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.
- 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.
Which standard the law names for the battery passport
With battery passport standards, look at the law first: it says less than the debate suggests. The regulation sets out content and requirements, but names a specific standard in only one place.
Article 77(1) of Regulation (EU) 2023/1542 requires an electronic record, the battery passport, for every LMT battery, every industrial battery over 2 kWh and every electric vehicle battery from 18 February 2027. Paragraph 3 governs access via the QR code and, in its second sentence, prescribes the only standard the law names for the passport: "The QR code and the unique identifier shall comply with standards ISO/IEC 15459-1:2014, 15459-2:2015, 15459-3:2014, 15459-4:2014, 15459-5:2014 and 15459-6:2014 or equivalent standards."
The rest is written as requirements, not as references to standards. Article 78 demands, among other things, that the passport is fully interoperable with other digital product passports (point a), that the data is stored by the responsible economic operator (c), stays available after that operator ceases to exist (e), and that authenticity, reliability and integrity are ensured (g). What goes into the passport is in Annex XIII; how it is registered is in Implementing Regulation (EU) 2026/1778 on the DPP registry.
- EU lawbinding
- Regulation (EU) 2023/1542Art. 77, Art. 78, Annex XIII
- Implementing Regulation (EU) 2026/1778Operation of the DPP registry
- Standard named in the lawbinding, equivalent standards allowed
- ISO/IEC 15459-1 to -6Art. 77(3): identifier and QR code
- Commission interpretationnot binding, the reference target
- Guidance, 71 data points, version 2.015.08.2026, duties per category
- EU battery passport FAQ1st edition, September 2026
- Harmonised standards (ESPR)presumption of conformity for ESPR passports
- EN 18216, EN 18219 to EN 18223Decision (EU) 2026/1736
- EN 18239, EN 18246not yet cited in the Official Journal
- Specifications and industry standardsvoluntary
- DIN DKE SPEC 99100data attributes, free of charge
- IDTA 02035 / Catena-X7 AAS submodels
- GS1 Digital LinkGTIN and serial in the QR link
- Law outside the EUno effect on the EU market
- GB/T 47591-2026China, recommended standard
Below the law sits interpretation. In the guidance "Digital Batteries Passport - data points by category" (version 2.0 of 15 August 2026) the Commission numbered 71 data points and marked each one as mandatory, optional or not yet to be applied per battery category. The document is expressly not a binding position of the Commission, but it is the most precise target there is. The Commission's battery passport FAQ of September 2026 names exactly this combination as preparation: the regulation plus the data point document.
A standard is not an obligation
European standards are voluntary in principle. A standard becomes binding only when a legal act prescribes it, as Article 77(3) does with ISO/IEC 15459. A harmonised standard cited in the Official Journal works differently: whoever applies it is presumed to meet the requirements of the act concerned. Whoever does not apply it must demonstrate compliance in another way.
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.
| Standard | Title | What it governs | Status |
|---|---|---|---|
| EN 18216 | Data exchange protocols | Protocols and formats that move passport data between systems | cited in the Official Journal |
| EN 18219 | Unique identifiers | Identifiers for product, economic operator and facility; model, batch or item level | cited in the Official Journal |
| EN 18220 | Data carriers | The physical link to the passport: symbology, error correction, print quality, durability | cited in the Official Journal |
| EN 18221 | Data storage, archiving and data persistence | Storage, versions, backups and long-term availability | cited in the Official Journal |
| EN 18222 | APIs for lifecycle management and searchability | Interfaces to find, resolve, retrieve and maintain passports | cited in the Official Journal |
| EN 18223 | System interoperability | Semantic, technical and organisational rules for exchange | cited in the Official Journal |
| EN 18239 | Access rights, information security, confidentiality | Who may see which data and how that is enforced | not yet cited |
| EN 18246 | Data authentication, reliability and integrity | Protection of passport data against alteration and forgery | not 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.
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.
| Layer | EU law | EN 182xx | DIN DKE SPEC 99100 | IDTA 02035 / Catena-X | GS1 Digital Link |
|---|---|---|---|---|---|
| Identifier | main subjectArt. 77(3) | main subjectEN 18219 | not its focus | addressedPart 1 | main subjectGTIN + AI 21 |
| Data carrier | main subjectArt. 13(6), Annex VI C | main subjectEN 18220 | not its focus | not its focus | main subjectQR with link |
| Content and data model | main subjectAnnex XIII | addressedEN 18223 | main subjectdata attributes | main subjectParts 1-7 | not its focus |
| Exchange and API | addressedArt. 78(a) | main subjectEN 18216, 18222 | not its focus | main subjectAAS, data space | addressedresolver |
| Storage and availability | main subjectArt. 78(c), (e) | main subjectEN 18221 | not its focus | not its focus | not its focus |
| Access and confidentiality | main subjectArt. 78(f), Annex XIII | addressedEN 18239 | addressedlevel per attribute | not its focus | not its focus |
| Integrity and authenticity | main subjectArt. 78(g), (h) | addressedEN 18246 | not its focus | not its focus | not its focus |
| Registry | main subjectIR 2026/1778 | addressedEN 18222 | not its focus | not its focus | not its focus |
| Layers as main subject (of 8) | 7 | 4 | 1 | 2 | 2 |
- main subject
- addressed
- not its focus
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.
