DPP field to regulation mapping
This page provides a comprehensive cross-reference table mapping each major Traceable DPP field to the corresponding EU Battery Regulation article, annex, or recital. Use this table to identify the regulatory basis for any given field, understand which battery categories the field applies to, and determine whether a field is mandatory or optional.
Informational only — not legal advice or a compliance guarantee
This documentation is provided for informational purposes only. It is not legal advice and does not constitute a compliance guarantee, certification, or attestation of conformity with Regulation (EU) 2023/1542. Field-level requirements are subject to further specification by Commission delegated acts. Operators remain solely responsible for their own compliance and should consult qualified regulatory counsel.
How to Read This Table
- Traceable Field Name: The label used in the Traceable DPP Builder.
- Regulation Reference: The primary article, annex, or recital that mandates or defines this field.
- Mandatory For: The battery categories for which this field is mandatory. "All" means all five categories. "—" means not required for that category.
- Notes: Clarifications, conditions, or links to related pages.
"Mandatory" and "blocks publication today" are not always the same thing
A field can be mandatory under the Regulation before its compliance date arrives. Traceable's publish gate blocks only on the data points the Commission's data-points guidance marks Mandatory for the category (template fields flagged required and mandated), plus other checks such as lineage, certificate rules, the identifier rule and the recycled-content minimum shares. The carbon-footprint and due-diligence fields and the four per-metal recycled-content fields (see the Carbon Footprint, Recycled Content and Supply Chain Due Diligence sections below) are optional on every battery template; the platform records a date for each category from which its carbon-footprint value checks block and its compliance score counts the attribute. The platform setting for EV carbon footprint follows the guidance as well (changed in September 2026): the Commission's data-points guidance of 28 July 2026 (points 17-18) marks the carbon-footprint declaration "not to be filled/displayed as of February 2027, format still to be specified in the upcoming implementing act" for all categories including EV, and the platform changed its earlier in-force-since-2025 setting to follow it; that guidance does not change the dates Art. 7(1) sets. If Traceable cannot resolve a product's battery category, the gate fails closed and treats every mandatory field as blocking, rather than assuming the obligation does not apply.
Battery Identity
| Traceable Field Name | Regulation Reference | Mandatory For | Notes |
|---|---|---|---|
| Manufacturer name | Art. 38(7), Annex XIII | All | Full legal registered name |
| Manufacturer registered address | Art. 38(7) | All | Registered business address |
| Manufacturer contact details | Art. 38(7) | All | Contact for MSA and consumer enquiries |
| Manufacturing facility country | Annex VI Part A point 3, Annex XIII | All | Country of manufacture |
| Battery model identifier | Art. 38(6), Annex XIII | All | Model/type designation |
| Battery serial number | Art. 38(6) | All: batch or serial number, or product number or another element allowing identification | The QR code links to the unique identifier attributed under Art. 77(3), which need not be the serial number |
| Battery batch/lot number | Art. 38(6); Annex XIII point 1(a) for passport categories | All: batch or serial number, or product number or another element allowing identification | |
| Date of manufacture | Art. 13(1), Annex VI Part A point 4; Annex XIII point 1(a) for passport categories | All | Month and year minimum |
| Battery category | Art. 3(1)(9)–(14) | All | Must accurately reflect classification |
| Battery lifecycle status | Annex XIII point 4 | EV, industrial >2 kWh, LMT | Five values: Original, Repurposed, Re-used, Remanufactured, Waste |
