What is DIN SPEC 99100?
DIN DKE SPEC 99100:2025-02 is a pre-standard published in February 2025 that defines the data structure for the digital battery passport. It provides the technical foundation for how battery information is uniformly captured, structured, and made digitally accessible — across the entire lifecycle, from raw material extraction through production and use to recycling.
The specification is based on the requirements of the EU Battery Regulation (EU 2023/1542), which mandates a digital battery passport for certain battery types starting February 2027. DIN SPEC 99100 specifies which data must be provided in which format — creating a practical foundation for manufacturers, importers, and software providers.
At its core, DIN SPEC 99100 defines seven data categories with mandatory and optional fields each. These categories cover all regulatory aspects: from identification and material composition to carbon footprint and supply chain due diligence, through to circularity, performance data, and labeling.
Technically, DIN SPEC 99100 is implemented through the BatteryPassDataModel v1.2.0 — a set of seven JSON schemas corresponding to each data category. Data is made accessible via a QR code or GS1 Digital Link, enabling authorities, recyclers, and other economic operators to access battery passport data in a standardized manner.
For companies preparing for the digital battery passport, DIN SPEC 99100 is the authoritative reference. It describes not only which data is required but also how that data must be technically structured and validated.
Who developed DIN SPEC 99100?
DIN SPEC 99100 was developed under the leadership of DIN (German Institute for Standardization) and DKE (German Commission for Electrical, Electronic & Information Technologies). Both organizations are Germany's central standardization bodies and play a key role in European and international standardization.
The content draws heavily on the results of the Battery Pass Consortium — a project funded by Germany's Federal Ministry for Economic Affairs (BMWK), coordinated by Systemiq. Consortium partners included renowned companies and institutions across the entire battery value chain: BMW, BASF, Umicore, acatech, Fraunhofer IPT, and others. This broad participation ensured that the specification is both technically sound and practically applicable.
DIN SPEC 99100 is also embedded in the broader European standardization work of CEN/CLC/JTC 24 — the Joint Technical Committee working on overarching European standards for digital product passports. The DIN SPEC serves as preparatory work and reference for the upcoming EN standards (European Norms) being developed under the ESPR (Ecodesign for Sustainable Products Regulation).
The publication as DIN DKE SPEC 99100:2025-02 in February 2025 marks an important milestone: for the first time, a complete, technically implementable data model for the battery passport exists, jointly supported by industry, academia, and standardization bodies.
The 7 Data Categories in Detail
The heart of DIN SPEC 99100 consists of seven clearly delineated data categories corresponding to sections 6.1 through 6.7 of the specification. Each category addresses a specific aspect of the battery lifecycle and contains both mandatory and optional fields.
- Identification and Product Data (6.1) — Unique identifiers, manufacturer info, battery type
- Labeling and Conformity (6.2) — CE marking, EU declaration of conformity, test reports
- Carbon Footprint (6.3) — Lifecycle emissions, performance classes
- Supply Chain Due Diligence (6.4) — Due diligence obligations, OECD guidelines, audits
- Materials and Composition (6.5) — Raw materials, hazardous substances, origin data
- Circularity and Resource Efficiency (6.6) — Recycled content, recyclability, disassembly
- Performance and Durability (6.7) — Capacity, energy density, cycle life, lifespan
1. Identification and Product Data (Section 6.1)
This category forms the foundation of the battery passport. It encompasses all data that uniquely identifies a battery: the GS1 Digital Link as the primary identifier, manufacturer information (name, address, contact details), battery type (EV, industrial, LMT), model designation, production date, and manufacturing facility location. This data enables complete traceability of each individual battery throughout its lifecycle.
2. Labeling and Conformity (Section 6.2)
This section captures all regulatory conformity information: CE marking, the EU declaration of conformity (as a manufacturer document), test reports, and relevant symbols. This category documents that the battery meets all applicable requirements and that corresponding evidence is available. The EU declaration of conformity is a document issued by the manufacturer — its creation and accuracy is the responsibility of the economic operator.
3. Carbon Footprint (Section 6.3)
The carbon footprint captures greenhouse gas emissions across the entire lifecycle of the battery — from raw material extraction through processing and cell manufacturing to transport. The value is expressed in kg CO₂ equivalent per kWh of rated energy. Additionally, information on the calculation methodology and the standard used is documented. Starting August 2028, CO₂ performance classes will be introduced to enable comparability between batteries based on their footprint.
4. Supply Chain Due Diligence (Section 6.4)
Supply chain due diligence is a central component of the battery passport. This category requires proof that the manufacturer complies with due diligence obligations in accordance with the OECD Due Diligence Guidance for responsible supply chains. This includes information on raw material sourcing, supply chain risks, audits conducted, and measures taken. This is particularly relevant for critical raw materials such as cobalt, lithium, and nickel, whose extraction can be associated with human rights and environmental risks.
