(EU) 2023/1542 · Annex XIII(4)(b) -> Annex VII, Part A
Battery state of health (SoH): an obligation running since 2024
If one field in the whole regulation catches companies out, it is this one. It does not fall due on 18 February 2027 — it has applied since 18 August 2024. Anyone who has placed a stationary system, LMT or EV battery on the market since then without this data in the BMS has a retroactive gap.
What the BMS must contain
Article 14(1) requires up-to-date data for the parameters in Annex VII to be held in the battery management system. For electric vehicle batteries that is the state of certified energy (SOCE). For stationary battery energy storage systems and LMT batteries it is remaining capacity, where possible remaining power capability, where possible remaining round trip efficiency, the evolution of self-discharging rates and, where possible, ohmic resistance.
Third parties must be able to read it
Article 14(2) requires read-only access to that data on a non-discriminatory basis for anyone who has legally purchased the battery — including independent operators and waste management operators. A closed proprietary protocol with no documented access does not satisfy this.
The software reset function
Article 14(3) requires the BMS to include a software reset function for cases where operators carrying out preparation for re-use or remanufacturing need to upload different software. That is a design requirement, not a documentation one — it cannot be added retrospectively with a certificate.
Where it goes wrong
- Assuming this is a passport requirement due in 2027. It has applied since 18 August 2024.
- The data exists in the BMS but there is no documented read access for third parties.
- Reporting only SOCE, which is intended for EV batteries, on stationary or LMT products.
- A missing software reset function — a hardware and firmware design problem, not a paperwork one.
Frequently asked
Since when has the state-of-health obligation applied?
Since 18 August 2024. Article 14(1) requires up-to-date data for the Annex VII parameters in the BMS of stationary systems, LMT and EV batteries.
Which parameters are required for a stationary system?
Remaining capacity, where possible remaining power capability, where possible remaining round trip efficiency, the evolution of self-discharging rates and, where possible, ohmic resistance.
Can I restrict access to my authorised service partners?
No. Article 14(2) requires non-discriminatory read access for any natural or legal person who has legally purchased the battery, including independent operators.
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