| Original passport URL | Art. 77(7) | EV, industrial >2 kWh, LMT | Optional at entry; the publish gate requires one of the two links when lifecycle status is Repurposed or Remanufactured, and also when it is Re-used and the Lineage Operation answer is anything other than None (including no answer) |
| Linked passport URN | Art. 77(7) | EV, industrial >2 kWh, LMT | Optional at entry; the publish gate requires one of the two links when lifecycle status is Repurposed or Remanufactured, and also when it is Re-used and the Lineage Operation answer is anything other than None (including no answer) |
| Battery chemistry (anode) | Annex XIII point 2(a) | EV, industrial >2 kWh, LMT | Active anode material (e.g. graphite, LTO); accessible only to persons with a legitimate interest and the Commission |
| Battery chemistry (cathode) | Annex XIII point 2(a) | EV, industrial >2 kWh, LMT | Active cathode material (e.g. NMC, LFP, NCA, LCO); accessible only to persons with a legitimate interest and the Commission |
| Battery chemistry (electrolyte) | Annex XIII point 2(a) | EV, industrial >2 kWh, LMT | Electrolyte type (liquid, solid, polymer); accessible only to persons with a legitimate interest and the Commission |
| Rated capacity (Ah) | Art. 13(1), Annex VI Part A point 6; Annex XIII point 1(g) for passport categories | All | At defined temperature and C-rate |
| Energy content (kWh) | Not an Annex XIII datapoint (platform field) | Platform only: EV, Industrial, LMT | Total usable energy; Annex XIII point 1(g) lists rated capacity (in Ah), not energy |
| Nominal voltage (V) | Annex XIII point 1(h) | EV, industrial >2 kWh, LMT | Nominal operating voltage |
| Maximum charge voltage (V) | Annex XIII | EV, industrial >2 kWh, LMT | Upper charge limit |
| Minimum discharge voltage (V) | Annex XIII | EV, industrial >2 kWh, LMT | Lower discharge cutoff |
| Producer registration number (no platform field) | Art. 55 | Not an Annex XIII datapoint | Producers register in the register of producers of each Member State (Art. 55(2)); Annex XIII does not list a registration number, and no battery template has a producer registration field (the LMT template has an optional Producer Responsibility Organisation ID) |
| Authorised representative | Art. 40 | Not mandatory (Art. 40(1)) | Optional: a manufacturer may designate one by written mandate (Art. 40(1)); Art. 40 governs the mandate and delegated obligations. A producer selling by distance contracts directly to end-users from another Member State or a third country must appoint an authorised representative for extended producer responsibility (Art. 56(3)) |
| Importer name and address (no platform field) | Art. 41(3) | Not an Annex XIII datapoint | Importers indicate on the battery their name, registered trade name or registered trade mark and postal address (Art. 41(3)); no battery template has an importer field |
Carbon Footprint
| Traceable Field Name | Regulation Reference | Mandatory For | Notes |
|---|---|---|---|
| Carbon footprint value (kg CO₂e/kWh) | Art. 7(1) | EV batteries: 18 February 2025 or 12 months after the date of entry into force either of the delegated act or of the implementing act respectively referred to in the fourth subparagraph, points (a) and (b), whichever is the latest; rechargeable industrial batteries >2 kWh except those with exclusively external storage: 18 February 2026 or 18 months after the date of entry into force either of the delegated act or of the implementing act respectively referred to in the fourth subparagraph, points (a) and (b), whichever is the latest; LMT batteries: 18 August 2028 or 18 months after the date of entry into force either of the delegated act or of the implementing act respectively referred to in the fourth subparagraph, points (a) and (b), whichever is the latest; rechargeable industrial batteries >2 kWh with external storage: 18 August 2030 or 18 months after the date of entry into force either of the delegated act or of the implementing act respectively referred to in the fourth subparagraph, points (a) and (b), whichever is the latest | Total lifecycle footprint. Each date applies as Art. 7(1) sets it, whichever is the latest of the fixed date and the stated period after the delegated act or implementing act enters into force; the Commission's 28 July 2026 guidance marks the datapoint "not to be filled/displayed as of February 2027" for all categories including EV; that is guidance and does not change the dates Art. 7(1) sets. See Enforcement timeline. Not yet in force does not mean not required: it means the compliance date has not arrived |
