Battery Passport Data Points Explained: All 71 Fields by Access Level

On 19 October 2026 the European Commission published version 3.2 of its guidance mapping the 71 data points of the digital battery passport under Regulation (EU) 2023/1542. It replaces version 2.0 of 15 August 2026. Separately for EV, LMT and industrial batteries above 2 kWh, it shows which fields are mandatory, optional, conditional or not to be filled from February 2027.

Mandatory data points by category (version 3.2):

• EV: 46
• LMT: 49
• Industrial (above 2 kWh): 31

LMT still has the highest count. Five state-of-health fields (points 62 to 66) are mandatory for LMT and not to be filled for EV, and EV's own two fields (points 33 and 61) do not close that gap.

The counts include point 51 (rated capacity of the individual battery), which the guidance marks "same as data point 11" for EV and LMT. Conditional and optional fields are not counted.

The guidance creates no new legal requirement. It states that it "should not be considered as representative of the European Commission's official position" and is to be read with the Regulation. Use what follows as a field-level reference to check against your own data-collection plan. Our digital battery passport guide explains scope, responsibility and access, and our battery passport deadlines guide covers the wider timeline.

What changed from version 2.0

• The C-rate field is now two fields. Point 39 is the charge C-rate of the cycle-life test. A new point 40, the discharge C-rate, is optional for all three categories.
• The spare-parts fields are merged. Part numbers for components and contact details for replacement spares, previously points 46 and 47, are now one field, point 47.
• Points 41 to 46 have new numbers. Because of the split and the merge, the marking, EU declaration of conformity, waste information, instructions for use and detailed composition fields each moved one number higher. Points 48 to 71 keep their numbers.
• Industrial conditions are now specific. Where version 2.0 said "if applicable" for industrial batteries, version 3.2 names the condition. Most dynamic performance fields apply "only for rechargeable batteries", and the five state-of-health fields apply only to stationary battery energy storage systems with a battery management system.
• Use data applies from first use. Points 68 to 71 (cycles, negative events, operating conditions and state of charge) changed from "if applicable" to "applicable as soon as the battery starts to be used", for all categories.
• Access levels come from the guidance. Version 3.2 marks each field as public or restricted and says who may see the restricted fields. The table below uses these groups.
• Each mandatory count fell by one (EV from 47 to 46, LMT from 50 to 49, industrial from 32 to 31). The merge removed one mandatory field, and the new field is optional.

If your data schema follows version 2.0, renumber fields 39 to 47, add point 40 and recheck the industrial fields against the new conditions.

Fields not to be filled at launch

None of these goes in the passport as of February 2027, for any category:

• Points 16 and 25: repeat data already required elsewhere (composition and capacity)
• Points 17 and 18: carbon footprint declaration and label; the format is still to be set in an implementing act
• Point 19: responsible sourcing information from the due diligence report; required from August 2027 (Article 48(1) of Regulation (EU) 2025/1561)
• Points 20 to 23: recycled cobalt, lithium, nickel and lead shares; to be applied as envisaged by Article 8
• Point 45: printable instructions for use; on hold pending Omnibus adoption. The guidance marks this field as to be confirmed, as it refers to an Annex XIII point that is not in the current consolidated Regulation

Keep the eight postponed fields (17 to 23 and 45) in your data schema as pending fields. Points 16 and 25 repeat other fields, so they do not need their own. Several postponed fields become mandatory once the missing act or date arrives, so don't build a February 2027 pipeline around carbon footprint or due diligence.

Some fields are also excluded for one or two categories: points 33 and 61 are not to be filled for LMT and industrial batteries, and points 62 to 66 are not to be filled for EV batteries.

Mandatory for all three categories

These 31 fields apply to every battery in scope, so they are the easiest to plan for. They are also the full mandatory list for industrial batteries.

• Points 1 to 4 and 6 to 15: identification and manufacturer data (point 5, web and email address, is optional)
• Point 24: share of renewable content
• Points 26 to 30 and 34: voltages, power capability, power limits and temperature range
• Point 38: internal cell and pack resistance
• Points 41, 43 and 44: Article 13(4) marking, EU declaration of conformity and waste battery information
• Points 46 to 50: detailed composition, spare parts, dismantling information, safety measures and test reports
• Point 67: battery status (original, repurposed, reused, remanufactured or waste)

What EV and LMT batteries add

EV and LMT batteries share 13 further mandatory fields:

• Points 31 and 32: expected lifetime in cycles and its reference test
• Points 36 and 37: round trip energy efficiency, initial and at 50 % of cycle life
• Point 39: charge C-rate of the cycle-life test
• Points 51 to 56, 59 and 60: performance and lifetime values of the individual battery

Each category then has its own state-of-health fields:

• EV only: point 33 (capacity threshold for exhaustion) and point 61 (state of certified energy)
• LMT only: points 62 to 66 (remaining capacity, remaining power capability, remaining round trip efficiency, evolution of self-discharging rates and ohmic resistance)

EV batteries report state of health through one figure, and LMT batteries through five. That is why LMT's count (49) is higher than EV's (46).

