Battery Passport Data Attributes

Battery passport preparation is becoming a major compliance and data management priority for companies placing batteries on the European market. It is not only a regulatory task. It is also a product data, sustainability, quality, supplier management, and lifecycle information challenge.

The Battery Pass-Ready Data Attribute Longlist v1.3, dated March 2026, provides a structured overview of 100 battery passport data attributes. These attributes are grouped into seven main categories and linked to important implementation elements such as applicability, access rights, data format, static or dynamic behaviour, and granularity.

For businesses, the key question is not only “Which data is required?” The more important question is: “How can we collect, structure, verify, update, and control this data in a reliable way?”

This guide explains the battery passport data attributes in practical business language and shows how companies can use the longlist to start preparing for battery passport implementation.

5. Battery Materials and Composition Attributes

The battery materials and composition category includes 5 attributes. These attributes describe the chemistry, raw materials, and substance-related information connected to the battery.

Attributes included in this category

Why these attributes matter

Materials and composition data is central to battery compliance, sustainability, safety, and circularity. It supports transparency on what the battery contains and helps inform downstream handling, recycling, safety management, and due diligence.

This category is often supplier-dependent. Companies may need structured declarations from cell suppliers, material suppliers, or battery manufacturers. The data may also be sensitive, so access rights and confidentiality controls should be considered early.

Practical business guidance

Companies should create a controlled process for collecting materials and composition data from internal engineering systems and suppliers.

A practical approach should include:

• Defining the approved source of truth for battery chemistry
• Mapping critical raw materials by battery model or product family
• Collecting structured data for cathode, anode, and electrolyte materials
• Connecting hazardous substance information with existing material compliance processes
• Keeping evidence for substance impact information
• Aligning supplier declarations with internal product data records

Likely internal data owners

6. Circularity and Resource Efficiency Attributes

The circularity and resource efficiency category includes 15 attributes. These attributes support dismantling, repair, spare parts, recycled content, renewable content, collection, second life, and end-of-life treatment.

Attributes included in this category

Why these attributes matter

Circularity attributes help make batteries easier to handle responsibly after use. They support dismantling, spare part identification, safe removal, end-user guidance, separate collection, second-life preparation, and end-of-life treatment.

The recycled and renewable content attributes are also important because they require quantitative data on material shares. These values may depend on supplier information, material traceability, and production records.

Practical business guidance

Companies should manage circularity attributes as part of product design, service, recycling, and sustainability planning.

A practical approach should include:

• Preparing clear dismantling and disassembly information
• Linking component part numbers to controlled product data
• Identifying approved sources of spare parts
• Defining safety measures for removal and handling
• Collecting recycled content data for nickel, cobalt, lithium, and lead where applicable
• Managing renewable content share data in a structured format
• Preparing clear end-user information for waste prevention and separate collection
• Coordinating with recycling, service, and second-life partners where relevant

Likely internal data owners

7. Performance and Durability Attributes

Performance and durability is the largest category in the longlist, with 42 attributes. These attributes describe the technical performance, state, degradation, lifetime, efficiency, resistance, temperature exposure, and negative events of the battery.

This category is especially important because many attributes are technical, measurable, and may need to be updated over time.

Attributes included in this category

Why these attributes matter

Performance and durability attributes provide insight into the battery’s technical condition and expected behaviour. They support transparency on capacity, energy, power, degradation, efficiency, resistance, lifetime, temperature exposure, and significant negative events.

These attributes can also be more difficult to manage than static product data. Some may be available at the time the battery is placed on the market, while others may change during the lifecycle of the battery.

What Is the BatteryPass-Ready Data Attribute Longlist?

The BatteryPass-Ready Data Attribute Longlist is a structured reference document for battery passport data preparation. It maps battery passport attributes against regulatory and standardization references and provides implementation-relevant details.

The longlist includes information such as:

• Attribute category
• Attribute sub-category
• Attribute name
• Short definition or understanding
• Regulation or standardization reference
• Unit of attribute, where applicable
• Expected data format
• Access rights
• Static or dynamic data behaviour
• Update requirements for dynamic data
• Granularity level
• Pack, module, and cell-level relevance

This makes the document useful for companies that need to move from general regulatory awareness to practical implementation planning.

