Mandatory fields, explained one by one
Annex XIII is not one list with one deadline. Each field has its own article, its own deadline and its own evidence. We explain them individually — starting where we see the most confusion.
Fields covered: 51 of 51 in the rulepack
Battery carbon footprint in the passport: when it actually falls due
The carbon footprint declaration has four different deadlines by battery category, and all of them are conditional.
Annex XIII(1)(c) conditionalRecycled content in batteries: why you do not owe this yet
The share of recycled cobalt, lithium, nickel and lead falls due 18 August 2028 — 2033 for LMT batteries — not at the passport deadline.
Annex XIII(1)(e) already appliesBattery state of health (SoH): an obligation running since 2024
State-of-health data must have been in the battery management system since 18 August 2024. Most obligated parties do not know this.
Annex XIII(4)(b) -> Annex VII, Part A due 18 Feb 2027EU declaration of conformity for batteries: what belongs in it
The declaration under Article 18 attests compliance with Articles 6 to 10 and 12, 13 and 14.
Annex XIII(1)(r) already appliesBattery performance parameters: an obligation running since August 2024
The document with electrochemical performance and durability values has been mandatory since 18 August 2024.
Annex XIII(4)(a) -> Annex IV, Part A(1) laterBattery due diligence: who is exempt, and who is already late
Companies under EUR 40 million net turnover are exempt from the whole chapter under Article 47.
Annex XIII(1)(d) due 18 Feb 2027Hazardous substances in a battery: the field asks about everything but three
Annex VI requires hazardous substances “other than mercury, cadmium or lead”, because those three are already restricted by Annex I.
Annex XIII(1)(a) -> Annex VI, Part A(8) due 18 Feb 2027Critical raw materials above 0.1%: the field the regulation gives no list for
Annex VI requires critical raw materials above 0.1% by weight, yet the regulation never defines the term.
Annex XIII(1)(a) -> Annex VI, Part A(10) already appliesBattery marking: one deadline has already passed, another is not yet fixed
The separate collection symbol has been mandatory since 18 August 2025 without exception.
Annex XIII(1)(q) due 18 Feb 2027Dismantling information: six requirements and an open question about who may see it
Annex XIII requires exploded diagrams, disassembly sequences, fastening techniques, tools, warnings and cell layout.
Annex XIII(2)(c) due 18 Feb 2027Rated capacity in ampere-hours: the same number in four places
Annex XIII requires rated capacity in Ah, Annex VI requires “capacity”, and Annex IV requires capacity with fade. When these disagree, any reviewer will notice.
Annex XIII(1)(g) due 18 Feb 2027Expected lifetime in cycles: a number without a test is not data
Annex XIII requires expected battery lifetime in cycles “and reference test used”.
Annex XIII(1)(j) due 18 Feb 2027Battery chemistry: the shortest field with the longest shadow
“LFP” or “NMC” is a three-character answer, yet it determines at least four other passport fields.
Annex XIII(1)(a) -> Annex VI, Part A(7) due 18 Feb 2027Round trip energy efficiency: the second value is the trap
Annex XIII requires the initial efficiency AND the efficiency at 50% of cycle-life.
Annex XIII(1)(n) due 18 Feb 2027Battery use data: the only field that does not end at the point of sale
Cycles, negative events, operating conditions and state of charge are collected across the battery's life.
Annex XIII(4)(d) due 18 Feb 2027Manufacturer identification: the regulation does not mean the factory
Under Article 3 the manufacturer is whoever markets the battery under its own name, not whoever built it. An incomplete entry is formal non-compliance.
Annex XIII(1)(a) -> Annex VI, Part A(1) due 18 Feb 2027Battery category: five legal classes, not market segments
The regulation knows five categories, defined by sealing, weight and purpose. “Home storage” is not one of them, and the tie-break rule is limited to Chapter II.
Annex XIII(1)(a) -> Annex VI, Part A(2) due 18 Feb 2027Place of manufacture: which of the three plants is the right one
Cells, modules and pack come from three plants. Elsewhere the regulation keys carbon footprint and recycled content to the plant; here there is one entry.
