(EU) 2023/1542 · Annex XIII(1)(a) -> Annex VI, Part A(4)
Date of manufacture: the clock runs from placing on the market, not from the build
Month and year. It is hard to imagine a field with less room for error — yet this is the field companies most often use to miscalculate whether the obligation reaches them at all. The reason is simple: they mistake the date of manufacture for the clock that governs the deadline. It does not. On top of that, the regulation never says which production step counts as manufacture, and it demands the same date a second time, more precisely, in a system run by different people.
Stock built earlier is not exempt
Article 77(1) provides that from 18 February 2027 each LMT battery, each industrial battery with a capacity greater than 2 kWh and each electric vehicle battery placed on the market or put into service shall have an electronic record. The trigger is placing on the market or putting into service, not the build date. Article 3 defines placing on the market as the first making available of a battery on the Union market, and putting into service as the first use in the Union for its intended purpose without prior placing on the market. A 2026 battery shipped from stock in mid-2027 needs a passport.
The regulation does not say which step is manufacture
Cell production date, pack assembly date, end-of-line test date and release-to-stock date can be months apart for storage products. The regulation designates none of them and does not define the term. The choice is therefore not wrong as long as it is consistent and recorded: every unit of a model has to be dated by the same step, or the data is not comparable even with itself, let alone with your supplier's documentation.
The same date exists again, per unit
Point 1 of Part B of Annex VII requires the date of manufacture of the battery and, where appropriate, the date of putting into service, among the parameters for determining the expected lifetime of stationary battery energy storage systems and LMT batteries. Under Article 14(1) that data has had to sit in the battery management system since 18 August 2024. So the label and the public passport carry a month and year at model level while the BMS carries a per-unit date — and because two different systems write them, in practice they drift apart.
Where it goes wrong
- Concluding that a battery built before 18 February 2027 needs no passport — Article 77(1) attaches the obligation to placing on the market or putting into service.
- The cell production date copied across as the battery's date of manufacture.
- An encoded batch marking instead of month and year; the field asks for a month and a year, not for a decoding key.
- A month and year in the passport that do not match the date in the BMS under point 1 of Part B of Annex VII.
- A repurposed battery keeping the original date, although Article 77(7) requires a new passport linked to the original battery's passport.
Frequently asked
Does a battery built before the deadline need a passport?
Yes, if it is placed on the market or put into service from 18 February 2027. Article 77(1) attaches the obligation to that event rather than to the build date, so stock built ahead does not escape it.
Which production step governs?
The regulation does not say. Whichever step you choose has to be applied consistently across all units of the model and has to be reconcilable with the BMS date where point 1 of Part B of Annex VII applies.
Why only month and year?
That is what point 4 of Part A of Annex VI requires. The finer, per-unit date is required by point 1 of Part B of Annex VII, and it belongs in the battery management system rather than on the label.
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