October brought several important updates for companies preparing for the EU Digital Battery Passport. The European Commission published new technical documentation for the Digital Product Passport (DPP) Registry, updated its Battery Passport data-point guidance, and released draft rules explaining who can access restricted passport information.
Together, these publications give manufacturers and their technical teams a clearer picture of what they need to prepare for February 2027. They also address some practical questions we get asked a lot: How should battery data be structured? How will company systems connect to the DPP Registry? What authentication methods are needed? And who will be able to access information that isn't publicly available?
However, not every October publication changes a legal requirement. Some simply explain how to implement existing requirements, while others provide guidance or propose rules that have not yet been adopted.
Let’s dive into what changed and what it means for your Battery Passport preparations.
October's Battery Passport updates at a glance
The Commission's October publications cover three main areas: DPP Registry integration, battery data requirements, and access rights.
The October 30 package contains six technical resources:
- API Integration Guide for Economic Operators and OpenAPI Specifications: Explain the Registry interfaces, API operations, submission workflows, and request and response structures.
- Semantic Data Guide and Semantic Data Artifacts: Explain how passport information is structured, interpreted, and validated.
- Service Account Technical Integration Guide: Covers machine-to-machine authentication and access to DPP Registry services.
- Self-Hosted Authentication Guide for Economic Operators: Explains how to secure DPP Registry access to passport information hosted by an economic operator or a provider acting on its behalf.
All six technical resources are available on the European Commission's DPP Resources and Documentation page.
The DPP Registry: New technical guidance for integration
The October 30 publications give technical teams some more concrete guidance on connecting company systems to the DPP Registry.
The API Integration Guide explains the registration workflow, API operations, authentication, and how to handle responses and errors. The accompanying OpenAPI Specifications provide machine-readable definitions of the DPP Registry interfaces, which developers can use when building or generating integrations.
Why does this matter? Well, we know battery information rarely sits in one place. Product data may come from ERP or PLM systems, technical specifications from engineering teams, and performance information from battery management systems. A DPP Registry integration needs to bring the relevant information together in a consistent format.
The new documentation also clarifies important parts of the submission process:
- A submission can contain one Battery Passport item or a batch of up to 100 items.
- Items in the same batch must belong to the same product classification.
- Processing is asynchronous, so submitting a request does not mean the passport has been successfully registered.
- Registration is all-or-none: if any item fails validation, none of the passports in that submission is registered. The invalid entries must be corrected and the complete set resubmitted as a new request.
For companies managing larger battery volumes, this makes data preparation and validation particularly important. Teams need to monitor submission outcomes and resolve errors rather than assuming that an accepted request has completed registration.
Another distinction manufacturers need to keep in mind is that publishing a battery passport and registering it in the EU DPP Registry are not the same thing. A passport may already have its own URL and QR code, but that doesn't mean its registration has been accepted by the DPP Registry. Companies need to check both passport data completeness and the outcome of DPP Registry validation, rather than treating publication as confirmation of compliance.
Understanding the semantic data model
The Semantic Data Guide and its accompanying artifacts address another important part of implementation: making sure different systems interpret battery information consistently.
The package includes resources such as taxonomies, JSON Schemas, SHACL shapes, and JSON-LD contexts. These define shared data concepts, expected structures, and validation rules.
In practice, the changes go beyond field names. The semantic guidance also defines how certain information needs to be represented, from multiple battery chemistry values and language-specific documentation to structured operating-condition and state-of-charge histograms. Manufacturers may already have this information in their systems, but it may need to be reorganized to match the DPP Registry's expected formats.
For manufacturers, this provides a more concrete reference for mapping internal product data to the Battery Passport structure.
For companies already preparing Battery Passports using earlier industry templates, the new semantic guidance is an important reference point. Existing data mappings may still be useful, but they should be reviewed against the Commission's latest data-point guidance and semantic specifications to identify differences in field names, structures, and validation requirements.
Authentication: How can companies connect securely?
The October package also explains two complementary parts of authentication: how company systems connect to the DPP Registry, and how the DPP Registry accesses passport information hosted elsewhere.
Before using the registration integration, the responsible economic operator must complete organization verification in the DPP Registry. For automated access, its administrator creates a service account with the required permissions and registers a public credential. The economic operator remains responsible for protecting and controlling use of the matching private key.
The Service Account Technical Integration Guide explains how automated systems access DPP Registry services. It covers private_key_jwt authentication, credential and key handling, access-token retrieval, and authenticated API calls. This supports integration with company systems and authorized passport platforms.
Company verification and automated API authentication are two separate steps. Economic operators verify their legal identity during initial DPP Registry onboarding (which involves an organization-level credential or qualified verification). However, day-to-day passport submissions do not require an active per-passport digital signature transaction: once onboarded, automated systems authenticate via service accounts using asymmetric key pairs (private_key_jwt). This distinction is critical for manufacturers evaluating integration architecture and third-party provider workflows.
The Self-Hosted Authentication Guide addresses economic operators and providers hosting passport information on their behalf. It explains how the passport host verifies DPP Registry requests and checks authorization before returning protected passport information.
Battery Passport data guidance v3.2: What changed?
On October 19, the Commission published Version 3.2 of its Digital Batteries Passport – Data Points by Category guidance.
The document covers 71 data points and explains their applicability to electric vehicles (EV), light means of transport (LMT), and industrial batteries. It also clarifies expected data formats and access classifications.
One important point here: 71 data points does not mean 71 mandatory fields for every battery. Applicability depends on the battery category and relevant legal requirements.
Updates and clarifications highlighted by Commission:
Let’s take a closer look at some of these changes:
Discharge C-rate is optional across EV, LMT and industrial batteries. It records the discharge rate used in the relevant cycle-life test.
