Battery passport: who gets to read the restricted data

A text that decides who sees what

The battery passport is not a single document that everyone reads the same way. Annex XIII of Regulation (EU) 2023/1542 arranges its data in four tiers:

Points 1 and 3 are settled by the Regulation. Points 2 and 4 were waiting for an implementing act, the one Article 77(9) required the Commission to adopt by 18 August 2026. That text has been out in draft since 19 October 2026.

The official description of the initiative is explicit about the intent: information relevant to repairing, remanufacturing, repurposing and recycling the battery should be accessible only to those companies and persons with a legitimate interest in it, and the act defines who can access it.

What the draft has to settle, and what stays open

Three questions arise for every data field in points 2 and 4, and the text has to answer them field by field.

Who. The draft lists categories of actors. Feedback published within days asks how an actor proves it belongs to one of them. Vetta Advisory, an independent French consultancy on digital product passports, writes on 26 October that Article 1 names categories but does not say how membership is established. Marklytics, which builds the VoltTrail passport platform, raises the same question on 23 October and asks for a recital setting common principles: identity, role, and a link to the specific battery or model.

What. The Commission's September 2026 FAQ states that the act must specify not only who has access, but how far: download, share, publish, reuse. Those are five distinct rights, and none of them is the same as simply viewing the data.

How. The FAQ adds that the act will not set the detailed authentication mechanism. The system is decentralised, so authentication cannot readily be operated centrally. National registers of recyclers and waste operators are mentioned as a way to confirm the status of different categories of actors.

Why this is a platform problem, not only a legal one

A company hosting passports will have to turn this text into software permissions. In practice that means four things.

1. Permissions per field, not per page. A repairer may need dismantling instructions without access to detailed composition. A model that grants access to "the restricted page" as a block will have to be rebuilt.
2. Roles that outlive the text. The draft's categories can still change before adoption. A role model hard-coded on today's categories will be expensive to fix in January.
3. A record of every access. If the act limits use of data by purpose or over time, proof of compliance runs through logging. A passport that cannot say who read what cannot demonstrate that it respects access rights.
4. An explicit state for empty fields. The FAQ recalls that the registry does not give access to the full passport, and that the operator manages access to the data. An absent field, an empty field and a hidden field are three different states, and the text does not yet say how to tell them apart in the interface.

The calendar, and the gap

The deadline set by Article 77(9) was 18 August 2026. The draft was only published on 19 October 2026, and it is not adopted. The battery passport becomes mandatory on 18 February 2027 for electric vehicle batteries, light means of transport batteries and industrial batteries above 2 kWh.

That leaves four months, four of which are consultation. The September FAQ states that the text is not yet law and that access to points 2 and 4 depends on it. A platform that has to ship in January cannot wait for the final text to design its roles, and cannot freeze them either.

What the first submissions say

Fourteen contributions had been published as of 27 October. They show two concerns.

Recycling actors want to be recognised without ambiguity. Umicore writes on 26 October that timely access to relevant data is essential for the safe handling, treatment and high-quality recycling of end-of-life batteries, and supports recognising recyclers and waste management operators carrying out treatment.

Platform providers want common rules for proof and identification. They worry that the same actor could be recognised by one market surveillance authority and refused by another, for lack of shared principles.

What to do now

1. Map your fields by access tier. Take the data in your passport and attach each item to point 1, 2, 3 or 4 of Annex XIII. That classification will not change, even if the entitled persons do.
2. Separate view, download, share and reuse. They are four different rights in the text, and probably four different permissions in your product.
3. Plan for configuration, not hard-coding. The final text arrives after your design deadline. A role model driven by a table rather than by code will cost you less in February.

To place your product in the timeline, the DPP scope checker gives the applicable date and legal basis in three questions. For the data required by battery category, the battery page details the deadlines.

Sources

• European Commission, Have your say, initiative 16473, Batteries – access rights to certain parts of the battery passport, draft act, feedback from 19 October to 16 November 2026, consulted on 27 October 2026
• European Commission, FAQ, EU Digital Product Passport for Batteries, September 2026 edition, questions 6.3, 6.4 and 6.5
• Regulation (EU) 2023/1542, Article 77(2) and 77(9), and Annex XIII
• European Commission, feedback from Vetta Advisory, published 26 October 2026
• European Commission, feedback from Marklytics (VoltTrail), published 23 October 2026
• European Commission, feedback from Umicore, published 26 October 2026