Reading the 71 data points: what the Digital Battery Passport needs in February 2027

The European Commission published its data point guidance in August 2026; the latest version, 3.2, is dated 19 October 2026. It lists 71 data points with their legal source and shows, for each of three battery categories, whether a data point is mandatory, optional, applicable only in certain cases, or not to be filled in or displayed as of February 2027. The guidance adds no legal obligations and does not represent the Commission’s official position. The Commission notes that later versions may add definitions, units and formats.

Four groups by who can access them

Items 1–45, public: including the unique identifier, the party responsible for the passport, manufacturer, battery category, place and date of manufacture, weight, capacity, chemistry, voltage, power, lifetime, internal resistance, a link to the declaration of conformity and waste battery information.
Items 46–49, for persons with a legitimate interest, notified bodies, Member State authorities and the Commission: detailed composition, part numbers and sources of spares, dismantling information and safety measures.
Item 50, only for notified bodies, Member State authorities and the Commission: results of test reports proving compliance.
Items 51–71, for persons with a legitimate interest, specific to the individual battery: including performance and durability parameters, state of health, battery status, number of cycles, negative events such as accidents, and periodically recorded temperature and state of charge.

Exactly who counts as a person with a legitimate interest will be set by the implementing act under Article 77(9).

Items not filled in as of February 2027

Items 16 and 25: these repeat other data points, so they are not filled in separately.
Items 17 and 18, carbon footprint declaration and label: the format is still to be set by an implementing act.
Item 19, responsible sourcing information: the related due diligence obligations apply from August 2027.
Items 20–23, recovered cobalt, lithium, nickel and lead content: these apply as envisaged by Article 8 of the Regulation.
Item 45, instructions for use: the application provisions are on hold pending adoption of the Omnibus.

Not filled in yet does not mean no preparation is needed. Carbon footprint, recovered content and responsible sourcing all rely on supply chain data, which takes time to build up.

Main differences between the three categories

State of health: EV batteries report the state of certified energy (SOCE, item 61); LMT batteries report remaining capacity and related values (items 62–66); for industrial batteries, items 62–66 apply only to stationary battery energy storage systems with a battery management system.
Item 33, capacity threshold for exhaustion: only EV batteries fill this in.
Industrial batteries: lifetime in cycles (items 31 and 32) and round trip efficiency (items 36 and 37) apply only to some batteries, and items 51–60 mainly concern rechargeable batteries.
Items 68–71 (number of cycles, negative events and periodically recorded operating information): for all three categories, these apply once the battery starts to be used.

Model information and individual battery information

Unless the guidance says otherwise, information relates to the battery model; items 51–71 relate to the individual battery. Items 51–60 may need updating when the battery’s status changes, for example after repurposing or remanufacturing, and items 68–71 come from actual use. A project therefore needs to settle early which data comes from specifications and test reports, which comes from the battery management system, and who updates each.

How to use the guidance

Take one representative model and go through the 71 data points, marking which apply.
Record a source for each: specification, test report, battery management system or supplier.
Split the gaps into those to close by February 2027 and those for later phases.
The guidance is still being updated, so check for the latest version before entering data.

Official sources

This article helps with project preparation and is not legal advice. Refer to the official text and professional advice for specific obligations.