The workbook also notes that requirements may still be altered or adjusted through regulatory and standardization processes. This means companies should treat the longlist as a strong readiness tool while continuing to monitor future updates.

Overview of the 100 Battery Passport Attributes

The longlist includes 100 attributes across seven main categories.

The largest category is performance and durability, with 42 attributes. This shows that battery passport readiness is not only about documentation. It also requires reliable technical and lifecycle data.

Battery Categories Covered by the Longlist

The workbook maps data attributes across four battery categories:

• EV batteries
• LMT batteries
• Other industrial batteries above 2 kWh
• Stationary batteries above 2 kWh

The longlist uses the following applicability logic:

Companies should begin by identifying which battery category applies to each product. This helps determine which attributes are mandatory, which are linked to developing standards, and which are voluntary or recommended.

Battery Passport Attribute Categories Explained

1. Identifiers and Product Data Attributes

The identifiers and product data category includes 20 attributes. These attributes create the foundation of the battery passport because they identify the passport, the battery, the manufacturer, the economic operator, and core product information.

Attributes included in this category

Why these attributes matter

These attributes are essential because they make the battery passport traceable. Without reliable identifiers, companies may not be able to connect the passport to the correct battery, battery model, manufacturer, facility, or economic operator.

They also help define whether a passport is active, archived, inactive, or marked for deletion. This is important because the passport is not only a one-time record. It may need to reflect changes over time, especially when the battery is reused, repurposed, remanufactured, recycled, exported, or linked to another passport status.

Practical business guidance

Companies should treat identifier and product data attributes as the starting point of battery passport implementation.

A practical approach should include:

• Creating a clear battery identifier strategy
• Linking each battery passport to the correct battery item or product identifier
• Ensuring each battery model has a consistent model identifier
• Connecting serial numbers to batch, production, and traceability systems
• Keeping manufacturer, facility, and operator information controlled and up to date
• Defining who can update DPP status and latest update timestamps
• Making sure battery category and battery mass are stored in structured product data systems

Likely internal data owners

2. Symbols, Labels and Documentation of Conformity Attributes

This category includes 7 attributes. These attributes help users, authorities, and other stakeholders understand required labels, symbols, conformity evidence, and safety-related documentation.

Attributes included in this category

Why these attributes matter

These attributes support transparency, safety, and verification. They help users and authorities understand how the battery should be handled, what labels mean, and whether supporting conformity documentation is available.

They are also important because battery passport data should not be disconnected from physical product labels and compliance documentation. The information in the passport should be consistent with what appears on the battery, packaging, technical documentation, and conformity files.

Practical business guidance

Companies should review whether label and documentation data is already centrally managed. In many organizations, this information may be spread across regulatory affairs, quality, product compliance, technical documentation, and packaging teams.

A practical approach should include:

• Checking that labels and symbols are consistent across product documentation and passport data
• Keeping EU declaration of conformity documents controlled and version-managed
• Ensuring test report results can be linked to the correct product or battery model
• Defining how extinguishing agent information is approved and maintained
• Making sure public-facing information is clear and understandable

Likely internal data owners

3. Battery Carbon Footprint Attributes

The battery carbon footprint category includes 8 attributes. These attributes focus on the carbon footprint of the battery and the contribution of different lifecycle stages.

Attributes included in this category

Why these attributes matter

Carbon footprint data is one of the most visible parts of the battery passport. It connects product compliance with climate impact, lifecycle assessment, supplier data, and public-facing sustainability information.

The category is also operationally challenging because carbon footprint information often depends on multiple internal and external data sources, including materials, production processes, energy use, logistics, and end-of-life assumptions.

Practical business guidance

Companies should not treat carbon footprint attributes as a last-minute reporting exercise. These attributes usually require early coordination between sustainability, procurement, engineering, manufacturing, and supplier teams.

A practical approach should include:

• Identifying which team owns carbon footprint methodology and data
• Mapping lifecycle stage contributions clearly
• Keeping the public carbon footprint study link controlled and reviewed
• Ensuring carbon footprint values are linked to the correct battery model, manufacturing site, and calendar year where relevant
• Aligning supplier data collection with lifecycle assessment needs
• Maintaining evidence and assumptions behind reported values

Likely internal data owners

4. Supply Chain Due Diligence Attributes

This category includes 3 attributes. Although it is the smallest category by number of attributes, it is highly important because it connects battery passport data with responsible sourcing and supply chain transparency.

