Regulatory position: ESPR framework in force; product-specific measures continue to develop. View status

Worked example · illustrative and synthetic

Battery passport example: how a future dataset might be organised

An illustrative, synthetic EU battery passport dataset for one LMT example. Not a certified passport or legal determination. Shows Annex XIII groups, evidence, access and missing data.

A battery passport example is a structured dataset — identifiers, Annex XIII information items, evidence, access class and update state — not a QR code and not a certificate. This page walks one synthetic LMT traction battery. It is ILLUSTRATIVE, SYNTHETIC, NOT A LEGAL DETERMINATION and NOT A CERTIFIED PASSPORT. From 18 February 2027, Article 77 requires a passport for each LMT battery, each EV battery and each industrial battery with capacity greater than 2 kWh placed on the EU market or put into service. Item labels come from Annex XIII as recorded in the reviewed battery profile; values are invented for teaching.

Why this example is synthetic

ILLUSTRATIVE and SYNTHETIC mean the SampleCo values are invented. NOT A LEGAL DETERMINATION means nothing here classifies a real SKU. NOT A CERTIFIED PASSPORT means DPPLogic does not issue, host, register or certify passports. Information-item labels are copied from Annex XIII as recorded in the reviewed battery profile. They are not a new mandatory-field list and not the Commission guidance’s 71 rows.

It is

An educational organisation example

One assumed LMT record showing how official information items, evidence, owners, verification states and access classes sit together.

It is not

A certified battery passport

Not a legal finding, not a complete Annex XIII inventory, and not proof that any real battery is in scope.

What this guide covers

This guide walks through one worked example: how a future dataset might be organised, where evidence sits, what missing data looks like, and why a QR code is not the passport. Overview and timing are on the Battery Passport hub. Statutory fields, conditions and the preparation checklist are on Battery passport requirements. Manufacturer duties are on the manufacturer guide.

The synthetic battery — not a real product

Assume, for teaching only, that the pack meets the Article 3(1)(11) LMT definition: a sealed traction battery weighing 25 kg or less for the specified wheeled vehicles, and not an EV battery. LMT has no Article 77 greater than 2 kWh threshold. That threshold belongs to the industrial class. This assumption is not a classification of any real SKU.

The synthetic battery — not a real product
AttributeSynthetic valueWhy it is here
Working nameSampleCo LMT-48-20Fictional placing brand
Assumed legal classLMT — Article 3(1)(11)Passport class without the industrial capacity test
Chemistry labelNMCPublic composition label, not a detailed bill of materials
Rated capacity20 Ah — syntheticAnnex XIII records capacity; the number is invented
Mass12.4 kg — syntheticBelow the 25 kg LMT mass limb; still only an assumption
Placing operatorSampleCo Mobility GmbH — fictionalArticle 77(4) sits with the operator who places the battery
StatusOriginal, not wasteArticle 77(7) and (8) change responsibility after specified operations or waste

Sample dataset organisation

Eight official information items. This is a sample, not Annex XIII in full. Commission August 2026 guidance numbering is GUIDANCE and includes overlapping, conditional and proposed rows. A data value and the evidence that substantiates it are different records. Available on this table is a preparation state, not a conformity finding.

Sample dataset organisation
Information itemIllustrative valueEvidence / ownerVerificationAccess
Manufacturer name, trade name or trademark, and postal contact — Annex XIII 1(a); Annex VI Part A(1)SampleCo Mobility GmbH, 10115 Berlin — SYNTHETICCompany register extract / placing manufacturerVerified internallyPublic model — Annex XIII point 1
Battery category and model, batch, serial or other identifying element — Annex XIII 1(a); Annex VI Part A(2)LMT / SAMPLE-LMT-48-20 / batch B-2027-02 — SYNTHETICType-designation file / manufacturer product dataNeeds legal-class reviewPublic model — point 1
Battery capacity and rated capacity in Ah — Annex XIII 1(a) and 1(g); Annex VI Part A(6)20 Ah rated — SYNTHETICType-test report / manufacturer and test labAvailablePublic model — point 1
Battery chemistry in the public composition information — Annex XIII 1(a) and 1(b); Annex VI Part A(7)NMC — SYNTHETIC labelCell datasheet and SDS / cell supplier and manufacturerAvailablePublic model — point 1
Carbon footprint declaration information — Annex XIII 1(c); Article 7(1) and (5)Not yet populated — Article 7 category-specific later-of triggersImplementing format and calculation file / manufacturerMissing / not yet duePublic — CONDITIONAL
Recovered cobalt, lithium, nickel and lead content information — Annex XIII 1(e); Article 8(1) and (4)Supplier neededRecovered-content statement / cell supplierMissingPublic — CONDITIONAL
Detailed composition, including cathode, anode and electrolyte materials — Annex XIII 2(a)Not shown on this public pageControlled BOM / cell and pack suppliersHeld, restrictedRestricted model — point 2; access entitlements IMPLEMENTING-ACT DEPENDENT
Remaining capacity — Annex XIII 4(b); Article 14(1); Annex VII Part A, stationary/LMT19.1 Ah after 120 cycles — SYNTHETIC use dataBMS export / placing operatorUnverified live feedRestricted individual — point 4; LMT/stationary condition

Download the synthetic battery example

Use the eight rows from the example above in a spreadsheet or a JSON reader. The values are fictional. Missing, conditional and restricted states remain visible. This sample is not the full Annex XIII inventory, a certified passport or a legal determination.

