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Access rights

Battery passport: who may see restricted data? Feedback until 16 November

The European Commission has published its draft on access rights. What is planned, what is missing and what manufacturers should do now.

By Redaktion Batterypass · 2 min read

Illustration: a battery passport with open and locked data blocks, different groups of people accessing individual blocks
In shortThe Commission is collecting feedback until 16 November 2026 on its draft on who may access restricted parts of the battery passport. The passport obligation from 18 February 2027 is not affected.

What happened?

Article 77(9) of Regulation (EU) 2023/1542 requires the Commission to set out who has a legitimate interest in certain passport data and how that data may be used. A feedback period runs from 19 October to 16 November 2026 on its “Have your say” portal, which lists adoption as planned for the fourth quarter of 2026.

According to specialist articles, the draft names repairers, remanufacturers, repurposers, waste treatment operators, recyclers, vocational training centres and battery purchasers, among others. Access would be limited to specific data blocks and purposes per group. As this is a draft, it may still change.

Who should see what: planned split in the draft
Data blockPlanned access
Composition, dismantlingRepair, remanufacturing, repurposing, waste treatment, recycling, vocational training
Part numbers, spare partsRepair, remanufacturing, repurposing, purchasers
Safety measuresAll of the above, plus end-of-life vehicle and WEEE facilities
Data on the individual batteryPurchasers and those acting for them
Simplified from specialist articles on the draft of 19 October 2026. The original text is decisive and changes are possible.

What is still open

Feedback received so far mainly asks how someone can prove in practice that they belong to an entitled group. The Commission’s FAQ also says the act does not set the detailed authentication procedure. Manufacturers and software providers will therefore need their own processes.

Who is affected?

All economic operators providing passports from February 2027, meaning manufacturers, importers and own-brand suppliers of LMT, industrial and electric vehicle batteries. Also businesses that will need access, such as repair shops and recyclers.

What to do now

  1. Read the draft on the Commission portal and check whether your supply chain is properly reflected.
  2. If something is missing, submit feedback by 16 November.
  3. Decide who in your company will check and document access requests.
  4. Separate your passport data into public and restricted now.

What this means for Batterypass

The app separates public and non-public fields and does not show restricted data on the public passport page. There is no approval process for entitled third parties yet. We are waiting for the final act before building it.

Sources

This article reflects the status on its publication date and is not legal advice. The linked original texts are decisive.