Where industrial batteries differ

Industrial batteries have no fields of their own. Instead, many fields apply to them only under a stated condition:

• Points 31 and 32 (lifetime in cycles): only some industrial batteries where lifetime can be expressed in cycles
• Points 36, 37 and 39 (round trip efficiency and charge C-rate): only some industrial batteries
• Points 51 to 56, 59 and 60 (performance and lifetime of the individual battery): only rechargeable batteries; point 59 also excludes non-cycle applications
• Points 57 and 58 (round trip efficiency and its fade): only rechargeable batteries, if applicable
• Points 62 to 66 (state of health): only stationary battery energy storage systems with a battery management system
• Points 33 and 61: not to be filled

Decide these fields per product, not per category. A rechargeable stationary storage system with a battery management system falls under most of them; a non-rechargeable industrial battery falls under few.

Conditional or optional for every category

• Point 35: commercial warranty period for calendar life, if a commercial warranty is envisaged
• Point 42: cadmium or lead symbol, if applicable
• Points 57 and 58: round trip efficiency and its fade, if applicable
• Points 68 to 71: cycle count, negative events, operating conditions and state of charge, applicable as soon as the battery starts to be used
• Points 5 and 40 are optional: manufacturer web and email address, and discharge C-rate

Use data can be empty when a new battery is first placed on the market (Commission FAQ 8.6), but points 68 to 71 apply once the battery is in use, so plan how that data will be captured. The guidance also notes that points 51 to 60 are dynamic: their values may need updating after a change in status, such as repurposing or remanufacturing.

Checklist for your data plan

• Close out the 31 fields that are mandatory for every category first; no category logic is needed
• If your schema follows version 2.0, renumber fields 39 to 47 and add point 40
• Keep the eight postponed fields (17 to 23 and 45) in the schema; don't delete them
• Don't schedule carbon footprint or due diligence work against February 2027
• Decide industrial conditional fields per product, using the guidance's conditions
• Build state of health as category-specific fields from the start, not one shared field
• Plan how use data (points 68 to 71) will be captured once the battery is in use

All 71 EU battery passport data points

The table below follows the European Commission's guidance (version 3.2, 19 October 2026). Data point names and statuses are as given in the guidance. Format notes in square brackets are left out (except [years], which tells points 59 and 60 apart), rows are grouped by the guidance's access column, and where a status is the same for all three categories it is shown once.

Source: European Commission, Guidance Document: Digital Batteries Passport, data points by category, version 3.2, 19 October 2026. Licence: CC BY 4.0. Changes made: format notes in square brackets omitted, rows grouped by access level and identical statuses merged across categories. The guidance states that it "should not be considered as representative of the European Commission's official position".

Access levels follow the guidance and Article 77(2) of Regulation (EU) 2023/1542. Who counts as a person with a legitimate interest will be set by an implementing act under Article 77(9). The Commission published a draft for feedback on 19 October 2026, and its planning lists adoption for the fourth quarter of 2026 (Have your say, initiative 16473).

How DigiProd Pass can help

DigiProd Pass works with battery manufacturers and importers on data-collection audits: mapping which of the 71 data points are already held, where the gaps sit by category, and how to bring supplier data into a form the passport can use before February 2027. Responsibility for the passport stays with the economic operator placing the battery on the market (Article 77(4)).

Book a data gap review to check your battery data against version 3.2.

FAQs

Is this guidance legally binding?

No. The guidance states that it should not be considered as representative of the Commission's official position, and it introduces no additional requirement. The legal obligations come from Regulation (EU) 2023/1542.

What changed in version 3.2?

The C-rate field was split into charge and discharge C-rate, the two spare-parts fields were merged, points 41 to 46 were renumbered, the industrial conditions were made specific and the use-data fields (68 to 71) now apply as soon as the battery starts to be used. Each mandatory count fell by one.

Do all 71 data points apply to every battery?

No. Each point is marked mandatory, optional, conditional or not to be filled, separately for EV, LMT and industrial batteries.

Why does LMT have more mandatory fields than EV?

Points 62 to 66, five state-of-health measures, are mandatory for LMT and not to be filled for EV. EV's own fields, points 33 and 61, do not offset that gap.

Are carbon footprint and due diligence data required at launch?

No. Carbon footprint (points 17 and 18) has no set format yet, and due diligence information (point 19) is required from August 2027.

When does the battery passport become mandatory?

From 18 February 2027, for EV batteries, LMT batteries and industrial batteries above 2 kWh (Article 77(1) of Regulation (EU) 2023/1542).

Sources

1. Regulation (EU) 2023/1542 on batteries and waste batteries, consolidated version of 13 August 2026: Articles 8, 48, 77 and Annexes VI and XIII
2. European Commission: Guidance Document, Digital Batteries Passport, data points by category, version 3.2, 19 October 2026
3. European Commission: EU Digital Product Passport FAQ for Batteries
4. European Commission, Have your say: Batteries, access rights to certain parts of the battery passport (draft implementing regulation)

This article reflects version 3.2 of the Commission's guidance as of 4 November 2026. It is general information, not legal advice. The implementing act on access to restricted data was still pending at the time of writing.