(EU) 2023/1542 · Annex XIII(1)(a) -> Annex VI, Part A(6)
Capacity: one word carrying two physical quantities
The trap in this field sits somewhere other than most people expect. It is not about which datasheet number to copy; it is that the regulation uses the word capacity in different places for two different physical quantities. In one place it is charge in ampere-hours, in another it is energy in kilowatt-hours — and it is the kilowatt-hour reading that decides whether you need a passport at all. Article 3 does not define the term, and the only definition of rated capacity is confined to a single annex.
Which quantity the regulation uses where
Article 77(1) and Article 13(6)(a) speak of an industrial battery with a capacity greater than 2 kWh, that is, of energy. Point 1(g) of Annex XIII requires rated capacity in ampere-hours, that is, charge. Point 6 of Part A of Annex VI asks only for “the capacity”, with no unit. Article 3 does not define capacity. Annex IV does define rated capacity as the total number of ampere-hours that can be withdrawn from a fully charged battery under reference conditions, but expressly for the purposes of that annex.
At 2 kWh this is a scope question, not a specification
For a product between roughly two and three kilowatt-hours, the answer in this field is not a product attribute but an answer to whether Chapter IX binds you at all. And the regulation prescribes no method for the kilowatt-hour figure: nameplate energy, usable energy after a depth-of-discharge window, and beginning-of-life energy give three different numbers. We do not settle that question for you. We check whether your file records which of those values was used and which measurement it came from.
For some batteries capacity appears on the label twice
Article 13(1) puts the content of Part A of Annex VI on the label. Article 13(2) additionally requires rechargeable portable batteries, LMT batteries and SLI batteries to bear a label containing information on their capacity — a standalone provision with its own legal basis, not discharged by the first entry. The format of both is to be harmonised by the implementing act that the Commission was to adopt by 18 August 2025 under Article 13(10); we do not assert on this page whether it has been adopted, because we have not verified that at source.
Where it goes wrong
- Concluding a battery is out of scope because the field holds ampere-hours — the Article 77(1) threshold is expressed in kilowatt-hours.
- Usable energy after a depth-of-discharge window in one document and nameplate energy in another, for a product close to 2 kWh.
- Treating the Annex IV definition of rated capacity as a general definition, although it applies expressly for the purposes of that annex.
- Assuming the Part A of Annex VI entry also satisfies the capacity label under Article 13(2) — those are two separate provisions.
Frequently asked
Does the regulation set a unit for this field?
Point 6 of Part A of Annex VI does not. Point 1(g) of Annex XIII requires ampere-hours for the passport, while the threshold in Article 77(1) is expressed in kilowatt-hours. The same word carries two quantities.
When does an industrial battery need a passport?
Under Article 77(1), from 18 February 2027 each industrial battery with a capacity greater than 2 kWh that is placed on the market or put into service must have an electronic record.
Where is rated capacity defined?
In the first definition of Annex IV: the total number of ampere-hours that can be withdrawn from a fully charged battery under reference conditions. That definition applies expressly for the purposes of that annex, and Article 3 does not define capacity.
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