Battery Passport Annex XIII Data Requirements
This page summarizes the EU Battery Passport data requirements using the structure in Annex XIII of Regulation (EU) 2023/1542. Annex XIII defines what data must exist in the passport, and which audiences can access which data.
What Annex XIII actually does
Annex XIII organizes required passport information into access tiers:
- Publicly accessible battery-model information
- Battery-model information accessible only to persons with a legitimate interest (and the Commission)
- Battery-model information accessible only to notified bodies, market surveillance authorities, and the Commission
- Individual-battery information accessible only to persons with a legitimate interest
This matters because you are not collecting one dataset¯. You are collecting multiple datasets with different access rights, update rights, and confidentiality rules.
Annex XIII access tiers
| Annex XIII tier | What it covers | Who can access | Typical owners inside a company |
|---|---|---|---|
| 1. Public model information | Model-level identity, composition summaries, sustainability/performance disclosures, marking and conformity info | General public | Compliance, product stewardship, regulatory, product engineering |
| 2. Legitimate-interest model information | Detailed composition, spares identifiers, dismantling/disassembly information, safety measures | Persons with a legitimate interest + Commission | Engineering, service/aftermarket, safety, IP/legal, recycling/EOL teams |
| 3. Authority-only model information | Test reports evidencing compliance with Regulation (EU) 2023/1542 and related acts | Notified bodies, market surveillance authorities, Commission | Compliance + labs + certification/quality |
| 4. Legitimate-interest individual-battery data | Unit-level performance/durability values, state of health, status changes (original/repurposed/etc), use-phase events and operating conditions | Persons with a legitimate interest | BMS/telematics, fleet/service, warranty, second-life, recycler interface |
Major data categories you must be ready to publish
Below are the major buckets¯ most teams use to plan Annex XIII readiness. The regulation™s wording is more granular, but these buckets map cleanly to how systems are typically implemented.
| Major category | Annex XIII mapping | Where the data usually lives | Common failure mode |
|---|---|---|---|
| Identity and markings | Public model info + QR/identifier access mechanics | PLM, labeling/marking systems, serialization services | No stable ID strategy across revisions, repairs, repurpose, and EOL |
| Materials and chemistry | Public composition summaries + legitimate-interest detailed composition | PLM, BOM, supplier declarations, material master | Supplier data arrives as PDFs; no structured, versioned, auditable dataset |
| Carbon footprint and sustainability | Public carbon footprint information + related sustainability disclosures | LCA tools, ERP/energy data, supplier emissions data, audits | Methodology mismatch across tiers; weak evidence chain |
| Performance, durability, and warranty | Public performance disclosures + unit-level values where applicable | Test labs, PLM, quality, warranty systems | Test artifacts are not linked to the exact model revision placed on market |
| Safety, disassembly, and EOL support | Legitimate-interest dismantling info + safety measures | Engineering docs, service manuals, recycler interface packs | Teams over-restrict access and block legitimate repair/reuse workflows |
| Use-phase and lifecycle updates | Individual battery data (cycles, events, conditions, status) | BMS, telemetry platform, service/repair tools, second-life operators | No governance for who can write¯ updates and when status changes |
Practical implementation guidance
Treat the passport as a governed data product:
- Define a canonical data dictionary that mirrors Annex XIII tiers (public, authority-only, legitimate-interest, unit-level).
- Assign system of record¯ for each field group (PLM vs ERP vs lab systems vs BMS telemetry).
- Version everything: product model revisions, BOM/material declarations, test reports, and published passport snapshots.
- Design access and write-permissions so repair, second-life, and recyclers can do their work without exposing IP beyond what is necessary.
Annex XIII can be amended by the Commission over time, and implementing acts can refine access rules for legitimate interest¯. Plan for controlled change, not a one-time compliance sprint.
Where to go next
| Topic | Recommended page | Why it matters |
|---|---|---|
| Battery ID and serialization | Battery ID & Serialization | Everything breaks if identifiers are unstable across lifecycle events |
| Carbon footprint | Battery Carbon Footprint | Disclosure requires consistent method + evidence chain |
| Digital architecture and QR codes | Digital Architecture & QR Codes | Decides how data is found, read, and controlled |
| Required passport fields (structured) | Required Passport Fields | Implementation-ready field groupings by category |
Disclaimer. Informational guidance only. Not legal advice. Validate requirements against your products, your supply chain, and the latest published Regulation (EU) 2023/1542 text.