| Carbon footprint — raw material stage | Art. 7(1), Annex II point 4 | EV, industrial >2 kWh, LMT | Breakdown by lifecycle stage |
| Carbon footprint — manufacturing stage | Art. 7(1), Annex II point 4 | EV, industrial >2 kWh, LMT | Cell and pack manufacturing |
| Carbon footprint — transport stage | Art. 7(1), Annex II point 4 | EV, industrial >2 kWh, LMT | Logistics contribution |
| Carbon footprint — end-of-life stage | Art. 7(1), Annex II point 4 | EV, industrial >2 kWh, LMT | EoL processing contribution |
| Carbon footprint performance class | Art. 7(2) | EV, industrial >2 kWh, LMT (LMT from 18 February 2030 or 18 months after the date of entry into force either of the delegated act or of the implementing act respectively referred to in the fourth subparagraph, points (a) and (b), whichever is the latest) | Performance classes set by delegated act, with category A being the best class (Annex II point 8) |
| Carbon footprint study reference | Art. 7(1) | EV, industrial >2 kWh, LMT | Web link giving access to a public version of the supporting study (Art. 7(1), first subparagraph, point (g)); platform field (Life Cycle Assessment Report) on the EV template only |
| Carbon footprint methodology | Art. 7(2), second subparagraph | Not an Annex XIII datapoint | The technical documentation must show that the declared carbon footprint was calculated by the delegated-act methodology |
| Carbon footprint verification status | Art. 17(2) | EV, industrial >2 kWh, LMT | Third-party verification |
Recycled Content
The Commission's guidance update of 15 August 2026 (v2.0, rows 20-23) marks the four recycled-content percentages "not to be filled/displayed as of February 2027" pending Article 8 and its delegated act, so none of the declaration fields below blocks publication on the platform today. The Article 8 dates themselves are unchanged.
| Traceable Field Name | Regulation Reference | Mandatory For | Notes |
|---|---|---|---|
| Cobalt — recycled content (%) | Art. 8 | Industrial >2 kWh, EV, LMT, SLI | Declaration from 18 August 2028 or 24 months after the date of entry into force of the delegated act referred to in the third subparagraph, whichever is the latest (industrial >2 kWh except exclusively external storage, EV, SLI); LMT declaration from 18 Aug 2033. Minimum shares from 18 Aug 2031 (LMT excluded), rising 18 Aug 2036 (all four, incl. LMT) |
| Nickel — recycled content (%) | Art. 8 | Industrial >2 kWh, EV, LMT, SLI | Declaration from 18 August 2028 or 24 months after the date of entry into force of the delegated act referred to in the third subparagraph, whichever is the latest; LMT from 18 Aug 2033 |
| Lithium — recycled content (%) | Art. 8 | Industrial >2 kWh, EV, LMT, SLI | Declaration from 18 August 2028 or 24 months after the date of entry into force of the delegated act referred to in the third subparagraph, whichever is the latest; LMT from 18 Aug 2033 |
| Lead — recycled content (%) | Art. 8 | Industrial >2 kWh, EV, LMT, SLI | Declaration from 18 August 2028 or 24 months after the date of entry into force of the delegated act referred to in the third subparagraph, whichever is the latest; LMT from 18 Aug 2033; consult Art. 8 for the applicable minimum shares |
| Recycled content verification (no platform field) | Art. 17(2) | Not an Annex XIII datapoint | Conformity with Art. 8 is assessed under Module D1 or Module G of Annex VIII (Art. 17(2)); no battery template has a recycled-content verification field |
The four per-metal fields exist on the EV, industrial, stationary and LMT templates. The SLI template has Recycled Cobalt, Lithium, Nickel and Lead Content (%) fields as well as a Total Recycled Content (%) field. The portable template has a single Recycled Content (%) text field.
