Key facts
- EU battery passports apply from 18 February 2027 to covered new EV batteries, LMT batteries and industrial batteries above 2 kWh.
- The Commission published a revised 71-data-point guidance document in October 2026; applicability differs across fields and battery categories.
- The law provides different access levels for the public, authorities and parties with legitimate interests.
- The Commission says carbon-footprint, recycled-content and due-diligence information will not all be required at the February 2027 start.
Quick answer: A digital passport is required for qualifying EV batteries placed on the EU market or put into service from 18 February 2027. But the European Commission’s guidance listing 71 data points does not mean that every new battery must display all 71 fields publicly on day one. Some information is restricted, some applies only to certain battery types, and several obligations start later.
What changed in the October 2026 guidance?
The European Commission’s official batteries and digital product passport page identifies a data-point document updated on 19 October 2026. Its notes mention a new data point 40, a merger affecting earlier points 46 and 47, access clarifications for points 46–49, category-specific applicability for 51–66, and additional guidance about histograms for points 70 and 71. That is a change to explanatory guidance, not proof that every field is instantly compulsory.
What must the public be able to see?
Article 77 and Annex XIII of Regulation (EU) 2023/1542 establish distinct audiences. One set of data is open to the general public; further fields are intended for authorities and notified bodies; a separate category can be accessible to people with a legitimate interest. A consumer should therefore not assume that scanning a code will expose production trade secrets or a live engineering diagnostic readout.
Which information is not required immediately?
The Commission’s battery passport FAQ explicitly states that some carbon-footprint, recycled-content and due-diligence disclosures follow different application dates. It also says not all passport fields apply to every category or are required in February 2027. The passport obligation, underlying data obligations, and permission to view each field are three separate questions.
An original six-question checklist for buyers and researchers
- Market date: Was the battery placed on the EU market before or after the applicability date? An older battery does not automatically get a passport solely because it is still in use.
- Battery category: Is this a vehicle traction battery, an LMT battery, or a covered industrial battery? Different rows may apply.
- Record identity: Does the QR code resolve to a record matching the vehicle or battery, rather than an unrelated marketing webpage?
- Public versus restricted: Does an absent field belong to a restricted audience? An empty consumer-facing screen alone cannot prove noncompliance.
- Future-effective obligation: Is the item required now, in certain circumstances, or after a separate legislative date?
- Responsible entity: Who placed the battery on the market and is responsible for maintaining the record? A later repurposing or remanufacturing can change the record’s stewardship.
Two hypothetical checks show why these distinctions matter
Example A: A vehicle’s battery entered the EU market in 2025. You cannot infer from the February 2027 deadline alone that this original battery needed a passport in 2025. Example B: A qualifying new battery is placed on the market in March 2027. It falls within the new passport regime, but the operator still needs to consult the guidance for that battery’s specific mandatory fields and permissible data access. These are illustrations, not claims about any particular manufacturer’s compliance.
What about battery state of health?
State-of-health and other dynamic information can matter for ownership and second-life decisions. The Commission explains that relevant dynamic data may need updates when battery status changes or when repurposing, remanufacturing or recycling is considered. A QR code must not be mistaken for an independent battery condition certificate. For a used-car purchase, obtain an appropriate model-specific diagnostic assessment and documented history in addition to any passport information.
Related reading and official update checks
For the broader legal background, read our EU Battery Passport 2027 introduction. For used batteries, our battery ownership checklist explains ownership questions that a passport alone may not settle. Revisit the Commission’s live guidance page before publishing legal compliance claims, because implementing measures and field formats can change.
Frequently asked questions
Does 71 mean 71 mandatory fields in every passport?
No. The Commission separates mandatory, conditional, optional and future-effective data points, as well as battery-category applicability.
Will every EU EV already on the road receive a passport in February 2027?
No blanket retrofit obligation follows from the date alone. Check when a battery was placed on the market and whether later remanufacturing or repurposing triggers a new obligation.
Reviewed against EU Commission material available on 12 November 2026. This guide is informational, not legal compliance advice.