(EU) 2023/1542 · Annex XIII(1)(a) -> Annex VI, Part A(7)
Battery chemistry: the shortest field with the longest shadow
This is the shortest field in all of Annex VI and simultaneously the one that determines the most. Chemistry is not a standalone data point; it is the key that unlocks or locks several other fields. Companies fill it in first and in three seconds, then wonder why the other fields do not add up.
What chemistry determines downstream
If you state NMC, you have said the battery contains nickel and cobalt — which immediately triggers the critical raw materials field and the recycled content field, which concerns precisely cobalt, lithium and nickel. If you state LFP, nickel and cobalt are out while lithium remains. Chemistry therefore tells you in advance which other fields you will have to complete and which you will not.
A type designation is not a composition
Point 7 of Part A of Annex VI requires the chemistry; point 1(b) of Annex XIII requires the material composition including chemistry, hazardous substances and critical raw materials. Those are two different levels of detail. The abbreviation LFP satisfies the first but not the second, where you need cathode, anode and electrolyte materials.
The same data also goes on the label
Because this field sits in Part A of Annex VI, it is simultaneously label content under Article 13(1). The labelling deadline is conditional and may fall before the passport deadline. Anyone who settles the chemistry only when preparing the passport may need it earlier.
Where it goes wrong
- Stating a cell trade designation instead of the chemistry.
- Using the abbreviation LFP or NMC as the answer to the material composition field — that is a different, more detailed field.
- Switching to a cell supplier with a different chemistry without updating the linked fields.
- One chemistry for several product variants that in fact use different cells.
Frequently asked
Is “Li-ion” sufficient?
Not for a meaningful entry. The regulation asks for the chemistry; “Li-ion” is a family, not a chemistry. LFP, NMC, NCA or LTO state what is in the battery and determine the linked fields.
What is the difference between chemistry and material composition?
Chemistry is point 7 of Part A of Annex VI and is a short entry. Material composition is point 1(b) of Annex XIII and also covers hazardous substances and critical raw materials.
What if the same model uses cells from two suppliers?
If the chemistry differs, these are two variants with different data. The passport attaches to the battery model, so the difference must be visible.
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