Start with an applicability column
Article 77 sets the passport requirement for the covered battery categories and directs you to Annex XIII. The Commission’s version 2.0 guidance, dated 15 August 2026, maps 71 data points to EV, LMT and industrial batteries over 2 kWh. It distinguishes mandatory, optional, conditional and not-needed-as-of-February-2027 entries. The guidance is non-binding and must be read with the relevant legal provisions and acts.
Our recommendation: give each candidate field separate applicability and evidence statuses. For example, “required; awaiting reviewed document” is different from “not currently required; legal condition recorded”. Neither a missing supplier response nor an unsupported estimate should change the legal applicability status. Keep the guidance version used beside your decision.
Source: Regulation (EU) 2023/1542 — scope, passport and Annex XIIISource: European Commission — battery data guidance v2.0, 15 August 2026
Use four access groups as the starting matrix
Annex XIII separates public model information, restricted model information, conformity test evidence and individual-battery information. Article 77 also specifies the permitted authority and legitimate-interest audiences. The following is a practical grouping to design your review; it is not an exhaustive field list or a replacement for the precise access provisions.
Do not assign access solely from a company label such as “recycler” or “customer”. Define the relevant purpose and entitlement. Check the applicable access rules and technical acts before operational deployment, including whether a person may read, download or update a particular information group.
- Public model group — identification and applicable technical/sustainability information; tie the approved value to the correct model and source.
- Restricted model group — detailed composition, spare-part sources, dismantling and safety information; legitimate-interest and authorised public-body access follows Article 77 and Annex XIII.
- Conformity evidence group — results of applicable compliance test reports; the specified notified bodies, market-surveillance authorities and Commission have the relevant access.
- Individual-battery group — applicable performance, state-of-health, status and use records; link information to the actual unit and the permitted legitimate-interest audience.
Source: Regulation (EU) 2023/1542 — scope, passport and Annex XIII
Build one reviewed model record
Operational recommendation: begin with manufacturer identity, model identifiers and the battery specification. Connect the model to its manufacturing configuration, technical reports and applicable declarations. Ask reviewers to verify units, measurement conditions and product coverage rather than merely checking whether a value exists.
Keep summary fields separate from restricted source documents. A public performance value can be supported by evidence that needs controlled access. Where multiple suppliers provide conflicting weights or capacities, retain the disagreement, identify the configuration each value describes and require a decision. Do not average contradictory numbers just to fill a field.
Keep unit history out of the shared model template
Annex XIII includes information specific to an individual battery, and Article 77(7) addresses certain later lifecycle operations and linked passports. A shared model record cannot stand in for the history of every physical unit. Not every candidate lifecycle field necessarily has the same applicability condition or launch timing.
Operational recommendation: define how the unit identifier connects to the approved model and how service events arrive. Record event time, source system, responsible actor and review status. Rehearse a corrected event and a status change. Preserve the original context instead of overwriting all batteries when one unit receives new information.
Source: Regulation (EU) 2023/1542 — scope, passport and Annex XIIISource: European Commission — battery data guidance v2.0, 15 August 2026
Ask suppliers for evidence that can be reused
Our recommended request asks for a value, its unit, the underlying document and the product configuration it covers. Add the issuing organisation, document revision and a contact for clarification. Explain which requested fields are currently applicable and which are only being collected for future preparation, so suppliers can prioritise intelligently.
Use a small matrix row for each field: legal source, applicability condition, model or unit, value and unit, evidence reference, owner, access group, reviewer and update trigger. Give a missing item a concrete next action. This avoids repeating the same broad request when the real problem is one unsigned report or an unclear model reference.
Review publication and maintenance together
Article 78 requires an operating design with appropriate security, integrity, interoperability and continued availability. Publishing all documents as a public download does not recreate that design. Check the legal access requirements alongside the data values before approving a release.
Operational recommendation: test a public scan, an authorised restricted request and a rejected request against the same sample. Review what happens after a correction, staff departure or provider change. Passvanta can support evidence collection, reviewed proposals and versioned preparation records. Confirm lifecycle feeds and required restricted-access behaviour separately before relying on them in a regulated rollout.
Source: Regulation (EU) 2023/1542 — scope, passport and Annex XIII