Annex XIII(1)(a) -> Annex VI, Part A(3) due 18 Feb 2027Date of manufacture: the clock runs from placing on the market, not from the build
A battery built before 18 Feb 2027 is not exempt: Article 77(1) attaches to placing on the market. The same date exists again, more precisely, in the BMS.
Annex XIII(1)(a) -> Annex VI, Part A(4) due 18 Feb 2027Battery weight: the number that decides which category you are in
The 5 kg and 25 kg lines in Article 3 sort batteries into categories. Annex VI gives this field neither a unit nor a rule on what is being weighed.
Annex XIII(1)(a) -> Annex VI, Part A(5) due 18 Feb 2027Capacity: one word carrying two physical quantities
The 2 kWh threshold in Article 77(1) decides scope, Annex XIII asks for ampere-hours, and Annex VI says “capacity” with no unit. Article 3 never defines it.
Annex XIII(1)(a) -> Annex VI, Part A(6) due 18 Feb 2027Usable extinguishing agent: the only public fire data in the passport
Detailed safety measures are restricted in the passport; this sentence is public and goes on the label. The regulation prescribes no method for reaching it.
Annex XIII(1)(a) -> Annex VI, Part A(9) due 18 Feb 2027Material composition in the passport: three questions in one field
The field asks for chemistry, hazardous substances other than three metals, and critical raw materials. The 0.1% threshold belongs to the label, not here.
Annex XIII(1)(b) due 18 Feb 2027Share of renewable content: a field with no definition and no method
The word “renewable” appears exactly once in the whole Regulation — in this field. No definition, no method, no act. What you enter is your own reading.
Annex XIII(1)(f) due 18 Feb 2027Minimal, nominal and maximum voltage: a cell figure is not a pack figure
Three voltages the Regulation never defines. A cell datasheet describes a cell; the passport covers the pack, where the minimum is a BMS cut-off setting.
Annex XIII(1)(h) due 18 Feb 2027Original power capability: the same quantity in two places in the passport
Point 1(i) is public and model-level. The same quantity returns in point 4 as individual-battery data with restricted access.
Annex XIII(1)(i) due 18 Feb 2027Capacity threshold for exhaustion: a field for electric vehicle batteries only
The Regulation confines this field to EV batteries and never defines “exhaustion”. The 90% in the remanufacturing definition and SOCE are not substitutes.
Annex XIII(1)(k) due 18 Feb 2027Temperature range when not in use: the Regulation wants a test it never names
The field asks what the battery withstands when idle and demands a reference test in brackets. Which test that is, the Regulation nowhere says.
Annex XIII(1)(l) due 18 Feb 2027Commercial warranty for calendar life: the one commercial field on the list
This value comes from warranty terms, not from a laboratory. Calendar life is not cycle life and not the expected lifetime under Annex IV.
Annex XIII(1)(m) due 18 Feb 2027Internal cell and pack resistance: two values, two owners
The field asks for cell resistance and pack resistance. The first sits with the cell supplier, the second with you — and no method is prescribed.
Annex XIII(1)(o) due 18 Feb 2027C-rate of the cycle-life test: data about a test, not about a battery
The term “c-rate” appears once in the Regulation and is not defined. The value is public, while the test report it comes from is reserved to authorities.
Annex XIII(1)(p) due 18 Feb 2027Waste prevention in the passport: five terms that are not synonyms
Point (a) of Article 74(1) requires recommendations for extending the use phase and names five separate options. “Second life” answers none of them.
Annex XIII(1)(s) -> Article 74(1)(a) due 18 Feb 2027Separate collection: the field that states the reader's legal duty
Point (b) refers to end-users' obligations under Article 64 — the only one of the six fields that states a statutory duty of the reader, not advice.
Annex XIII(1)(s) -> Article 74(1)(b) due 18 Feb 2027Collection points in the passport: one record, twenty-seven different answers
Point (c) requires take-back and collection points and the treatment available. The answer differs in every Member State and changes without your input.
