Mandatory fields, explained one by one
Annex XIII is not one list with one deadline. Each field has its own article, its own deadline and its own evidence. We explain them individually — starting where we see the most confusion.
Fields covered: 15 of 51 in the rulepack
Battery carbon footprint in the passport: when it actually falls due
The carbon footprint declaration has four different deadlines by battery category, and all of them are conditional. What that means in practice, and who produces the calculation.
Annex XIII(1)(c) conditionalRecycled content in batteries: why you do not owe this yet
The share of recycled cobalt, lithium, nickel and lead falls due 18 August 2028 — 2033 for LMT batteries — not at the passport deadline. What that means for your budget.
Annex XIII(1)(e) already appliesBattery state of health (SoH): an obligation running since 2024
State-of-health data must have been in the battery management system since 18 August 2024. Most obligated parties do not know this. What the BMS must hold and who must be able to read it.
Annex XIII(4)(b) -> Annex VII, Part A due 18 Feb 2027EU declaration of conformity for batteries: what belongs in it
The declaration under Article 18 attests compliance with Articles 6 to 10 and 12, 13 and 14. It follows the model structure in Annex IX and must be kept up to date — not signed once.
Annex XIII(1)(r) already appliesBattery performance parameters: an obligation running since August 2024
The document with electrochemical performance and durability values has been mandatory since 18 August 2024. Which parameters, which tests, and why this is not a 2027 field.
Annex XIII(4)(a) -> Annex IV, Part A(1) already appliesBattery due diligence: who is exempt, and who is already late
Companies under EUR 40 million net turnover are exempt from the whole chapter under Article 47. For everyone else the duty has applied since 18 August 2025 and requires notified body verification.
Annex XIII(1)(d) due 18 Feb 2027Hazardous substances in a battery: the field asks about everything but three
Annex VI requires hazardous substances “other than mercury, cadmium or lead”, because those three are already restricted by Annex I. What that means for your safety data sheet and SCIP notification.
Annex XIII(1)(a) -> Annex VI, Part A(8) due 18 Feb 2027Critical raw materials above 0.1%: the field the regulation gives no list for
Annex VI requires critical raw materials above 0.1% by weight, yet the regulation never defines the term. Which list applies, and how to handle that without guessing.
Annex XIII(1)(a) -> Annex VI, Part A(10) already appliesBattery marking: one deadline has already passed, another is not yet fixed
The separate collection symbol has been mandatory since 18 August 2025 without exception. The general label has a conditional deadline, and the Pb marking bites at a lower threshold than Annex I allows.
Annex XIII(1)(q) due 18 Feb 2027Dismantling information: six requirements and an open question about who may see it
Annex XIII requires exploded diagrams, disassembly sequences, fastening techniques, tools, warnings and cell layout. It is not public — and who is entitled to it is set by an act not yet adopted.
Annex XIII(2)(c) due 18 Feb 2027Rated capacity in ampere-hours: the same number in four places
Annex XIII requires rated capacity in Ah, Annex VI requires “capacity”, and Annex IV requires capacity with fade. When these disagree, any reviewer will notice.
Annex XIII(1)(g) due 18 Feb 2027Expected lifetime in cycles: a number without a test is not data
Annex XIII requires expected battery lifetime in cycles “and reference test used”. Without the test conditions, two figures are not comparable even when they are identical.
Annex XIII(1)(j) due 18 Feb 2027Battery chemistry: the shortest field with the longest shadow
“LFP” or “NMC” is a three-character answer, yet it determines at least four other passport fields — hazardous substances, critical raw materials, recycled content and carbon footprint.
Annex XIII(1)(a) -> Annex VI, Part A(7) due 18 Feb 2027Round trip energy efficiency: the second value is the trap
Annex XIII requires the initial efficiency AND the efficiency at 50% of cycle-life. The second cannot be measured on a new battery — and it is what stalls most preparations.
Annex XIII(1)(n) due 18 Feb 2027Battery use data: the only field that does not end at the point of sale
Cycles, negative events, operating conditions and state of charge are collected across the battery's life. This is not a document but a requirement on product design.
Annex XIII(4)(d)We add the remaining fields gradually. Each one gets a real explanation — we do not publish empty pages.