Who Can See Battery Data in a Battery Passport

Access to battery data in a passport is tiered, not open, and the tier that a reader falls in decides which fields the reader can see. Annex XIII splits the passport information into information accessible to the general public, information accessible only to persons with a legitimate interest and the Commission, information accessible only to notified bodies, market surveillance authorities and the Commission, and individual information accessible to persons with a legitimate interest. A general reader sees the public fields, a repairer, repurposer or recycler with a legitimate interest sees more, and an authority sees the test reports that prove compliance. A reader who expects to see every field, regardless of tier, misunderstands the structure, and a record that shows every field to every reader would not follow Annex XIII.

The scope is the Annex XIII access structure, as checked on 28 October 2026. The guide does not state the practical access procedure for any record system, because that procedure depends on the implementing arrangements, and it does not state data protection law beyond the tier structure.

What can the general public see?

The general public can see the information in point 1 of Annex XIII, which includes manufacturer information, battery model and category, weight, capacity, chemistry, hazardous substances, carbon footprint, recycled content, expected lifetime and collection and end of life information, in general terms as the Regulation summaries describe the public tier. The public fields let a buyer, a user or a general reader confirm what kind of battery is in hand, what its stated characteristics are and how it should be handled at end of life, without needing a technical role. The public view is deliberately general, and it does not contain the detailed composition, dismantling or safety detail that the legitimate interest tier holds, or the test reports that the authority tier holds. The limit is a feature of the tier design, not a defect in a particular record.

Who has a legitimate interest?

A person with a legitimate interest is a person who needs the detailed information for a legitimate purpose connected with the battery, such as repair, repurposing, remanufacturing, recycling or other work that requires detailed composition, dismantling information, part numbers or safety measures, as Annex XIII describes the tier. The Regulation does not, in the summaries consulted, list every legitimate interest holder by name, and the practical test for legitimate interest will depend on the implementing arrangements and on the record system. A holder should therefore establish, before work begins, whether the holder falls within legitimate interest for the battery in question, what evidence is required, and how access is obtained, rather than assuming that a technical role alone guarantees access. The access question should be answered for each record system.

What can notified bodies and authorities see?

Notified bodies, market surveillance authorities and the Commission can see the test reports proving compliance with the Regulation, in the authority tier of Annex XIII, together with the information in the other tiers that their role requires. The authority tier is restricted because test reports contain the evidence that compliance was assessed, and unrestricted access to that evidence would not serve the market surveillance purpose. A manufacturer, importer or other operator who is asked by an authority for test reports should provide them through the authority route, with the request, the reports and the date recorded, rather than publishing the reports in the public tier. The tier restriction protects the assessment process while still giving authorities the evidence they need.

What does an access tier table look like?

An access tier table maps the tier, the reader and the kind of information, so that a reader can see at a glance what the reader tier contains. The table below uses the Annex XIII structure in general terms.

How is access obtained in practice?

Access in practice is obtained through the record system, by establishing identity, role and legitimate interest where required, and by following the system procedure for the tier in question. The procedure may involve authentication, a statement of purpose, or a check by the record holder, and the details will vary by system, because the Regulation sets the tiers while the implementing arrangements and the record systems set the procedure. An operator should test the access procedure before work begins, record the test, and keep the access credentials and the access log with the battery file, so that a later reader can see who accessed which tier and when. Access without a log is access that cannot be audited.

What happens when access is refused or limited?

When access is refused or limited, the reader should record the refusal, the tier requested, the reason given and the remedy sought, and should seek the information through another route, such as the equipment documentation, the operator chain or the authority, rather than proceeding without the information where the information is needed for safe work. A refusal may be correct, where the reader does not fall within the tier, or it may be an error, where the reader does fall within the tier but the system does not recognise it, and the distinction needs the system procedure and the tier rules to resolve. Work that needs legitimate interest information should pause until the access question is resolved, because proceeding without safety or dismantling information carries a risk that the record system is designed to prevent.

What limits apply to access readings?

The limits are that access procedures depend on implementing arrangements, and this guide states only the tier structure. This guide gives general educational information only and is not individual legal advice. A reader with a specific record should check Annex XIII and the record system procedure as checked on 28 October 2026 before acting.