Annex XIII(1)(s) -> Article 74(1)(c) due 18 Feb 2027Safety instructions for waste batteries: a document for a damaged one
Point (d) requires instructions for handling a waste battery, expressly including lithium risks. Transport documentation describes an intact one.
Annex XIII(1)(s) -> Article 74(1)(d) due 18 Feb 2027Meaning of battery labels: the explanation must match what is printed
Point (e) requires the meaning of labels under Article 13 and on packaging and accompanying documents. Those markings arrive on staggered dates.
Annex XIII(1)(s) -> Article 74(1)(e) due 18 Feb 2027Impact of substances in a battery: “hazardous” here means CLP, not the SVHC list
Point (f) requires the impact of substances on environment and health, including from improper discarding. Hazardous is defined via CLP, not REACH.
Annex XIII(1)(s) -> Article 74(1)(f) due 18 Feb 2027Detailed battery composition: one bill of materials, two access tiers
Annex XIII asks for composition twice — publicly in point 1(b) and in detail in point 2(a).
Annex XIII(2)(a) due 18 Feb 2027Part numbers and spare sources: the one field that goes stale
Point 2(b) of Annex XIII requires part numbers and contact details of sources for replacement spares.
Annex XIII(2)(b) due 18 Feb 2027Disassembly sequences: a procedure, not a drawing — and how deep it must go
The second indent of point 2(c) requires disassembly sequences.
Annex XIII(2)(c) due 18 Feb 2027Fastening techniques: type and number are required, even where nothing can be unlocked
The third indent of point 2(c) requires the type and number of fastening techniques to be unlocked.
Annex XIII(2)(c) due 18 Feb 2027Tools for disassembly: a list that doubles as a self-assessment under Article 11
The fourth indent of point 2(c) requires the tools needed for disassembly.
Annex XIII(2)(c) due 18 Feb 2027Warnings about damaging parts: the one conditional item, and the line to safety measures
The fifth indent of point 2(c) is triggered only if a risk of damaging parts exists. It is not about harm to people — that is a separate item in point 2(d).
Annex XIII(2)(c) due 18 Feb 2027Amount of cells and layout: the regulation counts cells, the industry counts modules
The sixth indent of point 2(c) requires the amount of cells used and the layout.
Annex XIII(2)(c) due 18 Feb 2027Safety measures in the passport: two words with no list, but a defined scope
Point 2(d) of Annex XIII lists nothing. Article 77(2) sets the scope: safety measures to be taken during dismantling — not in-use safety, and not Annex V.
Annex XIII(2)(d) due 18 Feb 2027Results of test reports: the passport tier only regulators see
Point 3 of Annex XIII opens a compartment visible only to notified bodies, market surveillance authorities and the Commission.
Annex XIII(3) already appliesPower and power fade: why the cell datasheet does not cover it
Annex IV defines power as energy over a given period and fade as a drop at rated voltage. A cell datasheet answers half of that, and answers it differently.
Annex XIII(4)(a) -> Annex IV, Part A(2) already appliesInternal resistance: cell, pack and the question of method
The Annex IV definition covers both a cell and a battery but prescribes no method. The same battery measured two ways yields two different numbers.
Annex XIII(4)(a) -> Annex IV, Part A(3) already appliesEnergy round trip efficiency: who decides it is not applicable
The only Part A parameter carrying a where-applicable qualifier. Public point 1(n) carries none, and asks for two values rather than one.
Annex XIII(4)(a) -> Annex IV, Part A(4) already appliesExpected lifetime: cycles, calendar years and the warranty trap
The only Part A parameter that is a forecast. Its two units rest on two different bases, and the point 1(m) warranty period is not the same number.
Annex XIII(4)(a) -> Annex IV, Part A(5) due 18 Feb 2027Battery status: one word that triggers a new passport
Original, repurposed, re-used, remanufactured or waste. Changing this value transfers responsibility and requires a new battery passport.
Annex XIII(4)(c)We add the remaining fields gradually. Each one gets a real explanation — we do not publish empty pages.