From seven data categories to one published record

Annex XIII of the Battery Regulation says what a passport must contain. It doesn't say how to structure it. That gap is filled, for now, by DIN DKE SPEC 99100, a specification published by DIN and DKE in February 2025 from the work of the Battery Pass consortium. It is free, in English and not legally binding, but it is the structure most tools and teams use, and it is published as open JSON schemas (the BatteryPass data model).

It sorts every field into seven categories, each with mandatory and optional attributes. EV batteries have the most mandatory fields, industrial batteries above 2 kWh slightly fewer and LMT batteries the fewest. The Commission's 2026 guidance lists 71 data points in total, of which roughly 36 to 53 are mandatory depending on battery type. The Commission's semantic catalogue, expected at the end of 2026, will set the binding data model, so design yours to be mapped onto it.

The steps

Most manufacturers need 6 to 12 months, and nearly all of that is waiting on data from suppliers. Typing the data in takes hours once it exists.

0. Scope. List every battery: type, capacity and when it will first reach the EU market. This tells you which need a full passport and which only a QR code.

1. Identification. Identifier, manufacturer and operator details, site, dates, category, weight and warranty. Usually already in your ERP or PLM system; the work is turning it into typed, validated fields.

2. Materials and composition. Cathode, anode, electrolyte, hazardous substances and critical raw materials, with proportions and origin. This comes from cell suppliers and is usually the slowest step.

3. Carbon footprint. Kilograms of CO₂ equivalent per kWh over the life of the battery, per model and per plant, from your own life cycle assessment. Start early: it depends on value-chain data.

4. Due diligence. Your policy, risk analysis, audit results and the public report, following OECD guidance for cobalt, lithium, nickel and natural graphite.

5. Circularity. Recycled cobalt, lithium, nickel and lead, dismantling information, spare parts and safety information. Minimum recycled content starts in 2031; documenting it starts sooner.

6. Performance and durability. Rated capacity and energy, voltage, power, expected cycle life, self-discharge, internal resistance and state of health, from test protocols and datasheets (and measured values for used batteries).

7. Labelling and publication. Collection and hazardous-substance symbols, extinguishing agent, the declaration of conformity and test reports. Set the access levels before you publish, since the passport is readable from the moment it goes live.

Who owns what

The data comes from several teams: purchasing (suppliers and materials), engineering (technical data), quality (test results) and IT (integration). Name one person who owns the passport overall. If someone outside the company does the work, authorise it in writing; responsibility stays with you.

Gap analysis

Take the full list of data points and mark each one as available, partly available or missing, and where it lives: PIM or ERP for master data, PLM for bills of materials, your own LCA for carbon, suppliers for materials and origin. Master data usually exists already. Material and supplier data usually has to be collected fresh.

When supplier data arrives, check it: flag empty mandatory fields automatically, make sure carbon figures relate to one model at one plant (default values aren't allowed, and plants shouldn't be mixed), catch impossible values such as recycled content above 100%, and record who approved each figure, when and on what evidence.

Pilot one model

Take one battery model all the way, from data collection to a published passport behind a working QR code. Time each step, and use the result as both your template and your cost estimate. Moving every model partway at once tends to leave a pile of incomplete drafts close to the deadline.

Common pitfalls

• Contacting suppliers too late. Start at least six months before you need to publish.
• Free-text fields where typed, validated values are needed.
• Leaving the carbon footprint until last.
• Ignoring recycled-content documentation because the quotas are years away.
• Aiming for the bare minimum instead of a complete, maintainable record.

FAQ

Is DIN DKE SPEC 99100 mandatory?

No. Only Annex XIII of the Battery Regulation is binding. DIN DKE SPEC 99100 is a free, non-binding specification, but it is the structure most battery passport tools use, and the Commission's coming semantic catalogue builds on the same work.

How long does it take to create a battery passport?

Typically 6 to 12 months for a manufacturer, mostly waiting on supplier data. Entering the data takes hours once it has been gathered.

What are the seven categories of the battery passport?

Identification and product data, materials and composition, carbon footprint, supply-chain due diligence, circularity, performance and durability, and labelling and conformity.

Sources

• DIN SPEC 99100 explained, DPP Hero
• How to create a battery passport, DPP Hero
• What is a battery passport?, DPP Hero