● Knowledge · 22 Standards

Battery passport standards: which one actually applies

Search for the battery passport standard and you will find a dozen acronyms: DIN DKE SPEC 99100, EN 18219, GS1 Digital Link, IDTA 02035, Catena-X. Only one family of standards is named in law. This guide sorts all battery passport standards by how binding they are and by the layer of the passport they govern.

By Grigor Muradyan · approx. 16 min read · Updated: · Not legal advice
1
Standard family in law
ISO/IEC 15459, Art. 77(3)
8
EN 182xx standards
6 of them cited in the Official Journal
71
Data points
Commission guidance, version 2.0
7
AAS submodels
IDTA 02035 for Catena-X
In brief
  • The law names exactly one family of standards. Article 77(3) requires ISO/IEC 15459 "or equivalent standards" for the QR code and the identifier. Everything else is implementation help, not an obligation.
  • The EN 182xx standards belong to the Ecodesign Regulation. Since 15 July 2026, six of them create a presumption of conformity for product passports under the ESPR. For the battery passport they are the technical yardstick, not the legal basis.
  • DIN DKE SPEC 99100 is not the duty list. It was never binding; the reference target is the Commission guidance with 71 data points in version 2.0 of 15 August 2026. The SPEC stays the free reference work for data structure, definitions and access levels.
  • Catena-X is one route, not a requirement. The Commission mandates no technology. The seven asset administration shell submodels pay off when a customer requires the data space.
02 · EN 182xx

The eight DPP standards, EN 18216 to EN 18246

Since May 2026 there have been European standards for the digital product passport. They come from the ecodesign world and still matter for every battery passport.

They were drafted by the joint technical committee CEN-CLC/JTC 24 "Digital Product Passport - Framework and System", whose secretariat is held by DIN, under the Commission's standardisation request M/604. Six standards appeared on 27 May 2026: EN 18216, EN 18219, EN 18220, EN 18221, EN 18222 and EN 18223. With Implementing Decision (EU) 2026/1736 of 14 July 2026, published on 15 July 2026, their references are in the Official Journal. Two further standards on access rights and integrity belong to the series but, according to CEN-CENELEC and the Commission, are not yet cited.

StandardTitleWhat it governsStatus
EN 18216Data exchange protocolsProtocols and formats that move passport data between systemscited in the Official Journal
EN 18219Unique identifiersIdentifiers for product, economic operator and facility; model, batch or item levelcited in the Official Journal
EN 18220Data carriersThe physical link to the passport: symbology, error correction, print quality, durabilitycited in the Official Journal
EN 18221Data storage, archiving and data persistenceStorage, versions, backups and long-term availabilitycited in the Official Journal
EN 18222APIs for lifecycle management and searchabilityInterfaces to find, resolve, retrieve and maintain passportscited in the Official Journal
EN 18223System interoperabilitySemantic, technical and organisational rules for exchangecited in the Official Journal
EN 18239Access rights, information security, confidentialityWho may see which data and how that is enforcednot yet cited
EN 18246Data authentication, reliability and integrityProtection of passport data against alteration and forgerynot yet cited

The presumption applies to the ESPR, not to Article 77

Decision 2026/1736 is based on the Ecodesign Regulation (EU) 2024/1781. Whoever applies the six standards is presumed to meet its Articles 10 and 11 with their product passport, to the extent the standards cover those requirements. For the identifier and QR code of the battery passport, Article 77(3) of the Battery Regulation remains decisive. Because the battery passport ends up in the same DPP registry and must be interoperable with other product passports under Article 78, the EN standards are still the obvious technical yardstick.

The full texts are paid documents; the German edition DIN EN 18219, for example, runs to 68 pages. For manufacturers this means the standards are mainly a checklist for the software that generates the passport and for the provider that hosts it. They do not change the battery's data sheet.

03 · Layers

Which standard governs which layer of the battery passport

No document covers the whole passport, except the law itself. The standards divide the work by layer, much as the Battery Pass consortium sketched it in its "Technical Standard Stack" back in December 2023.

