51 of 71 data points: what the battery passport actually requires on 18 February 2027
A European Commission guidance document classifies every single battery passport data point for the first time. Swiss DPP platform Transpareo has analysed the classification: for electric vehicle batteries, 51 of 71 data points are mandatory at the deadline; for batteries of light means of transport, 54; for industrial batteries, 36. The most consequential finding, however, is not the volume but the split.
Until the summer of 2026 there was no official answer to the question of what a battery passport must contain at the deadline. The EU Battery Regulation lists the content, the Battery Pass Consortium guidance expands it into roughly 90 attributes, and every development team drew its own line between “due in February 2027” and “due later”.
On 28 July 2026 the European Commission published guidance titled “Digital Batteries Passport – data points by category”. It lists 71 data points and issues a verdict on each one per battery category: mandatory, optional, applicable only in certain cases, or not to be completed at the deadline. The document is explicitly non-binding and creates no new obligations — but it is the clearest signal yet of how the Commission reads its own regulation.
One list becomes three. What counts as mandatory depends on the battery category. An EV battery reports the state of certified energy. An LMT battery instead reports the full state-of-health set: remaining capacity, remaining power capability, remaining round-trip efficiency and the evolution of self-discharge. An industrial battery carries most performance values only where applicable.
“A single checklist for all batteries falls short twice over,” says Günter Reichelt, Chairman of the Board of Transpareo AG. “It either forces e-bike fields onto EV batteries, or lets EV fields slip through. At the deadline there is not one mandatory list but three.”
What is excluded is what still lacks a methodology. The carbon footprint declaration and its label, the responsible sourcing information and the user manual do not have to be completed in February 2027 — they are waiting for their own legal acts. Supply chain due diligence reporting follows its own timetable and begins on 18 August 2027. “Anyone building a carbon footprint calculation engine today is investing too early,” says Reichelt. “A data model with room for it loses nothing by waiting for firm rules.” “A DPP system that cannot handle further data expansion easily and quickly is therefore too complex,” said Günter Reichelt
Not every mandatory field is public. The mandatory list and the public list are not the same list: state of health, status and usage history of an individual battery are mandatory but reserved for readers with a legitimate interest, such as repair and remanufacturing businesses. Test reports go exclusively to notified bodies and market surveillance. Anyone planning the passport as a purely consumer-facing page builds the permission model too late.
What manufacturers should do in 2026. Transpareo recommends three steps in this order. First, collect the mandatory core, most of which describes what the battery is: chemistry, voltages, masses, recycled content shares, dismantling information. Second, secure the supplier portion contractually, because recovery shares and performance test results sit with the cell manufacturers. Third, leave out what the Commission itself left out.
The full analysis is available in 40 languages at Battery passport: the day-one list is out
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