Battery passport data points: the Commission's version 2.0 guidance, explained

With just over five months to the first mandatory Digital Product Passport in the EU, the European Commission has refreshed the one document most battery teams are building against. On 21 August 2026 the Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs announced an updated Guidance Document: Digital Batteries Passport, data points by category. The file itself is labelled version 2.0, 15 August 2026, second edition, and was electronically signed on 16 August 2026.

The guidance supports the battery passport required by Regulation (EU) 2023/1542. Under Article 77(1), from 18 February 2027 each light means of transport (LMT) battery, each industrial battery with a capacity greater than 2 kWh and each electric vehicle (EV) battery placed on the market or put into service must have one.

What the document is

It is a single table of 71 data points. For each, it gives the data point name, its legal source in the Batteries Regulation, and its applicability to EV, LMT and industrial batteries. Applicability uses four labels: mandatory, optional, applicable only in certain cases, and not to be filled or displayed as of February 2027.

The Commission is explicit about the status. The text says the document should not be considered representative of the Commission's official position, that it does not extend rights or obligations under the legislation, and that it does not introduce any additional requirement. It also signals that future updates may add definitions, measurement units and reporting formats for individual data points. The announcement does not itemise what changed from the first edition.

The data points you can leave empty in February 2027

This is the practical value of version 2.0. Several Annex XIII data points are marked as not to be filled or displayed when the obligation starts, with a reason given for each:

• Carbon footprint declaration and carbon footprint label (Annex XIII, point 1(c)): the format is still to be specified in an upcoming implementing act. See our earlier note on the carbon footprint declaration.
• Responsible sourcing information from the due diligence report (point 1(d)): required from August 2027 under Article 48(1).
• Recycled content shares of cobalt, lithium, nickel and lead recovered from waste (point 1(e)): to be applied in line with Article 8 and the relevant delegated act.
• Instructions for use in a printable, downloadable format (point 1(t)): application provisions are described as on hold pending adoption of the Omnibus.

Two further rows are marked as not to be filled because they repeat data already captured elsewhere: the material composition entry under point 1(b), and the rated capacity entry under point 1(g), which duplicates the capacity data point.

Where the categories differ

The table is not uniform across battery types. A few examples from the guidance:

• Capacity threshold for exhaustion is mandatory for EV batteries and not to be filled or displayed for LMT and industrial batteries.
• State of certified energy (SOCE) under Article 14 is mandatory for EV batteries only. The other state-of-health entries (remaining capacity, remaining power capability, remaining round trip efficiency, self-discharge evolution, ohmic resistance) are mandatory for LMT batteries, applicable where relevant for industrial batteries, and not to be filled for EV batteries.
• Several performance entries such as reference lifetime tests, round trip efficiency and C-rate are mandatory for EV and LMT batteries but only applicable for some industrial batteries.
• The battery status field (original, repurposed, re-used, remanufactured or waste) is mandatory for all three categories.
• Dynamic use data such as number of cycles, negative events, operating conditions and state of charge are marked as applicable where relevant for all categories.

What to do now

• Re-run your data-point mapping against version 2.0 rather than the first edition, and record the applicability label you are relying on for each field.
• Do not design around the carbon footprint, recycled content and responsible sourcing fields as February 2027 blockers. Track their separate legal triggers instead.
• Remember that the guidance covers content, not access. Which persons can see the non-public tiers of the passport depends on the implementing act under Article 77(9), which is still outstanding.
• Registration of the passport goes through the central DPP registry, which has been live since 20 July 2026.

Primary sources: Commission announcement of 21 August 2026; Guidance Document: Digital Batteries Passport, data points by category, version 2.0; Regulation (EU) 2023/1542.