Performance and Durability
| Traceable Field Name | Regulation Reference | Mandatory For | Notes |
|---|---|---|---|
| Initial rated capacity (Ah) | Annex XIII, Annex IV Part A point 1 | EV, industrial >2 kWh, LMT | Beginning-of-life capacity |
| End-of-life capacity threshold (%) | Annex XIII point 1(k) | EV only | Capacity % defining end of life |
| Rated cycle life | Annex XIII, Annex IV Part A point 5 | EV, Industrial, LMT | Full cycles to EoL threshold. The Regulation sets no stationary or forklift condition: Annex XIII point 1(j) is included to the extent applicable to the category or sub-category (Art. 77(2)), and Annex IV Part A point 5 excepts non-cycle applications. For Industrial and Stationary, the platform's publish gate warns about empty expected cycle life and related endurance datapoints, without blocking publication, only when the declared industrial application is stationary energy storage (home or commercial/grid) or forklift duty |
| State of Certified Energy (SOCE) | Annex XIII (per the Commission's data-points guidance, point 61) | EV only | Percentage 0–100; the guidance marks it mandatory for EV and not-to-be-filled for LMT/industrial |
| Calendar life (years) | Annex XIII | EV, industrial >2 kWh, LMT | Particularly critical for BESS |
| Operating temperature — minimum (°C) | Annex XIII | EV, industrial >2 kWh, LMT | |
| Operating temperature — maximum (°C) | Annex XIII | EV, industrial >2 kWh, LMT | |
| Maximum continuous power (kW) | Annex XIII | EV, industrial >2 kWh, LMT | |
| Peak power capability (kW) | Annex XIII | EV, industrial >2 kWh, LMT | |
| Round-trip energy efficiency (%) | Annex XIII | EV, industrial >2 kWh, LMT | Particularly relevant for BESS; the platform warns about it, without blocking publication, for industrial batteries only when the declared application is stationary energy storage or forklift duty |
| Initial internal resistance (mΩ) | Annex XIII | EV, industrial >2 kWh, LMT | |
| State of health methodology (no platform field) | Art. 14, Annex VII | Not an Annex XIII datapoint | Annex VII sets the parameters for determining the state of health; Annex XIII point 4(b) requires information on the state of health pursuant to Art. 14 (EV, stationary battery energy storage systems, LMT); no battery template has a state-of-health methodology field |
| Current SoH (%) | Art. 14, Annex VII | EV, stationary battery energy storage systems, LMT | Up-to-date data in the battery management system from 18 August 2024 |
Hazardous Substances
| Traceable Field Name | Regulation Reference | Mandatory For | Notes |
|---|---|---|---|
| Hazardous substance name | Art. 13(1), Annex VI Part A point 8, Annex XIII point 1(b) | All | Each hazardous substance present in the battery, other than mercury, cadmium or lead; no concentration threshold |
| Hazardous substance CAS number | Not required by the Regulation (platform field) | Not required | Chemical Abstracts Service identifier; optional on the platform |
| Hazardous substance location in battery | Art. 74(3) | All | Component or material in which substance is present |
| Hazardous substance concentration (%) | Not required by the Regulation (platform field) | Platform only: EV, Industrial, LMT | Concentration by weight or range; optional on the platform |
| Safety data sheet reference | Not required by the Regulation (platform field) | Platform field on the EV, industrial, stationary, LMT, portable and SLI templates | SDS document reference or URL. On the first four it is required and is one of the carriers of the safety-measures data point (a safety data sheet, or a safety-measures text field); on the portable and SLI templates it is optional |
| CLP hazard pictograms | CLP Regulation (EC) 1272/2008 | All | Applied where CLP criteria are met |
Supply Chain Due Diligence
| Traceable Field Name | Regulation Reference | Mandatory For | Notes |
|---|---|---|---|
| Annex X material countries of origin | Art. 49(2)(c), Annex X | Not an Annex XIII datapoint (Art. 49(2) documentation, subject to Art. 47) | Platform field on the EV and LMT templates only, one field for all Annex X materials. Art. 49(2)(c) requires the country of origin of the raw material and the market transactions from its extraction to the immediate supplier; where Art. 49(2)(f) applies, the information can include the mine of origin |
| Cobalt sourcing declaration | Art. 48, Art. 49, Annex X point 1 | Not an Annex XIII datapoint (subject to Art. 47) | Platform field on the EV, industrial, stationary and LMT templates. Annex XIII point 1(d) requires information on responsible sourcing as indicated in the Art. 52(3) report |
