Access control
An authority sees less than a recycler.
That sentence surprises people, so here is the mechanism rather than the claim. Pick an audience below and watch which parts of the record appear.
Everything on this page is Regulation (EU) 2023/1542 Art. 77(2) and Annex XIII, quoted from the consolidated text. It is the battery passport — see the note at the foot of the page for why that matters.
Basis: Art. 77(2)(a)
Point 1 — public battery model information
Material composition, carbon footprint, recycled content, rated capacity, expected lifetime, declaration of conformity, waste management information.
Point 2 — model information for legitimate interest and the Commission
Detailed composition, dismantling instructions and the safety measures dismantling requires.
Point 3 — conformity evidence
"Results of test reports proving compliance with the requirements laid down in this Regulation".
Authority only — not visible to a recycler.
Point 4 — the individual battery's own history
State of health, battery status, and "data resulting from its use, including the number of charging and discharging cycles and negative events, such as accidents, as well as periodically recorded information on the operating environmental conditions, including temperature, and on the state of charge".
Legitimate interest only — not visible to an authority.
Why it is not a ladder
Neither audience contains the other.
Art. 77(2) assigns points 2 and 3 to notified bodies, market surveillance authorities and the Commission, and points 2 and 4 to holders of a legitimate interest.
Point 3 is absent from the second list. Point 4 is absent from the first. No ordering can express that, so no integer "tier" can either — which is why an implementation that models access as a ladder with the regulator on top produces the wrong answer for point 4.
Point 4 is the individual battery's own use history: charge cycles, accidents, temperature, state of charge. For an electric vehicle that is a usage record of an identifiable vehicle. Handing it to an audience the law does not grant it to is a personal-data disclosure, not a display bug.
Scope
This is the battery passport, and only the battery passport.
ESPR does not impose this lattice. Art. 11(b) gives actors access "based on their respective access rights set out in the applicable delegated act adopted pursuant to Article 4" — so the split belongs to each product group's own act.
For batteries that act exists and is quoted above. For textiles, electronics, furniture and the rest, no delegated act has been adopted, so there is no authority/legitimate-interest split to show. We model that as absence rather than guessing, and the product group manifests carry only the classes their own law defines.
A fixed three-tier access model, applied everywhere, would be encoding one product group's rule as if it were the regulation's.