As Europe prepares for the widespread adoption of Digital Battery Passports (DBPs), many organisations are asking an important question: where do all the required data fields actually come from?
The EU Battery Regulation establishes the legal framework for Battery Passports, but it does not define every technical detail of how information should be structured, organised or exchanged. That work is being supported by technical standards and specifications developed by standardisation bodies and industry experts.
One of the most influential documents in this area is DIN DKE SPEC 99100.
Although it is not legislation, DIN DKE SPEC 99100 provides one of the earliest comprehensive frameworks for organising Battery Passport information. It has helped shape discussions around the data fields, lifecycle information and interoperability principles needed to support future Digital Battery Passports.
For organisations preparing for Battery Passport implementation, understanding DIN DKE SPEC 99100 offers valuable insight into how Digital Battery Passports are likely to work in practice.
What Is DIN DKE SPEC 99100?
DIN DKE SPEC 99100 is a publicly available technical specification developed by DIN (the German Institute for Standardisation) and DKE (the German Commission for Electrical, Electronic & Information Technologies).
The specification was created with contributions from industry, research organisations and public sector stakeholders involved in battery manufacturing, digitalisation and sustainability.
Rather than creating new legal obligations, DIN DKE SPEC 99100 proposes a structured model for organising Battery Passport information throughout a battery's lifecycle.
It provides recommendations for what information should be recorded, how that information can be structured and how different stakeholders may exchange data consistently.
Reference: https://www.dinmedia.de/en/technical-rule/din-dke-spec-99100/385692321
Why Was The Specification Developed?
Modern batteries generate enormous amounts of information.
Manufacturers record production data, suppliers provide material information, battery management systems generate operational data, service providers document maintenance activities, and recyclers collect end-of-life information.
Without a common structure, each organisation could record information differently, making digital traceability extremely difficult.
DIN DKE SPEC 99100 was developed to encourage a common approach to organising Battery Passport information so that data remains understandable and interoperable across the battery value chain.
Its objective is not simply to standardise terminology but to improve the quality, consistency and usability of battery information throughout the product lifecycle.
The Specification Provides A Structured Data Model
One of the most valuable aspects of DIN DKE SPEC 99100 is its structured approach to organising Battery Passport information.
Instead of viewing the Battery Passport as a single digital document, the specification treats it as a collection of related information organised into logical categories.
These categories include battery identification, manufacturing information, technical characteristics, sustainability indicators, lifecycle events, compliance documentation, maintenance history and end-of-life information.
This structured approach makes Battery Passport information easier to exchange between digital systems while supporting long-term traceability.
Why Data Fields Matter
Every Battery Passport consists of individual data fields.
Each field answers a specific question about the battery.
For example, one field may identify the manufacturer, another records the battery chemistry, while others describe the carbon footprint, recycled material content or state of health.
Without clearly defined fields, organisations could describe similar information in completely different ways.
One manufacturer might record a manufacturing location as free text, while another uses regional codes. One company may record battery capacity in slightly different units from another.
These inconsistencies create significant challenges for interoperability.
By recommending structured data fields, DIN DKE SPEC 99100 helps reduce ambiguity and improve data quality across different organisations.
Supporting The Entire Battery Lifecycle
Another important feature of the specification is its lifecycle perspective.
Battery information does not stop at manufacturing.
As batteries move through transport, installation, operation, maintenance, repair, repurposing, second-life applications and recycling, new information continues to be generated.
DIN DKE SPEC 99100 recognises that a Digital Battery Passport should evolve alongside the physical battery.
Maintaining this continuous digital history supports better decision-making, improved sustainability reporting and more efficient recycling processes.
How DIN DKE SPEC 99100 Supports Interoperability
Battery manufacturers, automotive companies, logistics providers, repair centres, authorities and recyclers all use different software platforms.
Interoperability depends on these systems understanding the same information in the same way.
By recommending consistent data structures, DIN DKE SPEC 99100 helps create a common language for Battery Passport information.
This reduces the need for manual data conversion while supporting secure and automated information exchange across complex international supply chains.
As European Digital Product Passport initiatives continue to evolve, structured and interoperable data models will become increasingly important.
Is DIN DKE SPEC 99100 Mandatory?
This is one of the questions organisations ask most frequently.
The answer is no.
DIN DKE SPEC 99100 is not a legal requirement under the EU Battery Regulation.
Instead, it is a technical specification that provides practical guidance for organisations designing Digital Battery Passport systems.
However, because it reflects extensive collaboration between industry experts and standardisation bodies, many of its concepts have influenced wider discussions around Battery Passport implementation.
Organisations that understand the specification are therefore better positioned to prepare for future interoperability requirements and evolving European standards.
How It Relates To The EU Battery Regulation
The EU Battery Regulation establishes what information must ultimately be made available for applicable batteries.
Technical specifications such as DIN DKE SPEC 99100 help explain how that information can be organised within digital systems.
In other words, the regulation provides the legal framework, while technical specifications provide implementation guidance.
This distinction is important because legislation and standards serve different purposes, yet they work together to support practical Battery Passport deployment.
Reference: https://eur-lex.europa.eu/eli/reg/2023/1542/oj
How BASE Supports Practical Battery Passport Implementation
At BASE Project, we recognise that successful Digital Battery Passports require more than regulatory awareness. Organisations also need practical guidance on structuring, managing and exchanging battery data throughout the entire lifecycle.
Our work explores Digital Battery Passport frameworks that support interoperable data models, lifecycle traceability, secure information exchange and alignment with emerging European standards.
By contributing to practical approaches for Battery Passport implementation, BASE helps organisations prepare for a future where accurate, structured and trustworthy battery information becomes an essential part of Europe's digital and circular economy.
Looking Ahead
The Digital Battery Passport is rapidly becoming a cornerstone of Europe's battery ecosystem.
As implementation progresses, organisations will need both regulatory knowledge and technical understanding.
DIN DKE SPEC 99100 provides valuable insight into how Battery Passport information can be organised in a consistent, structured and interoperable way. While it is not legislation, it offers practical guidance that complements the objectives of the EU Battery Regulation and helps organisations prepare for future Digital Battery Passport implementation.
Businesses that begin understanding these technical foundations today will be better equipped to build scalable, interoperable and future-ready Battery Passport systems.
The BASE project has received funding from the Horizon Europe Framework Programme (HORIZON) Research and Innovation Actions under grant agreement No. 101157200.
References
DIN Media – DIN DKE SPEC 99100:2025-02: https://www.dinmedia.de/en/technical-rule/din-dke-spec-99100/385692321
EU Battery Regulation (Regulation (EU) 2023/1542): https://eur-lex.europa.eu/eli/reg/2023/1542/oj
European Commission – Batteries: https://environment.ec.europa.eu/topics/waste-and-recycling/batteries-and-accumulators_en
European Commission – Ecodesign for Sustainable Products Regulation: https://environment.ec.europa.eu/strategy/circular-economy/ecodesign-sustainable-products-regulation_en
BASE Project - JTC 24 Standards Explained For Battery Passport Teams: What They Mean In Practice: https://base-batterypassport.com/blog/regulations-4/jtc-24-standards-explained-for-battery-passport-teams-what-they-mean-in-practice-115