Most of what's been written about the battery passport this year has covered the big structural pieces — the deadline itself, the registry, who can see what. On 21 August, the Commission published something smaller and more immediately useful: a plain guidance document that goes through the battery passport's data points one by one and says, for each battery type, whether you actually need to fill it in.
What the guidance actually is
The document — “Digital Batteries Passport – data points by category” — brings together 71 data points sourced from the Battery Regulation, principally Article 77 and Annex XIII, and tags each one against three battery categories: EV batteries, light-means-of-transport (LMT) batteries such as e-bike and scooter batteries, and industrial batteries above 2 kWh. For every data point, in every category, it marks one of four states: mandatory, optional, applicable only in specific circumstances, or not to be completed or displayed at all.
That last distinction matters more than it sounds. Annex XIII, read on its own, is one long list that doesn’t make it obvious which fields genuinely apply to, say, an e-bike battery versus an industrial battery pack. The guidance does that sorting for you.
Why this is worth reading now, not just bookmarking
Nothing about the 18 February 2027 date has moved, and this guidance doesn’t add a single new obligation to what the Battery Regulation already requires. What it changes is how much guesswork sits between reading the law and actually structuring your data. If you make an e-bike battery, you don’t need to work out for yourself which of Annex XIII’s fields are genuinely relevant to LMT batteries and which are industrial-only — the guidance has already done that sorting.
- ✓If you already know your battery category, this is the fastest way to get from “what does the law say” to “what do I actually need to collect” — the mandatory/ optional split is stated per category, not buried in a single combined list.
- ✓It doesn’t settle carbon footprint. The carbon-footprint declaration methodology is still a separate, not-yet-adopted delegated act — nothing in this guidance changes that, and any data point tied to it should still be treated as pending rather than something to finalise today.
- ✓It was updated once already, on 15 August. Two of the clarifications in that update touched the applicability date for a handful of individual data points — a reminder that this is a living working document, not a one-off publication. Worth rechecking before you lock in a data schema, not just reading once.
What this doesn't change
The passport is still mandatory from 18 February 2027 for EV, light-means-of-transport and industrial batteries above 2 kWh. Embedded batteries under 2 kWh — phones, laptops — are still outside scope entirely. If you want the fuller picture of what else is required, our guide to collecting supplier material data and the battery passport overview cover the rest. This guidance sits entirely inside the existing framework; it’s a reading aid, not a rule change.
The short version
This isn’t a new deadline, a new obligation, or even, by the Commission’s own description, an authoritative reading of the law. It’s a practical sorting tool that turns one long Annex into a per-category checklist — which is exactly the kind of thing worth reading before you start structuring supplier data, not after.