The 71 Data Points of the EU Battery Passport

On 15 August 2026 the European Commission published version 2.0 of its guidance "Digital Batteries Passport – data points by category". The document lists 71 data points, gives the legal source of each in Regulation (EU) 2023/1542, and maps its applicability to the three battery categories covered by Article 77. Counting strictly the cells marked "Mandatory", the result is 46 mandatory data points for electric vehicle batteries, 49 for LMT batteries and 32 for industrial batteries above 2 kWh on 18 February 2027 — plus an explicit list of points that must not be filled in at that date, carbon footprint included.

It is the most useful document published on the battery passport so far, and the least discussed. Here is exactly what it says.

What is the 15 August 2026 guidance?

It is a guidance document from the Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs (DG GROW, Unit G2 "Single Market Implementation Tools"), published as version 2.0 on 15 August 2026 and announced on 21 August 2026. It follows a first edition dated 28 July 2026.

Its purpose is stated plainly: to help economic operators prepare the implementation of the battery passport data requirements by identifying "where information is mandatory, optional, applicable only in certain cases, or does not have to be filled/displayed as of February 2027".

The document is not binding, and says so: it "does not extend in any way the rights and obligations deriving from applicable legislation nor introduce any additional requirement". But it is currently the only official map connecting each passport field to its legal basis.

How is the table structured?

The 71-point table is built on five elements:

1. 01.the number of the data point;
2. 02.its name;
3. 03.its legal source in the Batteries Regulation — Article 77(3), Annex VI Part A, or Annex XIII points 1 to 4;
4. 04.its applicability to electric vehicle batteries;
5. 05.its applicability to LMT batteries and to industrial batteries above 2 kWh.

Applicability cells take four values: Mandatory, optional, if applicable, and not to be filled/displayed as of February 2027.

How many data points are actually mandatory on 18 February 2027?

We counted the 71 points of version 2.0 line by line. The counting rule is strict: a point counts as mandatory only where the cell reads exactly "Mandatory", excluding optional points, conditional points and points not to be filled in.

Three notes so the count is reproducible:

• •point 5 (manufacturer web and email address) is the only optional point across all three categories;
• •point 51 (rated capacity in Ah, Annex XIII 4(a)) is counted here as conditional: the guidance presents it as point 11 repeated "but now dynamic";
• •different counts circulate in the trade press (51 / 54 / 36). They rely on another counting rule, or on version 1.0 of 28 July 2026. We publish ours with its rule so it can be checked line by line against the Commission PDF.

Which data points must NOT be filled in for February 2027?

This is the most counter-intuitive part of the document. Ten points are explicitly set aside for all three battery categories.

In other words: carbon footprint, recycled content and responsible sourcing — the three topics that dominate communication around the Batteries Regulation — are not passport fields to complete on 18 February 2027. They are genuine obligations under the Regulation, on their own timelines; they simply do not enter the passport at that date.

Reading it the other way round is expensive: it leads teams to delay a passport project while waiting for carbon data that is not required, when the 46 to 49 points that are genuinely due are already sitting in an ERP and a PLM.

Where do EV, LMT and industrial batteries diverge?

The reading is clear: state of health is not declared the same way across categories. An EV battery publishes one aggregated indicator — the state of certified energy under Article 14 — while an LMT battery publishes five detailed indicators. Industrial batteries, whose parameters depend on the application, carry most of the conditional points: 26 of 71.

What to do with this guidance

1. 01.Freeze the required core. 46, 49 or 32 points depending on your category: that is the scope due on 18 February 2027, and it is stable.
2. 02.Map every point to its real source — ERP, PLM, BMS, laboratory, supplier — and name an owner per point. The guidance gives the legal source, not the system source: that work is yours.
3. 03.Create the dormant fields. The 10 to 15 points set aside for 2027 will arrive later. Modelling carbon, recycled content and responsible sourcing fields now avoids a schema migration in 2028.
4. 04.Separate static from dynamic. Points 51 to 71 (Annex XIII point 4) are fed continuously from the BMS, not frozen at manufacturing. That is an architecture constraint, not a content one.
5. 05.Lock access rights before opening the data. A mandatory point is not a public point: Article 77(2) splits information between the general public, notified bodies and authorities, and persons with a legitimate interest.

In short

The 15 August 2026 guidance turns the battery passport from a vague regulatory topic into a countable specification: 71 points, one legal source per point, one applicability per category. The core genuinely due on 18 February 2027 — 46 points for EV, 49 for LMT, 32 for industrial batteries — is narrower than most players assume, and it contains neither carbon footprint nor recycled content.

Arianee runs an open DPP infrastructure that structures these points, separates static data from dynamic BMS data and enforces the Article 77 access rights. See our Battery Pass — Regulation (EU) 2023/1542 page, the detail of battery passport access levels, or request a demo.

Sources: Guidance Document: Digital Batteries Passport – data points by category, version 2.0, 15 August 2026 (PDF, European Commission) · Commission announcement, 21 August 2026 · Digital Product Passport — Batteries, European Commission · Regulation (EU) 2023/1542, EUR-Lex. Mandatory data point counts: line-by-line count of version 2.0 carried out by Arianee, counting rule stated above.