| Graphite sourcing declaration | Art. 48, Art. 49, Annex X point 1 | Not an Annex XIII datapoint (subject to Art. 47) | Platform field on the EV, industrial, stationary and LMT templates |
| Lithium sourcing declaration | Art. 48, Art. 49, Annex X point 1 | Not an Annex XIII datapoint (subject to Art. 47) | Platform field on the EV, industrial, stationary and LMT templates |
| Nickel sourcing declaration | Art. 48, Art. 49, Annex X point 1 | Not an Annex XIII datapoint (subject to Art. 47) | Platform field on the EV, industrial, stationary and LMT templates |
| Due diligence policy URL | Art. 48 | All (subject to Art. 47) | Ch. VII (Arts 47–53); from 18 Aug 2027 (as amended by Regulation (EU) 2025/1561), subject to Article 47, first paragraph (net turnover of less than EUR 40 million, group limit of EUR 40 million). Platform field on the portable and SLI templates; the EV, industrial, stationary and LMT templates have a Due Diligence Report field |
| Third-party audit report reference | Art. 48 | All (subject to Art. 47) |
Compliance Labelling
| Traceable Field Name | Regulation Reference | Mandatory For | Notes |
|---|---|---|---|
| CE marking present (yes/no) | Art. 20(1), Art. 19 | All | Must be on physical battery |
| Declaration of Conformity reference | Art. 18, Annex IX | All | DoC document number and date |
| DoC issuing entity | Art. 18(4), Annex IX points 2 and 3 | All | Annex IX point 2 names the manufacturer and, where applicable, its authorised representative; the declaration is issued under the sole responsibility of the manufacturer (Annex IX point 3). No separate platform field: the DoC is uploaded as a document |
| Notified body name | Annex IX point 7 | All (where applicable) | Required for third-party assessed requirements |
| Notified body number | Art. 20(3) | All (where applicable) | EU notified body identification number |
| Harmonised standards applied | Art. 15, Annex IX point 6 | All | References to EN standards |
| Separate collection symbol present | Art. 13(4), Annex VI Part B | All | Crossed-out wheelie bin symbol |
| Capacity label (no platform field) | Art. 13(2) | Rechargeable portable, LMT, SLI | Label containing information on capacity, from 18 August 2026 or 18 months after the date of entry into force of the implementing act referred to in paragraph 10, whichever is the latest (Art. 13(2) and (10)) |
| Carbon footprint label | Art. 7(2) | EV, industrial >2 kWh, LMT | Performance class letter on label; phased under Art. 7(2) (LMT from 18 February 2030 or 18 months after the date of entry into force either of the delegated act or of the implementing act respectively referred to in the fourth subparagraph, points (a) and (b), whichever is the latest) |
Extended Producer Responsibility
| Traceable Field Name | Regulation Reference | Mandatory For | Notes |
|---|---|---|---|
| EPR producer registration number (no platform field) | Art. 55 | Not an Annex XIII datapoint | National producer register per Member State |
| EPR registration country/countries (no platform field) | Art. 55(2) | Not an Annex XIII datapoint | Member states where batteries are placed |
| Take-back scheme name | Art. 57(1) | Where the producer has appointed a producer responsibility organisation | Art. 57(1) makes the appointment optional; the collection and take-back information itself is required by Art. 74(1)(c) |
| Take-back scheme contact (no platform field) | Art. 74(1)(c) | All | For consumer return enquiries |
| Collection point information | Art. 74(1)(c), Art. 62 | All | Producers make collection point information available to end-users; distributors take back waste batteries of every category |
End of Life
| Traceable Field Name | Regulation Reference | Mandatory For | Notes |
|---|---|---|---|
| Dismantling instructions URL | Annex XIII point 2(c) | EV, industrial >2 kWh, LMT | Link to or summary of dismantling guide |
| Safety precautions for dismantling | Annex XIII | EV, industrial >2 kWh, LMT | Tool requirements, PPE, hazards |
| Recycling process type | Not required by the Regulation (platform field) | Not required | Hydrometallurgy, pyrometallurgy, etc.; optional on the platform |
| Second-life suitability assessment | Art. 73(1)(a) | Not an Annex XIII datapoint (waste LMT, industrial and EV batteries) | Platform field: Repurposing Potential. Art. 73(1)(a) requires the holder of a waste battery prepared for re-use or repurposing to demonstrate, upon request by a competent authority, evidence of a state of health evaluation or state of health testing |
| Hazardous substance disposal instructions | Art. 74(1), points (d) and (f); Annex XIII point 1(s) for passport categories | All | Specific instructions for substances requiring special handling |
Was this page helpful?