Which source governs which layer of the battery passport
LayerEU lawEN 182xxDIN DKE SPEC 99100IDTA 02035 / Catena-XGS1 Digital Link
Identifiermain subjectArt. 77(3)main subjectEN 18219not its focusaddressedPart 1main subjectGTIN + AI 21
Data carriermain subjectArt. 13(6), Annex VI Cmain subjectEN 18220not its focusnot its focusmain subjectQR with link
Content and data modelmain subjectAnnex XIIIaddressedEN 18223main subjectdata attributesmain subjectParts 1-7not its focus
Exchange and APIaddressedArt. 78(a)main subjectEN 18216, 18222not its focusmain subjectAAS, data spaceaddressedresolver
Storage and availabilitymain subjectArt. 78(c), (e)main subjectEN 18221not its focusnot its focusnot its focus
Access and confidentialitymain subjectArt. 78(f), Annex XIIIaddressedEN 18239addressedlevel per attributenot its focusnot its focus
Integrity and authenticitymain subjectArt. 78(g), (h)addressedEN 18246not its focusnot its focusnot its focus
Registrymain subjectIR 2026/1778addressedEN 18222not its focusnot its focusnot its focus
Layers as main subject (of 8)74122
Legend
  • main subject
  • addressed
  • not its focus
Our own mapping based on the wording of the regulation, the published scopes of the EN standards, the IDTA guideline and the GS1 specification. The full texts of the EN standards are paid documents and were not evaluated here. Only EU law spans all eight layers.

Three things stand out. First, EN 18219 and GS1 Digital Link overlap on identifier and data carrier. That is not a conflict but the point where an industry standard fills in a standard. Second, neither the EN standards nor GS1 decide which data belongs in the passport; Annex XIII and the guidance do that, worked out as data models in DIN DKE SPEC 99100 and IDTA 02035. Third, access and integrity are governed by the law, but the matching standards EN 18239 and EN 18246 are not yet cited. Anyone implementing access levels today works from Annex XIII and Article 78, not from a harmonised standard.

04 · DIN DKE SPEC 99100

DIN DKE SPEC 99100: what it is and what it is not

The best-known battery passport standard is, strictly speaking, not a standard but a non-binding specification. It does not set the mandatory fields; the Commission's data point list does.

DIN and DKE presented DIN DKE SPEC 99100 "Requirements for data attributes of the battery passport" on 15 January 2025; the edition is dated 2025-02 and is available free of charge from DIN Media. It is based on the content guidance of the Battery Pass consortium, a project of eleven organisations led by Systemiq and supported by the German Federal Ministry for Economic Affairs. The SPEC describes legally required and voluntary attributes: general information, material composition, performance and durability, raw material extraction conditions and carbon footprint.

It was never binding, as no legal act refers to it. For a long time it was nevertheless the best list available. That changed in summer 2026: since 28 July there has been the Commission guidance with 71 numbered data points and their applicability per category, in version 2.0 since 15 August. Anyone who wants to know which field is mandatory on 18 February 2027 looks it up there.

QuestionReference sourceNote
Which fields are mandatory on the deadline?Guidance v2.0, 71 data pointsMandatory per category: EV 47, LMT 50, industrial 32
What exactly does an attribute mean?DIN DKE SPEC 99100 and the guidanceThe SPEC describes attributes in more detail
Who may see which field?Annex XIII, Art. 78; mapping per attribute in the SPECImplementing act on access rights: draft expected in October or November 2026, says the Commission
How detailed must the material composition be?Open1 % (SPEC) or 0.1 % (CEN draft), both reasonable according to the EU FAQ
What is not yet to be filled in February 2027?Guidance v2.0Among others the carbon footprint data and recycled content #20 to #23

The Commission cites the SPEC itself

How useful the SPEC remains is shown by the EU FAQ of September 2026: for the level of detail in material composition it names the 1 % threshold of the DIN SPEC and the 0.1 % threshold of a draft CEN technical specification and considers both reasonable, as long as the entry is more than a chemistry label such as "LFP".

What sits behind the 71 data points and which of them are public is covered in What data goes into the battery passport?

