---
title: 'Who sees what: public, restricted and authority data'
deck: A battery passport has three audiences, and each sees a different part of it. How the access levels work, what sits in each, and what never goes in the passport at all.
description: The three access levels of the EU battery passport under Art. 77 and Annex XIII, what data sits in each, who has a legitimate interest, and what stays out.
category: Technical
date: '2026-10-31'
image: /assets/tiles/b-3-3.jpg
order: 7
---

Scan a battery's QR code and you see part of its passport, not all of it. The regulation splits passport content into levels by audience (Art. 77(2) and (3), Annex XIII). Getting this right matters twice: it decides what your competitors can read, and it decides how your system has to be built.

## The three levels

| Level | Who | Annex XIII |
|---|---|---|
| Public | Anyone with the QR code or the passport address | Point 1 |
| Legitimate interest | Repairers, remanufacturers, second-life operators, recyclers and others the Commission defines | Points 2 and 4 |
| Authorities | Market surveillance authorities, notified bodies and the Commission | Points 2 and 3 |

**Public** information is mostly about the model: manufacturer and address, battery type and model, chemistry and electrolyte type (not exact formulations), capacity, voltage and weight, expected life, warranty, recycled-content shares, labels and symbols, collection information, a due diligence summary and the EU declaration of conformity. It is free to access.

**Legitimate-interest** information covers the detail a repairer or recycler needs: detailed composition of the electrodes and electrolyte, part numbers and supplier contacts for spare parts, dismantling instructions and safety measures (point 2), and the individual battery's data (point 4): state of health, status (original, repurposed, re-used, remanufactured or waste), cycle counts, negative events and operating conditions.

**Authorities** additionally see the test reports that prove compliance (point 3).

Private owners don't get the restricted levels, even for their own battery.

## The missing piece: who has a legitimate interest

The regulation names the kinds of party with a legitimate interest, but leaves the detail (who exactly qualifies, what they can see and how they may reuse it) to a Commission implementing act under Art. 77(9). It was due by 18 August 2026 and as of October 2026 hadn't been adopted. There is no finished way yet to verify who should get in.

Don't wait for it to design the structure. Separate the levels in your data model now, and make sure restricted fields never reach the public page at all, not even hidden in its source code.

## What doesn't go in the passport

The passport is not a disclosure of everything. These stay out:

- manufacturing processes and process parameters;
- exact formulations of additives, binders and coatings;
- prices, margins and costs;
- supplier contracts;
- internal quality data.

The technical documentation under Annex VIII also stays with you and your notified body, outside the passport.

The flip side: Annex XIII fields can't be filled with ranges or averages to protect commercial information. Trade-secret protection mainly applies to the due diligence report, not to mandatory passport fields. And for carbon footprint data, battery-specific materials need plant-specific primary data, not database averages.

## Designing for it

- Tag every field with its level when you build the data model, not when you publish.
- Keep model-level data (the same for every unit) apart from unit-level data (changing per battery), because they sit at different levels and change at different speeds.
- Decide who updates what, and give each party access only to its own section.
- Plan for the passport to stay available at every level even if your company or your provider stops operating (Art. 78(e)).

## FAQ

### Can anyone see all of a battery passport?

No. The public sees Annex XIII point 1. More detailed composition, dismantling and individual battery data is restricted to parties with a legitimate interest, and test reports to authorities.

### Who counts as having a legitimate interest?

The regulation names repairers, remanufacturers, second-life operators and recyclers, among others. A Commission implementing act will define it precisely; as of October 2026 it hadn't been adopted.

### Do we have to publish our battery formulations?

No. The public level shows chemistry and electrolyte type, not exact formulations. Detailed composition is restricted, and manufacturing processes, prices and contracts stay out of the passport.

## Sources

- [Battery passport data access rights](https://dpphero.com/en/blog/battery-passport-data-access-rights), DPP Hero
- [When is a battery passport mandatory?](https://dpphero.com/en/blog/battery-passport-mandatory-when), DPP Hero
- [Regulation (EU) 2023/1542](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023R1542), EUR-Lex