The authorised access tier is the part of a battery passport that is accessible only to persons with a legitimate interest and, for point 2, to the Commission. It adds two kinds of depth to the public summary: detailed model information in point 2, and individual battery information in point 4. Detailed model information includes detailed composition, part numbers and spare sources, dismantling information and safety measures. Individual battery information includes unit level performance values, state of health, status changes and use phase events.
The tier exists because repair, remanufacturing, repurposing and recycling require detail that cannot be published to everyone, and because unit history is personal to the battery and its holders in a way that a model summary is not.
Who has a legitimate interest?
Legitimate interest is a functional test, not a job title. A person has a legitimate interest where access to the detail is needed for a purpose connected with the battery: repair, preparation for re-use, repurposing, remanufacturing, recycling, assessment for a second life application, or a comparable purpose recognised by the system. The test is applied to the purpose and the detail requested, not to the person in general. A repairer has a legitimate interest in dismantling information for the model being repaired. The same repairer does not have a legitimate interest in detailed composition for a model that is not being worked on, unless another purpose justifies it. The system that grants access must therefore record the purpose, the battery or model concerned, and the detail granted, so that access can be reviewed. A blanket grant of authorised access to all detail for all batteries fails the functional test, even when the recipient is a reputable organisation.
How is access granted and controlled?
Access is granted through authentication, role assignment and logging. Authentication establishes who the reader is. Role assignment establishes what the reader may see, for which batteries, and for what purpose. Logging records what was accessed, when, and by whom, so that misuse can be detected and access can be reviewed. Access should be time limited or purpose limited where the system provides for it, and should be revoked when the purpose ends or the role changes. A reader who changes employer, changes role, or completes a repair should not retain indefinite access to detail for batteries no longer in scope. Access control is a record control, not a courtesy: a system that grants authorised access without authentication, or that logs nothing, cannot demonstrate that restricted detail was protected, and cannot detect leakage if it occurs.
What detail must be kept consistent with the public view?
Every shared field must be identical in the public and authorised views: same value, same scope note, same date, same version. The authorised view extends the public view, it does not correct it silently. Where a correction is made, the correction appears in both views with the same version note. Where a model revision occurs, both views point to the correct version for the unit concerned. Consistency testing means comparing the two views field by field, as a public reader and as an authorised reader, and recording any discrepancy as a defect. A discrepancy in a shared field undermines trust in both views, because a reader cannot tell which view is current. The table below shows the extension relationship.
| Content | Public view | Authorised view |
|---|---|---|
| Model summary | Present, summary depth | Same values, plus detailed composition |
| Dismantling | Not shown in detail | Sequences, tools, warnings, layout |
| Safety measures | Existence indicated | Full measures for the model |
| Unit history | Not shown | Dated performance, state of health, status |
| Test reports | Not shown | Authority tier only, not authorised tier |
What must an authorised reader not do with detail?
An authorised reader must not publish, share or reuse restricted detail beyond the purpose for which access was granted. Detailed composition, supplier identities, part numbers and dismantling sequences are restricted for a reason: they reveal proprietary construction and supply relationships, and they carry safety implications if used without context. An authorised reader must not quote restricted detail in a public report, a sales listing or a social media post, and must not use detail for a battery outside the granted purpose. A reader who receives detail in error, or who finds detail through a leak, should report the leak and should not rely on the detail until the operator confirms its status. Confidentiality is part of the access bargain, and breach of it undermines the willingness of operators to provide detail to legitimate readers in future.
What training and handling rules apply to authorised readers?
Authorised readers need handling rules as well as access rights. A reader granted dismantling detail should know how to store the detail, how to avoid copying it into uncontrolled documents, and how to dispose of printed copies when the work is complete. A reader granted unit history should know that history may contain holder information subject to data protection rules, and that the history must not be shared beyond the purpose of the grant. Handling rules should be stated at the point of granting access, in short written form, and acknowledged by the reader. A grant without handling rules relies on the reader inventing the rules, and invented rules vary. Handling failures, such as a dismantling diagram left in a public workshop file, are access failures even when the original grant was correct.
How is authorised access reviewed?
Authorised access is reviewed at intervals, on role change, and after any incident. Review checks that each grant still has a current purpose, that access logs show use consistent with the purpose, and that revoked grants no longer work. Review also checks that the tier boundary still holds: no restricted detail in the public view, no public field hidden from authorised readers, and no test report material in the authorised view where it belongs in the authority tier. This guide gives general educational information only and does not give legal advice for a particular battery, reader or access decision.
Sources & further reading
- Regulation (EU) 2023/1542, consolidated text, Article 77 and Annex XIII points 2 and 4 ↗
- European Commission, Batteries ↗
- EU Battery Regulation 2023/1542: passport from 2027 ↗
Source links point to primary materials and further reading, including commercial implementation resources where cited. This introductory guide does not replace the legislation.