05 · Identifier

ISO/IEC 15459, EN 18219 and GS1 Digital Link

At the identifier, law, standard and industry standard meet head-on. The good news: they do not contradict each other.

ISO/IEC 15459 does not prescribe a particular number. The series requires an identifier to come from a registered issuing agency and to be unique worldwide. GS1 is such an issuing agency. A serialised GTIN, the model number plus the serial number, therefore meets Article 77(3); in GS1 Digital Link both numbers sit as a path in the URL of the QR code.

EN 18219 sets out principles for identifiers of products, economic operators and facilities in the digital product passport: uniqueness, persistence, syntax, granularity, interoperability and openness. Product identifiers are possible at model, batch or item level; the battery passport needs item level, one passport per battery. EN 18220 deals with the data carrier, according to its published scope with symbology, error correction, print quality, durability and placement. In its FAQ the Commission writes that economic operators can create identifiers themselves using one of the options in the relevant standards, or use a commercial service.

Exports from China: two identifiers, one test

In 2026 China published GB/T 47591-2026, a recommended national standard for nameplates, labels and electronic identification of traction batteries. It applies to the Chinese market; the Battery Regulation does not refer to it. For the EU market the only question is whether the QR code and identifier comply with ISO/IEC 15459 or an equivalent standard. The economic operator placing the battery on the EU market is responsible for that, which for imported goods means the importer.

How long GTIN and serial number may be and how the check digit is calculated is covered in GTIN, serial number and check digit; the design rules for the code itself in QR codes on batteries from 2027.

06 · Catena-X

Catena-X battery passport: the asset administration shell IDTA 02035

The automotive industry has a data model of its own, built on the asset administration shell (AAS). It is one route to the battery passport, not a prescribed one.

The Industrial Digital Twin Association (IDTA), Catena-X Automotive Network e. V. and partners of the Battery Pass project published the specification IDTA 02035 "Digital Battery Passport" in February 2026. It distributes the attributes of DIN DKE SPEC 99100 across seven asset administration shell submodels. Three are derived from existing IDTA templates, one extends the template for technical data, and three come from the project "BatteryPass made with Germany". Each submodel has a semantic aspect model under SAMM, so the same data can be read in both the IDTA and the Catena-X world.

PartSubmodelBasisLevel
IDTA-02035-1Digital NameplateIDTA-02006per battery
IDTA-02035-2Handover DocumentationIDTA-02004per model
IDTA-02035-3Product Carbon FootprintIDTA-02023per model and plant
IDTA-02035-4Technical DataIDTA-02003-2-0per model
IDTA-02035-5Product ConditionBatteryPass projectper battery
IDTA-02035-6Material CompositionBatteryPass projectper model
IDTA-02035-7CircularityBatteryPass projectper model

According to IDTA, Catena-X intends to adopt the submodels in its CX-Neptune release, announced for September 2026. The Global Battery Alliance is also working on a passport of its own based on the UN Transparency Protocol, which it describes as interoperable with Catena-X. Both are frameworks for data exchange in supply chains - neither replaces the duties under Article 77.

When Catena-X pays off and when it does not

The Commission mandates no technology: "No specific technology, including blockchains, is mandated", its FAQ says. Catena-X pays off when a customer requires exchange via the data space, typically a vehicle manufacturer towards its battery and cell suppliers. For makers of e-bike batteries, home storage or industrial batteries without such customers, the asset administration shell is an option for later, not a prerequisite for the deadline.

07 · Roadmap

What is still missing before the deadline

The standards landscape only took shape in 2026, and it is not finished yet. Three building blocks are outstanding; all three concern access and the data model, not the identifier.