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.
| Question | Reference source | Note |
|---|---|---|
| Which fields are mandatory on the deadline? | Guidance v2.0, 71 data points | Mandatory per category: EV 47, LMT 50, industrial 32 |
| What exactly does an attribute mean? | DIN DKE SPEC 99100 and the guidance | The SPEC describes attributes in more detail |
| Who may see which field? | Annex XIII, Art. 78; mapping per attribute in the SPEC | Implementing act on access rights: draft expected in October or November 2026, says the Commission |
| How detailed must the material composition be? | Open | 1 % (SPEC) or 0.1 % (CEN draft), both reasonable according to the EU FAQ |
| What is not yet to be filled in February 2027? | Guidance v2.0 | Among 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?
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.
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.
| Part | Submodel | Basis | Level |
|---|---|---|---|
| IDTA-02035-1 | Digital Nameplate | IDTA-02006 | per battery |
| IDTA-02035-2 | Handover Documentation | IDTA-02004 | per model |
| IDTA-02035-3 | Product Carbon Footprint | IDTA-02023 | per model and plant |
| IDTA-02035-4 | Technical Data | IDTA-02003-2-0 | per model |
| IDTA-02035-5 | Product Condition | BatteryPass project | per battery |
| IDTA-02035-6 | Material Composition | BatteryPass project | per model |
| IDTA-02035-7 | Circularity | BatteryPass project | per 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.
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.
- 15 December 2023Battery Pass: Technical Standard Stack
The consortium arranges the passport in layers, from identifier to security.
- 15 January 2025DIN DKE SPEC 99100 presented
Data attributes of the battery passport, free from DIN Media, edition 2025-02.
- 4 March 2026IDTA 02035: seven AAS submodels
IDTA, Catena-X and Battery Pass partners, aligned with DIN DKE SPEC 99100.
- April 2026GB/T 47591-2026 in China
Nameplate, label and electronic identification of traction batteries.
- 27 May 2026Six EN 182xx standards published
CEN-CLC/JTC 24 delivers the core standards of the digital product passport.
- 15 July 2026Implementing Decision (EU) 2026/1736
The six standards are cited in the Official Journal: presumption under the ESPR.
- 17 July 2026Implementing Regulation (EU) 2026/1778
Rules for the DPP registry, where battery passports are registered too.
- 15 August 2026Guidance with 71 data points, version 2.0
Mandatory fields per battery category; the non-binding SPEC was never the duty list.
- September 2026EU battery passport FAQ
No technology mandated, an official data model announced.
- September 2026Catena-X release CX-Neptune
According to IDTA, the submodels are to be included as a use case.
- no dateImplementing act on access rights
Draft for feedback expected in October or November 2026, says the Commission.
- no dateEN 18239 and EN 18246 in the Official Journal
Access rights, security and integrity: not yet cited.
- no dateCommission semantic repository
Official data model for the registry, announced without a date.
- 18 February 2027Battery passport obligation
LMT, industrial (over 2 kWh) and electric vehicle batteries, Art. 77(1).
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.
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 situation | Binding | Also useful | Not needed |
|---|---|---|---|
| Manufacturer of LMT, industrial or storage batteries without data space customers | Art. 77 and 78, Annex XIII, identifier under ISO/IEC 15459 | Guidance v2.0, DIN DKE SPEC 99100 for reference, GS1 Digital Link | Catena-X, asset administration shell |
| Supplier to a vehicle manufacturer | The same duties as above | IDTA 02035 and Catena-X where the customer requires it by contract | A second data model next to the customer's |
| Importer of batteries from third countries such as China | Passport responsibility under Art. 77(4), identifier under ISO/IEC 15459 | Request supplier data along the 71 data points | GB/T 47591 as a replacement for the EU identifier |
| Software provider and in-house IT | Art. 78(a) to (h), Implementing Regulation 2026/1778 | EN 18216 and EN 18219 to EN 18223; watch EN 18239 and EN 18246 | - |
Four questions for your battery passport provider
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.
The Commission guidance with 71 data points in version 2.0, not DIN DKE SPEC 99100 alone.
A short link of at most 50 characters per passport, plus an export or interface for registration under Implementing Regulation 2026/1778.
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.
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.
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).
Frequently asked questions on battery passport standards
Which standard applies to the battery passport?
Is DIN DKE SPEC 99100 mandatory?
Do EN 18216 to EN 18223 apply to the battery passport?
Do I need Catena-X for the battery passport?
Which identifier does the Battery Regulation require for the passport?
Is there an official EU data model for the battery passport?
Sources & further reading
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.