Attributes included in this category

Why these attributes matter

Supply chain due diligence attributes help demonstrate that the company has considered sourcing-related risks and assurance mechanisms. These attributes may rely heavily on supplier input, external assurance, procurement processes, and responsible sourcing documentation.

The challenge is that this data may not sit in product systems. It may be held by procurement, sustainability, responsible sourcing, legal, or compliance teams.

Practical business guidance

Companies should create a clear process for collecting and validating supply chain due diligence information.

A practical approach should include:

• Identifying which suppliers must provide due diligence-related data
• Linking due diligence information to the correct battery, battery model, or supply chain scope
• Storing reports and assurance information in a controlled evidence system
• Defining how recognised scheme assurance information is reviewed
• Maintaining traceability between supplier declarations and passport data
• Monitoring whether supply chain information changes over time

Likely internal data owners

Practical business guidance

Companies should separate performance and durability attributes into two practical groups:

1- Initial technical data, such as rated capacity, certified usable battery energy, nominal voltage, original power capability, initial round trip energy efficiency, initial self-discharge rate, initial internal resistance, and expected lifetime.

2- Lifecycle and dynamic data, such as remaining capacity, remaining usable battery energy, state of charge, remaining power capability, remaining round trip efficiency, current self-discharge rate, number of full cycles, energy throughput, capacity throughput, temperature exposure, deep discharge events, overcharge events, and accident information.

This distinction is important because initial technical data may come from engineering, testing, and certification records. Dynamic lifecycle data may require battery management systems, service data, operational records, or other update mechanisms.

A practical approach should include:

• Identifying which performance attributes are available from design and testing records
• Defining which attributes require lifecycle updates
• Connecting technical data to the correct battery model or individual battery
• Establishing measurement and calculation rules
• Ensuring values use consistent units and formats
• Defining how battery status, remaining capacity, state of charge, and event data are updated
• Coordinating between engineering, quality, service, and data systems

Likely internal data owners

Cross-Cutting Implementation Requirements

Understanding the attributes is only the first step. Companies also need to structure the data correctly.

Static and Dynamic Battery Passport Data

The workbook classifies 78 attributes as static and 22 as dynamic.

Static data is generally created or confirmed at a specific point in time and does not change regularly. Examples include manufacturer information, battery chemistry, battery mass, manufacturing date, warranty period, labels, conformity documents, and many product-level data points.

Dynamic data changes or may need updating during the battery lifecycle. Examples include:

• Date-time of latest update of DPP
• Unique battery passport identifier where archiving is involved
• Battery status
• Remaining capacity
• Remaining usable battery energy
• State of charge
• Remaining power capability
• Remaining round trip energy efficiency
• Current self-discharge rate
• Number of full charging and discharging cycles
• Energy throughput
• Capacity throughput
• Temperature information
• Number of deep discharge events
• Number of overcharge events
• Information on accidents

Practical takeaway

Companies should not manage all attributes in the same way. Static data can often be managed through product master data, technical documentation, and compliance records. Dynamic data may require update rules, lifecycle data systems, battery management system input, or service processes.

Data Formats: Prepare for Machine-Readable Reporting

The longlist includes several data formats:

This means companies should avoid managing battery passport information only in unstructured documents or spreadsheets. Data should be stored in structured fields, with consistent formats and controlled units.

Practical takeaway

A battery passport data attribute should be managed in a format that can be validated, updated, and shared digitally. Evidence documents may still be needed, but the passport data itself should be structured.

Access Rights: Not All Battery Passport Data Is Public

The workbook identifies four access rights groups:

This is important because some data can be public, while other data may need restricted access.

Practical takeaway

Companies should classify each attribute by access rights before publishing or sharing battery passport data. This helps protect sensitive technical, commercial, supplier, and compliance information.