5. Materials and Composition (Section 6.5)
This category requires a detailed breakdown of battery materials: cathode material (e.g., NMC, LFP, NCA), anode material (e.g., graphite, silicon), electrolyte, separator, and housing materials. For critical raw materials — including lithium, cobalt, nickel, and manganese — specific quantity information and origin data are required. Furthermore, hazardous substances must be declared in accordance with the REACH regulation. This data is essential for assessing environmental impact and for subsequent recycling.
6. Circularity and Resource Efficiency (Section 6.6)
In the spirit of the circular economy, this category requires information on recycled content (share of recycled materials), recyclability of the battery, disassembly instructions, and planned second-life use. Recycling companies thus receive the information needed to efficiently disassemble batteries and recover valuable raw materials. From 2031 onward, binding minimum quotas for recycled content of certain raw materials will apply.
7. Performance and Durability (Section 6.7)
The final category encompasses performance and durability metrics for the battery: rated capacity (in Ah and kWh), energy density, power density, expected charge cycles, internal resistance, temperature range, and expected lifespan (in cycles and years). This data enables objective comparison between different battery products and is relevant for buyers, operators, and resellers alike. Beyond these static rated values, DIN SPEC 99100 Section 6.7 also requires dynamic condition data from the BMS — such as state of charge, capacity fade, and temperature extremes.
The seven data categories of DIN SPEC 99100 — Identification, Labeling, Carbon Footprint, Due Diligence, Materials, Circularity, and Performance — together form a complete picture of the ecological, social, and technical properties of a battery. Each category is defined by its own JSON schema.
Mandatory vs. Optional Fields
Not all fields in DIN SPEC 99100 are mandatory for every battery type. The specification distinguishes between mandatory and optional fields — with mandatory fields varying by battery type. As a general rule: the larger and more complex the battery, the more extensive the mandatory requirements.
EV Batteries (Traction Batteries)
Electric vehicle batteries face the most comprehensive requirements. Nearly all fields across the seven categories are mandatory — including detailed material composition data, carbon footprint with calculation methodology, full supply chain due diligence documentation, and comprehensive performance metrics such as rated capacity, energy density, charge cycles, and internal resistance.
Industrial Batteries (> 2 kWh)
Industrial batteries with a capacity exceeding 2 kWh are also subject to extensive mandatory requirements, though with slightly reduced obligations in certain performance fields. The core areas of identification, materials, carbon footprint, and due diligence are fully mandatory. Optional fields are found primarily in specific durability and cycle data that may be less relevant for stationary applications.
LMT Batteries (Light Means of Transport)
LMT batteries — those for e-bikes, e-scooters, and similar light electric vehicles — face the fewest mandatory requirements. Identification and basic material data are mandatory, but many fields relating to performance data and detailed circularity information are optional. This reflects the lower risk potential and simpler structure of these batteries.
Examples of Mandatory vs. Optional Fields
In concrete terms: the field "Manufacturer Identification" is mandatory for all battery types. The CO₂ footprint per kWh is obligatory for EV and industrial batteries but initially optional for LMT batteries. Disassembly instructions are mandatory for EV batteries but optional for smaller battery types. The detailed cathode composition (e.g., percentage of cobalt) is mandatory for all battery types with corresponding cell chemistry.
DIN SPEC 99100 and the EU Battery Regulation
A central point that manufacturers must understand: DIN SPEC 99100 is a pre-standard — it is not directly legally binding. The legally binding requirements for the digital battery passport will be defined by the EU Battery Regulation (EU 2023/1542) and its associated Delegated Acts under Art. 77 and Art. 78.
DIN SPEC 99100 serves as technical preparation for these Delegated Acts. Since the specification was developed with the involvement of the same experts and institutions contributing to the EU Delegated Acts, it is widely expected that the final version of the Delegated Acts will be very close to DIN SPEC 99100. Significant content deviations are considered unlikely.
The EU Battery Regulation timeline envisions publication of the Delegated Acts during 2026. The deadline for mandatory battery passports is February 18, 2027. By that date, manufacturers of EV batteries, industrial batteries above 2 kWh, and LMT batteries must be able to provide a complete digital battery passport.
In practical terms, this means: companies preparing today on the basis of DIN SPEC 99100 are building on the best available standard. Investing in data collection and structuring according to DIN SPEC 99100 is not speculation but well-founded preparation for upcoming regulatory requirements. Companies implementing the DIN SPEC 99100 data structure will likely need only minimal adjustments when the Delegated Acts are published.
Learn more in our articles about the EU Battery Regulation and the 2027 timeline and about what a battery passport actually is.
Technical Implementation: JSON Schema and API
DIN SPEC 99100 defines not only the content requirements but also the technical structure for the data. The reference implementation uses the BatteryPassDataModel v1.2.0 — a set of seven JSON schemas corresponding to the seven data categories.
