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Battery Passport Data Fields: The Full List

Every data category Regulation (EU) 2023/1542 requires in a battery passport, which party in the chain holds each figure, and who may read it once published.

CirculeID Research6 min read1,322 words

A battery passport must carry general battery and manufacturer information, composition including critical raw materials, carbon footprint, recycled content, performance and durability, state of health, hazardous substances, dismantling information and supply chain due diligence. Access differs by field: some are public, others restricted to legitimate interested parties.

What this gives you

The full field list grouped by who holds each figure, so you can turn the regulation into a supplier data request rather than a reading exercise, and see which fields are public.

Key takeaways

  • Battery passport data is not uniformly public; the access split is written into the regulation.
  • Most fields originate upstream, with cell and cathode producers rather than the pack assembler.
  • State of health is a series of dated values, not a single figure set at manufacture.
  • Recycled content is declared per metal — cobalt, lithium, nickel and lead separately.

The field list is the part of the battery passport that most programmes read first and act on last. Reading it is quick. Turning it into a set of supplier requests, each aimed at the party that actually holds the number, is the work.

What data must a battery passport carry?

Regulation (EU) 2023/1542 groups the required information into categories rather than presenting a flat list. The grouping matters, because access rights are assigned by group.

Battery passport data categories, their source and who may read them
CategoryTypical sourceAccess
Battery and manufacturer identificationPack assemblerPublic
Composition and critical raw materialsCell and cathode producersPublic in part
Carbon footprintCell producer and upstreamPublic
Recycled content per metalRefining and cathode chainPublic
Performance and durabilityCell producerRestricted
State of healthBattery management systemRestricted
Hazardous substancesCell producerPublic and treatment
Dismantling informationPack assemblerTreatment operators
Due diligence reportEconomic operatorPublic
Battery passport data categories, their source and who may read them

Which fields are hardest to obtain?

Difficulty does not follow the order of the list. The fields that hold programmes up are the ones whose source sits several tiers upstream and has no direct obligation to you.

  1. Recycled content per metal, because it depends on mass balance bookkeeping at the refiner.
  2. Carbon footprint, because it requires primary data from cell manufacture rather than an average.
  3. Due diligence evidence, because it reaches to mineral origin through parties you do not contract with.
  4. Critical raw material composition, where cathode formulations are treated as commercially sensitive.

Identification and dismantling data, by contrast, sit with the pack assembler and are usually available within weeks. Sequencing a programme to start with what you already hold produces a visible passport quickly and hides the fact that none of the difficult fields have moved.

How is state of health handled?

State of health
A measure of a battery’s condition relative to its original specification, expressed through parameters including remaining capacity, internal resistance evolution and cycle count, and updated across the battery’s service life rather than fixed at manufacture.

State of health is the one field that is wrong the moment it is written if it is treated as static. The passport must accept updates, and the useful form is a dated series rather than a replaced value, so that a second-life buyer sees a trajectory rather than a snapshot.

Recording each update as a dated event, in the EPCIS 2.0 vocabulary, gives that history without inventing a format. It also means an overwritten figure cannot quietly erase evidence of degradation.

What does recycled content require in practice?

Recycled content is declared separately for cobalt, lithium, nickel and lead, and each declaration must be supported by evidence that survives verification. The thresholds and their dates are covered in battery recycled content targets.

The mechanism that makes a claim defensible is chain of custody. A physically segregated claim is the strongest and the least commercially practical; a mass balance claim is what most chains will use, and it requires bookkeeping at the refiner that your contract has to reach.

How the fields map to a supplier request

Each layer is a different negotiation, and they do not run at the same speed.

Grouping the field list this way turns it into four supplier conversations plus a telemetry integration, which is a plan. Reading it as a flat list of around ninety attributes produces a spreadsheet nobody owns.

How do the fields change as the battery ages?

Most of the field list is fixed at manufacture and never changes: chemistry, composition, carbon footprint and recycled content describe how the battery was made. A smaller set describes how it has been used, and that set is the reason a battery passport is harder to operate than a passport for a static product.

Which battery passport fields are fixed at manufacture and which change in service
Field groupSet atChanges later
IdentificationManufactureNo
Composition and CRMManufactureNo
Carbon footprintManufactureOnly on recalculation
Recycled contentManufactureNo
State of healthIn serviceContinuously
Ownership and statusIn serviceOn transfer or repurposing
Dismantling informationManufactureOn design revision
Which battery passport fields are fixed at manufacture and which change in service

Designing the record so the fixed fields are written once and the in-service fields append is what keeps the passport honest over fifteen years. A model that permits any field to be overwritten silently loses the degradation history that gives a second-life buyer a reason to pay for the pack.

What happens if a field is missing?

A passport with an unpopulated mandatory field is a non-compliant passport, not a partial one. There is no partial credit at market surveillance, which is why gap reporting against the field list matters more than the rendering of the passport itself.

Frequently asked questions

How many fields does a battery passport contain?

Regulation (EU) 2023/1542 sets out the requirement as categories of information rather than a numbered field list, and the implementing detail expands each category into multiple attributes. Planning against roughly ninety attributes grouped into nine categories is a workable assumption until the implementing act fixes the schema precisely.

Is all battery passport data public?

No. The regulation splits access. Identification, carbon footprint, recycled content and the due diligence report are public, while performance and durability data is restricted to legitimate interested parties and the Commission, and dismantling information is aimed at treatment operators. A single published document cannot satisfy this.

Who is responsible for populating the fields?

The economic operator placing the battery on the EU market is accountable for the passport, but most figures originate upstream with cell producers, cathode suppliers and refiners. The operator obtains them by contract, which is why supplier engagement rather than software decides whether the date is met.

How often must state of health be updated?

The regulation requires the passport to reflect the battery’s current condition, which in practice means accepting updates from the battery management system across service life. Recording each as a dated event rather than overwriting one value gives a second-life buyer the degradation trajectory they need to price the asset.

Can we publish a passport with fields still empty?

A passport missing a mandatory field is non-compliant rather than partial. You can and should generate passports early to test the pipeline, but the internal measure that matters is the share of mandatory fields with an attributable source, not the number of passports produced.

Do the fields differ by battery category?

The core categories are common, but the detail varies. Electric vehicle batteries carry obligations tied to vehicle type approval, and industrial batteries above 2 kWh carry durability parameters relevant to their duty cycle. Scope decisions therefore change the field set as well as whether a passport is needed at all.

Sources

  1. Regulation (EU) 2023/1542 concerning batteries and waste batteriesEUR-Lex, European Union, 2023-07
  2. GS1 EPCIS and CBV 2.0 standardGS1, 2022-06

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