From consortium paper to obligation: the standards roadmap
  1. 15 December 2023
    Battery Pass: Technical Standard Stack

    The consortium arranges the passport in layers, from identifier to security.

    done1161 days before the deadline
  2. 15 January 2025
    DIN DKE SPEC 99100 presented

    Data attributes of the battery passport, free from DIN Media, edition 2025-02.

    done764 days before the deadline
  3. 4 March 2026
    IDTA 02035: seven AAS submodels

    IDTA, Catena-X and Battery Pass partners, aligned with DIN DKE SPEC 99100.

    done351 days before the deadline
  4. April 2026
    GB/T 47591-2026 in China

    Nameplate, label and electronic identification of traction batteries.

    done
  5. 27 May 2026
    Six EN 182xx standards published

    CEN-CLC/JTC 24 delivers the core standards of the digital product passport.

    done267 days before the deadline
  6. 15 July 2026
    Implementing Decision (EU) 2026/1736

    The six standards are cited in the Official Journal: presumption under the ESPR.

    done218 days before the deadline
  7. 17 July 2026
    Implementing Regulation (EU) 2026/1778

    Rules for the DPP registry, where battery passports are registered too.

    done216 days before the deadline
  8. 15 August 2026
    Guidance with 71 data points, version 2.0

    Mandatory fields per battery category; the non-binding SPEC was never the duty list.

    done187 days before the deadline
  9. September 2026
    EU battery passport FAQ

    No technology mandated, an official data model announced.

    done
  10. September 2026
    Catena-X release CX-Neptune

    According to IDTA, the submodels are to be included as a use case.

    announced
  11. no date
    Implementing act on access rights

    Draft for feedback expected in October or November 2026, says the Commission.

    pending
  12. no date
    EN 18239 and EN 18246 in the Official Journal

    Access rights, security and integrity: not yet cited.

    pending
  13. no date
    Commission semantic repository

    Official data model for the registry, announced without a date.

    pending
  14. 18 February 2027
    Battery passport obligation

    LMT, industrial (over 2 kWh) and electric vehicle batteries, Art. 77(1).

    deadline
The days to 18 February 2027 are computed from the dates. 'Pending' and 'announced' describe the status on 6 October 2026.

The sequence explains the confusion in the market. For more than a year DIN DKE SPEC 99100 was the only tangible document and was therefore quoted as "the standard" for the battery passport. The first harmonised EN standards appeared 267 days before the deadline, the Commission guidance another 80 days later. Still open are the implementing act on access rights, the citation of EN 18239 and EN 18246, and the Commission's semantic repository.

08 · Practice

Which battery passport standards you need by February 2027

The right selection depends less on the battery than on the supply chain you are part of.

Your situationBindingAlso usefulNot needed
Manufacturer of LMT, industrial or storage batteries without data space customersArt. 77 and 78, Annex XIII, identifier under ISO/IEC 15459Guidance v2.0, DIN DKE SPEC 99100 for reference, GS1 Digital LinkCatena-X, asset administration shell
Supplier to a vehicle manufacturerThe same duties as aboveIDTA 02035 and Catena-X where the customer requires it by contractA second data model next to the customer's
Importer of batteries from third countries such as ChinaPassport responsibility under Art. 77(4), identifier under ISO/IEC 15459Request supplier data along the 71 data pointsGB/T 47591 as a replacement for the EU identifier
Software provider and in-house ITArt. 78(a) to (h), Implementing Regulation 2026/1778EN 18216 and EN 18219 to EN 18223; watch EN 18239 and EN 18246-

Four questions for your battery passport provider

1
Which system do you use to assign the identifier?

The answer must be ISO/IEC 15459 or an equivalent standard, such as a serialised GTIN from GS1. An arbitrary database ID is not enough.

2
Which field list is your data model based on?

The Commission guidance with 71 data points in version 2.0, not DIN DKE SPEC 99100 alone.

3
How do the passports get into the registry?

A short link of at most 50 characters per passport, plus an export or interface for registration under Implementing Regulation 2026/1778.

4
Against which full text did you check the EN standards?

An honest 'not yet' beats a seal without a check. Two of the eight standards are not even in the Official Journal yet.

What else matters when choosing is covered in Battery passport software: obligation, requirements and selection.

09 · In Batteriepasswerk

Which standards Batteriepasswerk implements and which not yet

Battery passport software meets standards only as far as it can prove it. That is why we separate what runs today from what is in preparation.

