The Commission has finally said which battery-passport fields are mandatory

A fifteen-page document answers the question operators keep asking

On 28 July 2026, the Commission's DG GROW published "Digital Batteries Passport — data points by category, Version 1.0" — the first official document that goes data point by data point and states, for each battery category, whether it is mandatory, optional, applicable in certain cases, or not to be filled as of February 2027. Until now, that question could only be answered by reading Annex VI and Annex XIII of the Battery Regulation side by side and making judgement calls. Now every numbered data point carries its legal source — Article 77(3), Annex VI Part A, Annex XIII — and a per-category status for EV, LMT and industrial batteries.

If you are an importer, an authorised representative, or a manufacturer issuing your own passports, this is the closest thing yet to an official checklist of what your passport must actually contain on 18 February 2027.

What it settles

Some entries confirm what a careful reading of the Regulation already suggested: battery chemistry is mandatory for all three categories, as are hazardous substances beyond mercury, cadmium and lead, the share of renewable content, and the core identity set — manufacturer, category, weight, status. The recycled cobalt, lithium, nickel and lead shares under Annex XIII 1(e), by contrast, are marked not to be filled as of February 2027 — they apply in line with Article 8 and its delegated act, so like the carbon footprint declaration they join the collect-now, display-later set. Others resolve genuine ambiguity: several performance and durability points are mandatory for EV and LMT batteries but only applicable in certain cases for industrial ones, and a commercial-warranty period is required only where a commercial warranty exists at all.

The two entries most people will not expect

First: the aggregate material-composition entry under Annex XIII 1(b) is marked not to be filled or displayed — for all three categories — because it merely repeats the chemistry, hazardous-substances and critical-raw-materials points already required. This is a de-duplication, not a waiver: the detailed composition under Annex XIII 2(a), including the materials used in the cathode, anode and electrolyte, remains mandatory for all three categories in the restricted, legitimate-interest tier.

Second: the carbon footprint declaration is marked not to be filled as of February 2027, with the format "still to be specified in the upcoming implementing act". To be clear about what that does and does not mean: the carbon footprint obligation itself is not going anywhere, and the data collection behind it — methodology, lifecycle stages, verification — remains the longest lead-time item in a battery passport programme. What does not yet exist is the declaration format. If your project plan has "finalise CF declaration format" on the critical path for launch, the Commission has just told you that box cannot be ticked yet, by anyone.

What it does not settle

This is guidance, not a delegated act, and the document says itself that it may be further developed over time, including definitions, measuring units and formats. And it is not the semantic catalogue: registration of battery passports in the EU registry remains unavailable because that catalogue is still undefined — the registry User Guide (v1.01, 28 July) says so in terms. Our standing advice is unchanged: complete operator verification now; registration follows when the catalogue lands.

What we did with it

We audited our field enforcement against the matrix, category by category, data point by data point. As of today: chemistry is a required field across all three categories, the warranty field no longer blocks passports where no commercial warranty exists, and carbon footprint fields remain fully collectable but no longer block activation — matching the matrix rather than our own best guess of it. That audit is the point of a compliance platform: when the Commission moves, the rules you are held to move with it, without a project on your side.

If you want to see where your passports stand against the matrix, category by category, the platform will show you field by field.

Updated 19 August 2026: this analysis has been checked against Version 2.0 of the Commission matrix (published 15 August 2026) and corrected where the guidance moved.