Data, access and durability
A passport does not publish your formulation or supplier list
No. The EU battery passport holds the detailed composition in a restricted tier, and a host may not sell the data on.
No. The battery passport does not put your formulation or your supplier list on a public web page. The European Union (EU) battery law splits the passport data across three groups of readers, and the general public reads one group only.
The battery passport is the first digital product passport in EU law. It is also the only one that names its data fields today.
A wrong answer to this question costs you in two directions. If you believe a passport publishes everything, you hold back data that your importer needs, and your stock stays in a warehouse in Europe. If you believe the opposite, you publish a field that a competitor reads, and you cannot take it back.
Only the battery law separates the readers today
The battery regulation is Regulation (EU) 2023/1542, and it is in force. Its passport duty starts on 18 February 2027. It covers three categories:
- each light means of transport (LMT) battery, such as an e-bike battery
- each industrial battery with a capacity greater than 2 kilowatt hours
- each electric vehicle battery
The Ecodesign for Sustainable Products Regulation (ESPR) is Regulation (EU) 2024/1781. It entered into force on 18 July 2024. It requires a passport to give different actors different subsets of the data, free of charge. It names customers, repairers, refurbishers, remanufacturers, recyclers, market surveillance authorities and customs authorities.
ESPR sets no field list and no reader list for a product group until a delegated act covers that group. The European Commission has adopted no such act. So the battery passport is the only worked example of tiered access that you can read in law today. See batteries for the scope and the battery regulation for the instrument.
If you sell wine, honey or any other food product, no ecodesign passport reaches that product. See food and feed are excluded. Your packaging is a separate product, and the Packaging Regulation (EU) 2025/40 covers it. See packaging.
The design already separates a public view from a regulator view
Article 77(2) of the battery regulation names three groups of readers. Annex XIII holds the data in four numbered points.
| Tier | Who reads it | Annex XIII |
|---|---|---|
| (a) | The general public | Point 1 |
| (b) | Notified bodies, market surveillance authorities and the Commission | Points 2 and 3 |
| (c) | Any person with a legitimate interest | Points 2 and 4 |
The three tiers are not nested. A bigger tier does not contain a smaller one. Tier (b) and tier (c) share point 2, and each one then reads a point that the other cannot read. Who can see what sets out the structure in full.
Tier (c) carries a condition that the short phrase does not state. Article 77(2)(c) ties the legitimate interest to a purpose, and the law names those purposes. They cover dismantling, the detailed composition, and the work of a repairer, a remanufacturer, a second-life operator and a recycler.
Your composition sits in the restricted tier, and your sourcing report does not
Match the thing you worry about to the point that holds it.
| What you worry about | Where it sits | Who reads it |
|---|---|---|
| The materials in the cathode, the anode and the electrolyte | Annex XIII point 2(a) | The authorities, and a person with a legitimate interest |
| The part numbers, and the contacts for sources of replacement spares | Annex XIII point 2 | The authorities, and a person with a legitimate interest |
| The battery chemistry, and the rest of the material composition | Annex XIII point 1(b) | Everybody |
| The responsible sourcing information from the due diligence report | Annex XIII point 1(d) | Everybody |
| Your price, your cost, your margin and your customer list | No point in the register names them | Nobody |
Read the third row twice, because it surprises most exporters. Annex XIII point 1(b) makes the material composition public, and it names the chemistry inside it. Lithium iron phosphate is an example. Only the narrower detailed composition in point 2(a) stays out of public view.
Read the fourth row twice as well. A battery passport carries no supplier list, but it does carry the responsible sourcing information, and that sits in the public tier. The manufacturer must operate a due diligence policy for cobalt, natural graphite, lithium and nickel. Those due diligence duties apply from 18 August 2027.
So the answer splits three ways. Your formulation stays out of public view. Your chemistry does not, and neither does your account of where the material came from. See what data a passport holds for the full list.
A host may not sell your data on
Article 78 point (d) of the battery regulation bars an authorised third-party host from the resale of the passport data and from its re-use.
That limit protects you when you pay somebody else to hold the passport. It is written for the battery passport only. Write the same limit into your own contract for any other product. See what a passport service provider does.
That point answers a commercial question. It answers no question about personal data. See personal data in a passport.
Three limits on that answer
This site has read parts of Annex XIII, and not all of it
Warning: the answer above holds for a battery today. Check each limit below before you rely on it for anything else.
This site has read the text of Annex XIII point 1(b), point 2(a) and point 3. For point 2 it has read the heading and no more. The rest of the field list comes from a register of the rules, which cites the annex point by point.
Warning: a wrong guess about the public tier is the one mistake you cannot reverse. Check your own field list against the annex text before you publish a field.
One reading changes the table above. Annex XIII point 1(b) makes the material composition public, and it names the battery chemistry inside it. Point 2(a) restricts a narrower thing, the materials used in the cathode, the anode and the electrolyte. So your chemistry is public and your detailed composition is not.
Point 3 is now read as well. It holds one item, the results of the test reports, and only the authorities read it.
The re-use rules for a person with a legitimate interest are not settled
Article 77(9) sets the Commission a deadline of 18 August 2026. By that date the Commission must adopt implementing acts. Those acts must say who counts as a person with a legitimate interest. They must also say what that person may download, share, publish and re-use.
The same paragraph tells the Commission to hold access to commercially sensitive information at the minimum necessary. That criterion is in the law today, and it is the one that matters most to you.
This site searched the Official Journal and two Commission registers on 15 August 2026, and found no adopted act. So the third tier gives you a reader whose onward rights nobody has defined. Check the position yourself before you build access control for that tier. See public data versus legitimate interest.
Whatever is public becomes comparable
ESPR Article 14 requires a publicly accessible web portal. That portal lets stakeholders search and compare passport data.
Take a merino jumper, and assume a textile rule applies one day. A buyer in Hamburg can then put your public entry beside a competitor's public entry and read both in one view. Decide the public tier as a commercial question as well as a compliance question. See the EU passport portal.
Ask which tier each field sits in before you agree to supply it
A buyer can ask you for more data than any law requires. Such a request arrives in a purchase order or in a supply agreement, with no regulation behind it.
- Ask the buyer to name the tier for each field they request.
- Ask which rule requires the field. Ask for the article number.
- Supply every field that the law requires. Delay there stops your shipment.
- Question every field that no rule names. Ask what the buyer does with it.
- Ask who may re-use each field, and for what purpose.
- Write the tier and the re-use limit into the supply agreement, field by field.
Steps 1 to 6 cost only time, and they keep their value whatever the implementing act says. See how to agree data duties with your EU importer for the contract work. See if you supply a component when the request comes from a customer instead of a regulator.