부속서 XIII 해설

Annex XIII of the Batteries Regulation sets out which data the battery passport contains and who may see it. There are four data groups with three access levels (Art. 77(2)).

No. 1: Public, readable by anyone

Anyone who scans the QR code sees the data on the battery model:

• Manufacturer and address, battery category, model identifier, place and date of manufacture
• Weight, capacity, chemistry, hazardous substances, critical raw materials, suitable extinguishing agent
• Performance data: nominal, minimum and maximum voltage, power, expected lifetime in cycles, efficiency, internal resistance, permitted temperature range
• EU declaration of conformity, symbols and information on take-back and waste prevention
• Later also: carbon footprint, recycled content and the due diligence report, once those obligations apply

No. 2: For persons with a legitimate interest and the Commission

Detailed model data that enables repair, reuse and recycling: materials of cathode, anode and electrolyte, part numbers and sources for spare parts, dismantling information (exploded diagrams, steps, tools, cell layout) and safety measures.

No. 3: Authorities only

Test reports proving conformity. Only notified bodies, market surveillance authorities and the Commission can see them.

No. 4: Data of the individual battery

This data belongs to exactly one battery and changes over its life: current capacity and power, state of health, status (original, reused, repurposed, remanufactured, waste) and, where available, charge cycles and negative events. It is visible to persons with a legitimate interest, for example the buyer of the battery or a business acting on their behalf.

Who exactly has a "legitimate interest"

This is defined by an implementing act under Art. 77(9), which had not been adopted by October 2026. The draft names repair, repurposing and remanufacturing businesses, treatment facilities, recyclers, and the lawful buyer of the battery and third parties acting on their behalf.

What really has to be filled in from 18 Feb 2027

Not every field in Annex XIII is mandatory on the start date. Carbon footprint data, recycled content and the due diligence report only follow once the related acts apply. The Commission guidance on data points (version 2.0) and the reference data model of the BatteryPass-Ready consortium mark the mandatory scope per battery category. Batterypass Online asks for exactly that scope.

Lifetime of the passport

The passport must remain available even if the responsible economic operator no longer exists (Art. 78). It only ends once the battery has been recycled (Art. 77(8)). Reuse or repurposing creates a new passport linked to the original one (Art. 77(7)).