The checklist you built in July has a version number
On 28 July 2026 the Commission published the first per-category list of battery passport data points. If you import in-scope batteries, act as an authorised representative, or issue your own passports, you probably did the sensible thing: read the matrix, built your field list, briefed your suppliers.
On 15 August the Commission replaced it. Version 2.0 — announced on 21 August — changes the status of five data points, and four of them were on your mandatory list.
What moved
The percentage shares of recycled cobalt, lithium and nickel in active materials, and of recovered lead, sat in Version 1.0 as mandatory for every category. Version 2.0 marks all four not to be filled or displayed as of February 2027, "to be applied in line with Article 8 and the relevant delegated act". They join the carbon footprint declaration in the collect-now, display-later set: the disclosure duty is coming, but it arrives with the Article 8 delegated act — still a draft as of this week — not with your passport deadline.
Responsible-sourcing information moved too, in wording rather than status: Version 2.0 anchors it to Article 48(1), required from August 2027. That matches the due-diligence timetable set by Regulation (EU) 2025/1561 and settles when that block of the passport becomes live.
Two further entries gained explanations rather than changes: the aggregate material-composition point and the Annex XIII 1(g) rated-capacity point are confirmed as repetitions of data already required elsewhere — de-duplication, not waivers.
What this means for your preparation
If your supplier data programme has been chasing pre- and post-consumer recycled shares as a February 2027 blocker, it is not one. Reorder the effort behind the fields that remain mandatory — the identity set, chemistry, hazardous substances, critical raw materials, renewable content, the electrochemical parameters for your category. Do not delete the recycled-content workstream: Article 8's delegated act will make those shares live obligations on its own clock, and the collection lead time through a supply chain is the reason the carbon footprint taught everyone to start early.
And note what did not move. "From 18 February 2027, each EV battery, each LMT battery and each industrial battery with a capacity greater than 2 kWh that is placed on the market or put into service shall have a battery passport." That sentence is identical in both versions.
The discipline this teaches
The guidance says of itself that it may be developed further, including units and formats in future updates. Version 2.0 proved that within three weeks of Version 1.0. A battery passport field list is not a document you write once; it is a position you maintain against a moving source, version by version, with each change traced to what it touches.
If you want to see where your passports stand against the current matrix, category by category, start at the platform.
What changed in EU battery and product-passport regulation, what it means for operators, the dates ahead, and what changed on the platform.
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