The export was checked against this page on 23 September 2026. Its sources were last checked on 11 September 2026; downloading a copy does not refresh that check. Check the battery requirements reference and applicable current sources before using any legal classification.

Missing data is a first-class state

The recycled-content row is the educational gap: the placing operator still has to request a supplier statement, and Article 8 conditions may mean the item is not yet due for that category.

Missing data is a first-class state
StateWhat to recordWhat not to do
AvailableValue, source, date, ownerTreat the cell as complete forever
Missing / not yet dueThe condition, for example Article 7 later-of datesInvent a footprint to fill the cell
Supplier neededWho was asked, what evidence type, due datePretend the factory already has the passport
Restricted — heldThat the file exists and who may see itPublish Annex XIII point 2 or 4 data as if they were public
Needs legal-class reviewThat Article 3 definitions are not finishedSkip to QR artwork

Worked correction: missing response to recorded review

This separate teaching example follows the recovered-content row. Every value, document, method reference and reviewer action below is invented. The original eight-row dataset stays unchanged.

Use the supplier request workbook to keep the response, evidence and reviewer conclusion separate. Record conflicts and unknowns rather than replacing them with an assumed value.

  • Missing: record “Supplier needed”. Identify the holder and request a statement for the specified component and revision. Keep the Article 8 applicability and timing question open.
  • Received: a fictional response reports a lithium value of 6%. It lacks its calculation basis and covered revision. Record the response as received and retain those gaps.
  • Reviewed for record consistency: the fictional supplier supplies DEMO-DECL-06 revision 2, identifies the sample model, batch and component revision, and names DEMO-METHOD-1. A fictional reviewer reconciles those references with the response and records the review date.
  • Still unresolved: the method reference is invented and is not an approved statutory method. No real evidence was inspected. The value's accuracy, legal applicability and due date remain unverified. A recorded consistency review does not make the value legally compliant.

Start your own product evidence record

In a DPPLogic workspace, record product facts with their sources, link evidence references and keep human review decisions together. The Free plan covers up to 5 products. Your choices and results on this page are not transferred; start the product record in the workspace.

Create Free workspace See plan details

QR code, unique identifier and passport content

Article 13(6): from 18 February 2027 batteries shall have a QR code. For LMT, EV and industrial batteries greater than 2 kWh the QR provides access to the Article 77 passport. For other batteries it provides other Article 13 information. Article 77(3): the placing operator attributes a unique identifier. A printed QR on a pack that does not yet have accurate, complete, up-to-date information is not a finished passport. Article 77(4) keeps that duty with the placing operator.

QR code, unique identifier and passport content
ObjectWhat it isWhat it is not
QR / data carrierA mark that should resolve to the identifier or passport access pathThe dataset, the evidence, or a certificate
Unique identifierThe operator-attributed identifier for that batteryProof that Annex XIII items are complete
Registry uploadIdentifier and registration data under the battery–ESPR cross-referenceStorage of the full public-and-restricted passport
Passport contentAnnex XIII information, insofar as it applies, with access controlA PDF of the QR artwork

Access classes — public does not mean everything

Annex XIII splits public model information, restricted model information, conformity test reports, and individual-battery information. Article 77(9) set 18 August 2026 for the implementing act on legitimate-interest access. As of the 8 September 2026 official-source review, an adopted final act was not identified. The Commission DPP hub checked on 11 September 2026 still lists that work as indicative Q4 2026. That is a bounded search result, not proof that no later publication exists. Do not publish restricted rows, and do not treat a job title as an access right.

Implementation sequence — not a conformity assessment

Confirm the legal battery class and Article 1 exclusions. Identify who places the battery. Read each Annex XIII item with its condition — do not flatten the list into all fields by February 2027. Separate public model rows from restricted model, authority and individual rows. Record value, evidence, owner and verification date; keep missing and supplier-needed visible. Design the QR and identifier last, not first. Recheck Article 77(9) before exposing restricted information. Use the Annex XIII preparation checklist as the working inventory. This example is not that inventory.

What we are not claiming

  • That SampleCo or any real battery is in or out of scope.
  • That every battery needs an Article 77 passport.
  • That every Annex XIII item is due on 18 February 2027.
  • That Commission guidance rows are extra mandatory fields.
  • That a QR code is the passport.
  • That DPPLogic creates, hosts, registers, issues or certifies passports.
  • That completing a checklist or assessment is a legal determination.
  • That steel or other ESPR groups already have an operational product DPP.

Primary and authoritative sources

Source links are provided for verification. Scope, consolidated versions and later measures should be checked again before implementation or reliance.

Regulatory disclaimer. This content provides general diagnostic and preparation information. It is not legal advice, certification or regulatory approval. Requirements may differ by product category, jurisdiction, market and supply-chain role and may change over time.

Move from this example to the statutory preparation inventory.

The Annex XIII checklist is the working field list. This page is an educational walkthrough, not a legal determination or a certified passport.

Prepare a battery product record

A Free DPPLogic workspace includes the core preparation workflow, for up to 5 products, 1 team seat, 1 product family and 3 suppliers. Requirement packs cover textiles and apparel, and iron and steel (preparation stage), and batteries (research stage, not complete regulatory coverage); other product groups can be recorded without a requirement pack. This link opens DPPLogic sign-in and sign-up; it does not transfer this tool’s answers, files or results. Review product applicability separately.

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