Battery Passport Access Tiers: Public, Legitimate Interest and Authorities

A battery passport is not a single public web page with everything on it. The EU Battery Regulation sorts the data into access tiers, so that some information is open to anyone while other fields are reserved for specific audiences. This guide explains the tiers and why they shape how you build a passport.

Why tiers exist

The passport has to serve very different readers. A member of the public scanning a QR code wants basic, safe information. A recycler or a repairer needs more detail to do their job. A market-surveillance authority needs the full record to check compliance. Putting everything on the open web would expose commercially sensitive data and personal or security-relevant detail that does not belong there.

Access tiers solve this by attaching a visibility level to each field, so the same passport shows different amounts to different audiences.

The three broad tiers

The regulation frames access around three broad audiences:

• The general public. Open to anyone, typically by scanning the data carrier. This tier carries the basic identity and safety-relevant information a member of the public can reasonably see.
• Parties with a legitimate interest. A wider set of fields for those who need them for a defined purpose, such as operators involved in repair, repurposing and recycling. Access here is conditioned on that legitimate interest.
• Authorities and notified bodies. The conformity evidence, such as the test reports that prove the battery meets the rules, is reserved for notified bodies, national market-surveillance authorities and the European Commission.

The tiers themselves are set by Art. 77(2) and Annex XIII of Regulation (EU) 2023/1542. The public tier and the authorities tier are defined in the regulation. Who counts as having a "legitimate interest," exactly which of the reserved fields they may see, and for what purposes, is left to a Commission implementing act (Art. 77(9)), which the regulation required by 18 August 2026. That deadline passed without the act being adopted, and adoption is now signalled for the final quarter of 2026. See the access-rights deadline has slipped. So the three broad groups are fixed now, while the fine detail of the middle tier is still being written.

Why this is a legal requirement, not a display choice

The tiering is set by the regulation, so which fields are public is not something you decide for presentation. Serving a field to the wrong audience is a compliance failure, not a styling preference. On our platform, access-tier enforcement on passport pages is treated as a legal control: the tier determines who can see a field, and that is built into how passports are served rather than left to page design.

For importers, the practical consequence is that when you collect Annex XIII data you should also note which tier each field belongs to, so nothing sensitive is exposed by accident and nothing required is withheld. See Annex XIII explained.

What this means for your data work

1. Tag each field with its tier as you gather it, alongside its source.
2. Review the public tier carefully. This is what appears when anyone scans the battery, so it is the most exposed surface.
3. Do not improvise the mapping. Where a field's tier is unclear, treat it as a question to resolve against the regulation, not a judgement call.

In short

The battery passport serves data in tiers: public for anyone, a wider set for parties with a legitimate interest such as recyclers and repairers, and the full record for authorities. The mapping is set by the regulation, so it is a legal control rather than a display option. Record the tier of each field as you collect it, and pay closest attention to what lands in the public tier.