Identifier under Article 77(3)
One GS1 Digital Link QR per battery with a 14-digit GTIN and serial number; format and check digit are validated on save. Models without a GTIN only get a fallback link. It scans, but it is not an ISO/IEC 15459 identifier, and the QR page says so.
ISO/IEC 15459
Field list from the guidance
The readiness check measures every model against the 71 official EU data points and knows three states: met, missing, not yet applicable. Fields that need not be filled on the deadline stay visible instead of silently disappearing.
Guidance v2.0
Registry and interfaces
Every passport has a registry-compliant short link of at most 50 characters; the dashboard tracks verification status and mandate. For ERP and MES there is the REST API v1 with an OpenAPI 3.1 contract.
IR 2026/1778 · Art. 78(a)
Integrity you can recompute
Every version of a passport gets a SHA-256 fingerprint that contains the one of the previous version; a root hash is published daily and can be checked without an account.
Art. 78(g)

What is not there yet

We are preparing the export as asset administration shell submodels for Catena-X; it does not exist today. And we do not claim conformity with the EN 182xx standards as long as we have not checked them against the full text.

How the passport gets into the EU registry is explained in Battery passport registration: the EU DPP registry; how the hash chain works in Audit trail and data integrity in the battery passport. The interfaces are documented on the developer page, and the place of the battery passport within the ESPR in Digital Product Passport (DPP).

10 · FAQ

Frequently asked questions on battery passport standards

Which standard applies to the battery passport?
Exactly one family of standards is named in law: Article 77(3) of Regulation (EU) 2023/1542 requires the QR code and the unique identifier to comply with ISO/IEC 15459-1 to -6 or equivalent standards. Everything else is implementation help: the Commission guidance with 71 data points, the harmonised EN 182xx standards under the Ecodesign Regulation, DIN DKE SPEC 99100 and industry standards such as GS1 Digital Link or the IDTA submodels for Catena-X.
Is DIN DKE SPEC 99100 mandatory?
No. DIN DKE SPEC 99100 is a free specification from DIN and DKE, built on the groundwork of the Battery Pass consortium, and no legal act refers to it. The reference list of mandatory fields per battery category is the Commission guidance with 71 numbered data points, currently in version 2.0 of 15 August 2026. The SPEC remains useful for the definition of individual attributes and for mapping them to public and restricted access levels.
Do EN 18216 to EN 18223 apply to the battery passport?
Not directly. Implementing Decision (EU) 2026/1736 of 14 July 2026 cited six EN 182xx standards in the Official Journal as harmonised standards under the Ecodesign Regulation (EU) 2024/1781; the presumption of conformity covers its Articles 10 and 11. For the identifier and QR code of the battery passport, Article 77 of the Battery Regulation remains decisive. Because Article 78 demands full interoperability with other digital product passports, the EN standards are still the obvious technical yardstick.
Do I need Catena-X for the battery passport?
No. In its battery passport FAQ the Commission does not mandate any particular technology. Catena-X is a data space of the automotive industry; IDTA, Catena-X and partners of the Battery Pass project have published seven asset administration shell submodels for it, specification IDTA 02035. It makes sense when a customer such as a vehicle manufacturer requires exchange via Catena-X. Anyone selling e-bike batteries or home storage meets the obligation without a data space.
Which identifier does the Battery Regulation require for the passport?
A unique identifier per battery, assigned by the economic operator placing the battery on the market. Under Article 77(3) the QR code and the identifier must comply with ISO/IEC 15459-1 to -6 or equivalent standards. In practice this is often a serialised GTIN: GS1 is an issuing agency under ISO/IEC 15459, and GS1 Digital Link writes the GTIN and serial number into the URL of the QR code.
Is there an official EU data model for the battery passport?
Not yet as a finished document. In its FAQ of September 2026 the Commission announced a semantic repository that translates the legal requirements into the technical structure of the DPP registry, but gives no date. Until then the regulation with Annex XIII and the guidance with 71 data points are the basis. DIN DKE SPEC 99100 and the IDTA submodels are data models built on top of them.
11 · Sources

Sources & further reading

Standards sorted, duty clarified

Whether your battery needs a passport on the deadline, the check tells you

Five questions, no sign-up: the free eligibility check tells you whether your batteries need a passport from 18 February 2027 and which of your categories it covers - result as a PDF.