Detailed composition, spare parts, dismantling and safety information belongs to the restricted part of the passport. The updated guidance clarifies access classifications, while the draft access rights regulation specifies proposed legitimate interest groups and permitted uses.
Individual battery performance, durability and state-of-health information applies across EV, LMT and industrial batteries, depending on the field. For industrial batteries, performance and durability requirements generally concern rechargeable batteries. Remaining capacity and related state-of-health information concern stationary battery energy storage systems with a battery management system (BMS). Some measurements are simply qualified by “where possible.”
Operating conditions and state-of-charge information relate to individual batteries and become applicable once the battery starts to be used. The guidance clarifies their representation through histograms, including information about operating temperatures and periodically recorded state of charge.
Usage-generated information may initially be empty for a new battery, while its initial status and applicable performance and durability values must still be provided where required. Not every battery has continuous connectivity or a battery management system capable of providing all operational measurements. Depending on the applicable data requirements, some information may need to be collected through periodic checks or servicing instead. The Commission's guidance does not establish a universal requirement for continuous real-time communication.
What does not need to be included in February 2027?
The guidance also clarifies that some information is not required in the initial February 2027 dataset:
- Carbon footprint declaration and label (DP17 and DP18): Not to be completed or displayed as of February 2027; the relevant format is still to be specified through a future implementing act.
- Instructions for use (DP45): The guidance marks this passport entry as outside the initial February 2027 dataset, pending adoption of the Omnibus proposal. Its final scope and application depend on the legislative outcome.
- Recycled content and due diligence information: These have separate application dates and are not part of the initial February 2027 dataset.
Renewable content: Renewable content is separate from recycled content. Version 3.2 marks the share of renewable content as mandatory across the three passport battery categories.
Manufacturers may still want to collect information linked to later requirements, especially when customers or supply-chain partners already request it. However, collecting additional information internally is different from including it in the DPP Registry's active semantic model. Companies should distinguish between data they prepare for future compliance and the information currently expected for DPP Registry validation.
You can find the complete Version 3.2 data-point guidance on the Commission's Battery Passport page.
Battery Passport access rights: Who can see restricted information?
On October 19, the Commission published a draft implementing regulation on access to and use of certain Battery Passport information.
Article 77 of the Batteries Regulation already distinguishes publicly accessible information, information available to notified bodies, market surveillance authorities and the European Commission, and information available to people and organizations with a legitimate interest.
The October draft specifies the legitimate-interest groups and their permitted uses. It remains a proposal, not an adopted regulation. The consultation period closes on November 16, 2026.
Who would get access under the draft?
Separately, the Batteries Regulation already gives notified bodies, market surveillance authorities and the European Commission access to compliance test reports, as well as detailed material composition, spare-parts information, dismantling information and safety measures.
The draft’s permitted purposes include assessing battery condition and residual value, repair, preparation for reuse, repurposing, remanufacturing and recycling.
Purchasers and third parties acting on their behalf may also use individual battery information to make batteries available to independent aggregators or other market participants.
For legitimate-interest information other than safety measures, downloaded data may be retained only as long as necessary for the permitted purposes. Sharing and publication are restricted, subject to specified exceptions or authorization from the economic operator placing the battery on the market.
Access to safety information remains limited to designated recipients, but those recipients may use, download, share, publish and reuse it without restriction.
For manufacturers, this means access management needs to account for the information being requested, who is requesting it, and the permitted use. These distinctions should be reflected in how passport data is organized and shared.
We cover the proposed access groups and permitted uses in more detail in our article on Battery Passport access rights under the EU’s 2026 draft rules.
What should manufacturers and technical teams do now?
Thankfully, the October publications give companies more specific guidance, but they don't remove the need for preparation. Here are five areas we suggest to prioritize:
1. Review your existing battery data. Identify where required information currently lives across ERP, PLM, engineering, quality, and battery management systems. Map these sources against Version 3.2 and check which data points apply to your battery category.
2. Plan your system integration. Review whether existing systems can provide the necessary information through APIs or whether some data will need to be imported manually or in batches. As we often see with battery data, the challenge isn't always collecting information from scratch. It's bringing together data from systems that were never designed to exchange it in a standardized way.
3. Prepare for data validation. Use the semantic documentation to understand the expected data structures and formats. Test your mappings early so you can identify missing fields and inconsistencies before submitting passport information.
4. Confirm organization verification, authentication and hosting. Check that the responsible economic operator is verified in the DPP Registry and that the relevant users or service accounts have the required permissions. Decide how passport information will be hosted and how your systems will authenticate with Registry services. The new service account and self-hosted authentication guides provide a starting point for these decisions.
5. Plan for restricted data and lifecycle updates. Review how public and restricted information will be managed, and how passport records will stay aligned as batteries are used, repaired, repurposed, or remanufactured. A Battery Passport is not a one-time data submission; some information needs to reflect changes throughout the battery's lifecycle.
What happens next?
We see the October publications as a crucial step toward making Battery Passport implementation more concrete. Manufacturers now have more detailed technical documentation for DPP Registry integration, a clearer breakdown of data-point applicability, and a proposed framework for access to restricted information.
However, some questions remain open. The access-rights regulation is still subject to feedback and adoption, and the Commission may update its technical documentation and data guidance as implementation progresses.
From February 18, 2027, a Battery Passport is required for each EV battery, each LMT battery, and each industrial battery with a capacity greater than 2 kWh when placed on the EU market or put into service.
For manufacturers, the best next step is to use the available guidance to review data readiness, system integration, validation, and lifecycle processes now. The more clearly your data is mapped and connected today, the easier it will be to adapt as the DPP Registry and its supporting requirements continue to develop.
Getting ready for the Battery Passport deadline? See how Minespider can support your implementation and data management.