Each JSON schema defines the allowed fields, data types, mandatory/optional designations, and validation rules. A battery passport dataset that can be validated against these schemas fulfills the structural requirements of DIN SPEC 99100. The schemas use established web standards such as JSON Schema Draft 2020-12 and are accessible through public repositories.
For data access, the specification provides that battery passport data is retrievable via a QR code or a GS1 Digital Link. The GS1 Digital Link functions as a unique URL pointing directly to the dataset of the respective battery. Authorities, recyclers, and other authorized parties can access the data through a simple scan.
For companies with large product portfolios, integration via a REST API is recommended. Existing systems — ERP, PLM, MES — can programmatically create and update battery passport data, either through a single-product API or bulk import. This enables efficient management even with hundreds or thousands of battery products.
Specialized software tools like DPP Hero provide the DIN SPEC 99100 data structure out of the box. Data entry follows a step-by-step guided interface, with JSON export, PDF export, and QR code generation integrated. Companies looking to make the transition from Excel spreadsheets to a structured battery passport will find specialized tools to be the most efficient path.
Comparison with Other Standards
DIN SPEC 99100 does not exist in a vacuum — it relates to several other standards and initiatives. To avoid confusion, a clear delineation is helpful:
ESPR (Ecodesign for Sustainable Products Regulation)
The ESPR is the overarching European legal framework for digital product passports — not just for batteries but for a wide range of product categories (textiles, electronics, construction materials, etc.). The EU Battery Regulation and the battery passport represent the first concrete application of the DPP concept. DIN SPEC 99100 is the technical specification specifically for the battery sector within this broader framework.
Battery Pass Content Guidance (2023)
The Battery Pass Content Guidance was published in 2023 by the Battery Pass Consortium and served as a preliminary draft for DIN SPEC 99100. It contained initial recommendations for data structure and mandatory fields. With the publication of DIN DKE SPEC 99100:2025-02, the Content Guidance is effectively superseded. Companies should use DIN SPEC 99100 exclusively as their reference.
CEN/CLC/JTC 24
The Joint Technical Committee 24 of CEN and CENELEC is working on broader European standards for digital product passports — beyond the battery sector. JTC 24's work is expected to result in EN standards (European Norms) that will function as harmonized standards under the ESPR. DIN SPEC 99100 provides important groundwork for this effort, particularly in the area of data modeling and schema definition.
GBA Battery Passport (Global Battery Alliance)
The Global Battery Alliance (GBA) is an international multi-stakeholder initiative pursuing its own battery passport approach. The GBA approach differs from DIN SPEC 99100 in scope and level of detail: it focuses more strongly on ESG metrics (Environmental, Social, Governance) and is not directly tied to EU regulation. For companies serving the EU market, DIN SPEC 99100 is the authoritative reference.
Frequently Asked Questions about DIN SPEC 99100
Is DIN SPEC 99100 already legally binding?
No. DIN SPEC 99100 is a pre-standard. It will only become legally binding when the European Commission publishes the corresponding Delegated Acts under Art. 77/78 of the EU Battery Regulation. These Delegated Acts are expected to be adopted in 2026 and will define the binding data model for the battery passport. DIN SPEC 99100 serves as the technical foundation and is expected to be adopted very extensively.
Can DIN SPEC 99100 still change?
In principle, yes. When the Delegated Acts are published, minor adjustments are possible — for example, in the naming of individual fields, validation rules, or the classification of mandatory and optional fields for certain battery types. However, fundamental structural changes to the seven data categories or the JSON schema approach are considered highly unlikely, as the specification was developed in close coordination with EU institutions.
Do I need special software for the battery passport?
Special software is not strictly required but is strongly recommended in practice. The DIN SPEC 99100 data structure encompasses hundreds of fields across seven categories with complex dependencies and validation rules. A manual approach (e.g., via Excel spreadsheets) quickly becomes error-prone and is not scalable. Software tools like DPP Hero significantly simplify the process — from guided data entry in seven steps through automatic validation to export as JSON, PDF, and QR code.
Where can I find the complete specification?
DIN DKE SPEC 99100:2025-02 is available as a document through DIN Media, and the associated JSON schemas (BatteryPassDataModel v1.2.0) are publicly accessible. In practice, however, you don't need to read the specification yourself: specialized software like DPP Hero has the entire data structure — all seven categories with every mandatory and optional field — already built in and guides you step by step through data entry.
What happens if the Delegated Acts deviate from DIN SPEC?
Should the Delegated Acts deviate from DIN SPEC 99100 on individual points, manufacturers will need to adjust their data accordingly. Since the fundamental structure (seven categories, JSON schema-based) is very likely to be maintained, such adjustments would presumably be manageable. Companies working according to DIN SPEC 99100 today will in any case have a significant head start over those that only begin preparation after the Delegated Acts are published.