DIN SPEC 99100 software
for the battery passport

What DIN DKE SPEC 99100 is, and what it is not

The name regularly misleads. DIN DKE SPEC 99100:2025-02 is not a standard in the narrow sense, nor a pre-standard, but a DIN SPEC under the PAS procedure: a publicly available specification drawn up and funded by a consortium in a workshop process. The broad consensus of formal standardization is deliberately not waited for.

No presumption of conformity

Harmonised standards create a presumption of conformity; whoever works to them counts as compliant to that extent. Implementing Decision (EU) 2026/1736 lists six standards for that purpose, EN 18216 to EN 18223. That presumption applies under the Ecodesign Regulation, not to the battery passport, and DIN SPEC 99100 is not in the decision anyway. Applying it is voluntary and does not replace a check against the regulation.

Why it still helps

What binds is Annex XIII of the Battery Regulation. It says which entries belong in the passport and who may see them, but it supplies no data structure. The specification fills exactly that gap: it sorts the entries into seven categories and names attributes, data types and obligation levels. As a blueprint that is usable; as a legal basis it is not.

Anyone selecting software on this basis should separate the two. The specification shows whether a provider takes the data structure seriously. Whether the passport satisfies the regulation is decided by the regulation text.

Six checks that are specific to DIN SPEC 99100

There are separate pages for general software selection. Here it is only about the questions arising from the specification itself. They can be asked in a meeting and checked without expert knowledge.

1. Are all seven data categories implemented, or only the convenient ones? Identification, materials, carbon footprint, due diligence, circularity, performance and durability, labeling. Ask to see each one in the editor, not on a slide.
2. Which edition is implemented? The relevant one is DIN DKE SPEC 99100:2025-02. An older edition, or an implementation “broadly aligned with” it, is something else than the specification itself.
3. What happens if the EU legal act diverges? DIN SPEC 99100 is a guideline, not a legal obligation. What binds you is the regulation itself: Annex XIII for the content, Article 77(5) and Article 78 for open standards, an interoperable format and transferability without vendor lock-in. What is still missing are individual implementing acts, for example on the legitimate interest. Ask how the provider follows a divergence and who pays for the change.
4. Is there schema validation, or just a form to fill in? Passport data is read by machines. Ask to see what happens on export when a mandatory field is missing or a unit is wrong.
5. Are the access levels separated on the server? Annex XIII knows public data, data for persons with a legitimate interest and an authority level. Restricted fields must not merely be hidden in the interface. They must not appear in the source of the public passport page at all.
6. How does the data get out again? Article 77(5) requires open standards, an interoperable format and transferability without vendor lock-in. Ask to see a complete export before you commit.

Whether building your own pays off is covered in the guide build a battery passport yourself or use software. The provider types on the market are in the software comparison. The general selection criteria are in the guide battery passport software.

The seven data categories and what sits behind them

The specification divides passport data into seven categories. Three are uncritical today; four bring the actual work in practice.

Master data and labeling

Identification plus labeling and declaration of conformity are master data. That means manufacturer, model, identifiers, CE and the details from the label. With GTIN and GLN in hand this is a morning of work.

The four categories with real effort

Materials and composition require supplier data. The carbon footprint needs a life cycle calculation whose binding methodology is still outstanding. Supply chain due diligence concerns only economic operators above the turnover threshold in Article 47 and applies from 18 August 2027. Performance and durability, finally, are measured values that have to come from testing. In substance this covers the raw materials cobalt, natural graphite, lithium and nickel and the risks listed in Annex X, among them working conditions in raw material extraction: occupational health and safety, child labor, forced labor, discrimination and trade union freedoms. How the specification lands on the exhibition floor is covered in our review of Hannover Messe; terms are explained in the battery passport glossary.

The circularity category collects data on dismantling, spare parts and recycling. It is the part repair and recycling operations benefit from most. That is exactly why Annex XIII keeps it out of the public block, reserved for persons with a legitimate interest.

The nameplate: what Annex VI requires

The passport does not replace the label, it comes on top. Annex VI Part A lists what has to be on every battery. That is data identifying the manufacturer, the battery category and the identification of the battery. On top of that come place and date of manufacture with month and year, weight, capacity and chemical composition, as well as the hazardous substances contained, other than mercury, cadmium or lead. And finally the extinguishing agent to use and critical raw materials above 0.1 percent by weight.

These entries are master data, the same that go into the passport. Maintain them once properly and you serve both duties from one source. Keep them twice and you have two versions that drift apart.

On affixing, Article 13(7) is clear. Required are visible, legible and indelible, printed or engraved. Where nature and size do not allow it, marking and QR code may go on the packaging. The same applies to the accompanying documents.

The date hangs on an act that is still pending. Under Article 13(1) the labeling duty applies from 18 August 2026 or 18 months after the implementing act enters into force. The later date counts. Under paragraph 10 the Commission was to adopt that act by 18 August 2025. It sets the harmonized specifications for the label.