(EU) 2023/1542 · Annex XIII(2)(c)
Amount of cells and layout: the regulation counts cells, the industry counts modules
Of the six items in point 2(c) this is the only numerical one, which also makes it the easiest to check. The difficulty is not availability — the data sits in the bill of materials — but the unit. Industry documentation usually describes a pack in modules and configuration strings, while the regulation asks for the amount of cells used. Article 3 defines cell, module and pack as three different things, so moving between them is not a simplification but an answer to a different question than the one asked.
Three definitions that cannot be substituted for one another
Article 3 defines a battery cell as the basic functional unit composed of electrodes, electrolyte, container, terminals and, if applicable, separators. A battery module is a set of cells connected together or encapsulated in a casing to protect them against external impact. A battery pack is a set of cells or modules forming a complete unit which is not meant to be split up or opened by the end-user. The field asks for the amount of cells used. In cell-to-pack designs the module level, in these terms, does not exist at all.
The layout has to agree with the exploded diagram
The first indent of the same point requires exploded diagrams of the battery system or pack showing the location of battery cells. The same geometry is therefore described twice — once graphically, once as a layout. A mismatch between the cell count here and the cells shown in the diagram is the first thing a reader notices, and under Article 77(4) it means the information is not accurate. Describing the layout in words alone, with no geometry, makes that cross-check impossible to perform.
Why this particular number is the most commercially sensitive
The cell count and layout expose the pack architecture more precisely than any other item in the set. The criterion in Article 77(9)(c) requires that access to and processing of commercially sensitive passport information be limited to the minimum necessary. The item is nonetheless mandatory, because remanufacturing under Article 3 includes the disassembly and evaluation of all cells and modules — without a cell count a remanufacturer cannot size the job.
Where it goes wrong
- Reporting the module count as the cell count.
- Giving a series-parallel configuration string without the actual number of cells.
- Describing the layout in words with no geometry that could be compared to the exploded diagram in the first indent.
- Taking the number from the design intent rather than from the built configuration of the model placed on the market.
Frequently asked
Do we state modules or cells?
The item requires the amount of cells used. Article 3 defines cell, module and pack separately, so a module figure does not cover the question.
What if the pack has no modules at all?
Then the cell count is simply the pack-level count. In Article 3 terms, the module level does not exist for such a design and does not have to be invented.
Is this data public?
No. It sits in point 2 of Annex XIII — accessible to persons with a legitimate interest and the Commission, and under Article 77(2)(b) also to notified bodies and market surveillance authorities.
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