A practical access control process should define:

• Which attributes are public
• Which attributes are restricted
• Which stakeholders can access restricted data
• Who approves publication or disclosure
• How supplier-sensitive information is protected
• How evidence is shared with authorities or notified bodies where required

Granularity: Model, Individual Battery, Batch and Site Level

The longlist includes different granularity levels.

This means some data applies to the battery model, some to the individual battery, and some to production context such as calendar year and manufacturing site.

Practical takeaway

Companies should avoid creating a flat data model. Battery passport implementation should reflect the correct data hierarchy.

A practical structure should consider:

• Battery model
• Battery batch or calendar year and manufacturing site grouping
• Individual battery
• Pack-level data
• Module-level data, where applicable
• Cell-level data, where applicable

Practical Battery Passport Readiness Roadmap

Step 1: Define the Product Scope

Start by identifying which battery categories apply to your products.

Questions to answer:

• Do we place EV batteries, LMT batteries, industrial batteries above 2 kWh, or stationary batteries above 2 kWh on the market?
• Which products are in scope first?
• Which battery models and individual battery identifiers are already available?
• Which data is stored internally and which depends on suppliers?

Step 2: Create a Battery Passport Attribute Register

Convert the longlist into an internal working register.

The register should include:

Step 3: Assign Data Owners

Battery passport data requires cross-functional ownership.

Every attribute should have a named owner, source system, evidence location, and update process.

Step 4: Identify Supplier Dependencies

Many battery passport attributes may depend on supplier input, especially for:

• Battery chemistry
• Critical raw materials
• Cathode, anode, and electrolyte materials
• Hazardous substances
• Recycled content shares
• Renewable content share
• Supply chain due diligence information
• Third-party scheme assurance
• Carbon footprint lifecycle data
• Component part numbers and spare parts information

Companies should create structured supplier data request templates instead of collecting information through informal emails.

Step 5: Prioritize Gaps by Risk and Readiness

Not all gaps should be handled with the same urgency. Companies should prioritize attributes based on applicability, mandatory status, supplier dependency, dynamic behaviour, access rights, and evidence availability.

A useful prioritization model is:

Step 6: Build Evidence and Version Control

Battery passport data should be supported by reliable evidence. This may include test reports, declarations, supplier data, technical documents, carbon footprint studies, conformity documents, and controlled product records.

Companies should define:

• Where evidence is stored
• Who approves evidence
• Which version is current
• How evidence links to each attribute
• How updates are recorded
• How archived passport information is retained

Practical Battery Passport Attribute Checklist

Common Mistakes to Avoid

Treating the battery passport as only a compliance document

The longlist shows that battery passport readiness is also a data governance project. Companies need reliable systems, owners, evidence, and update processes.

Focusing only on public information

Some attributes are public, but others are restricted. Access rights must be considered from the beginning.

Ignoring dynamic attributes

Dynamic data such as remaining capacity, state of charge, battery status, cycle count, throughput, temperature information, and negative events may need lifecycle update processes.

Underestimating supplier data needs

Materials, recycled content, due diligence, and carbon footprint attributes may depend heavily on supplier information.

Using unstructured spreadsheets as the final solution

Spreadsheets can help with early gap assessment, but battery passport implementation should move toward structured, validated, machine-readable data.

Assigning ownership too late

Without clear data owners, attributes may remain incomplete, inconsistent, or unsupported by evidence.

How ComplyMarket Can Support Battery Passport Readiness

ComplyMarket can support companies by helping them turn the BatteryPass-Ready Data Attribute Longlist into a practical readiness roadmap.

Support can include:

• Mapping battery passport attributes to the company’s battery categories and product portfolio
• Identifying mandatory, standardization-driven, and voluntary attributes
• Creating a structured battery passport attribute register
• Assigning internal data owners across compliance, sustainability, engineering, procurement, quality, and product teams
• Identifying missing data and supplier dependencies
• Preparing supplier data request structures
• Supporting evidence collection and documentation workflows
• Classifying access rights for public and restricted data
• Separating static and dynamic data requirements
• Preparing data governance processes for updates and version control
• Helping companies monitor changes as regulatory and standardization processes evolve

The goal is to make battery passport preparation practical and manageable. Instead of reacting late to fragmented data requests, companies can build a structured roadmap, close gaps step by step, and prepare for more transparent battery value chains.