator identifiers and the access rules: Article 77(2) splits passport information between what is accessible to the general public, what is restricted to notified bodies, market surveillance authorities and the Commission, and what opens to anyone with a legitimate interest, in each case under Annex XIII.

Related deadlines

• February 18, 2027. The battery passport starts to apply: under Article 77(1) of Regulation (EU) 2023/1542, each LMT battery, each industrial battery with a capacity greater than 2 kWh and each electric vehicle battery placed on the market must have an electronic record.