Annex XIII of the Battery Regulation lists categories of information, not fields. That is fine for a legal text and useless for a database schema, which leaves every implementer with the same question: what exactly are the fields? DIN DKE SPEC 99100 is the specification the industry has converged on to answer it, and understanding its shape tells you a great deal about how hard your own project will be.
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DIN DKE SPEC 99100 is a German specification, published through DIN and the DKE, that sets out a data model for the battery passport. Its role is translation: Annex XIII of Regulation (EU) 2023/1542 describes what information the passport must convey, and the specification turns that into named attributes with datatypes and access classifications that a system can actually implement.
It is worth being precise about status, because this is frequently overstated. The specification is a technical reference, not the law. The binding obligation is Article 77 and Annex XIII. What the specification provides is a common vocabulary, which matters enormously in practice — without one, your passport, your customer’s procurement system and a recycler’s reader would each invent different field names for the same fact.
Note also that it is a paid standard. You purchase it from DIN. What we publish, and what this page describes, is our own reconciliation of the field set against the Regulation — the structure and the counts — not the text of the standard itself.
Reconciled against Annex XIII, the field set comes to around 110 attributes, of which 94 are mandatory from 18 February 2027. The distribution is uneven, and the shape of that unevenness is the most useful planning information in the whole exercise:
Access is classified per attribute: 82 public, 26 restricted to those with a legitimate interest such as repairers and recyclers, and 2 reserved for notified bodies and market-surveillance authorities.
Three consequences fall directly out of those numbers.
First, a passport is never “finished” at launch. With 21 attributes that only exist in service, any architecture that treats the passport as a document published once is wrong by construction. The record has to be updatable for the regulated lifetime — up to 15 years for batteries — which is longer than most software contracts.
Second, the hard fields are not yours. Carbon footprint, recycled content per metal and due-diligence evidence originate several tiers up the supply chain. They are a small share of the field count and the overwhelming majority of the project’s calendar time. Companies that miss the date almost never miss it because of software.
Third, most of what you need you already hold. Identity, conformity, materials and test results are largely in documents you own today — spec sheets, declarations of conformity, test reports. That is why an honest first step is an audit rather than a platform purchase: the gap is usually smaller and more concentrated than it feels.
One further point that catches implementers late: the field model is versioned, and the Regulation is still generating implementing guidance. Whatever you build should record which version of the field model each passport was created against, so that when the model moves you can tell which records need revisiting rather than re-auditing everything. It is a small design decision at the start and an expensive migration if skipped — the same reason our published dataset carries an explicit version date rather than presenting itself as timeless.
You will eventually want the specification itself if you are building an implementation. But you do not need it to find out where you stand, and we publish the reconciled field list free so that the first step costs nothing:
Take your own spec sheets and declarations, tick off what you already hold, and what remains is your actual project. If you would rather have that done for you, the free readiness check takes a couple of minutes, and the €99 Automated Gap Report returns a written first pass — AI-only with no human review, so indicative rather than verified.
For the legal basis behind all of this, see Article 77 explained.
Take the 2-minute readiness check, watch the 10-minute interactive walkthrough, or download the full 2026 compliance guide. No account needed.