(EU) 2023/1542 · Annex XIII(4)(d)
Battery use data: the only field that does not end at the point of sale
Every other passport field describes the battery as it was placed on the market. This one describes what happened to it afterwards. It therefore cannot be solved with a document or a supplier declaration — it has to be solved in product design, before the first battery leaves the factory.
What must be collected
Point 4(d) of Annex XIII requires information and data resulting from the battery's use: the number of charging and discharging cycles, negative events such as accidents, and periodically recorded information on operating environmental conditions, including temperature, and on the state of charge. The word “periodically” is decisive — this is a record over time, not a snapshot at the point of sale.
The link to the Annex VII parameters
Part B of Annex VII, on parameters for determining the expected lifetime of stationary systems and LMT batteries, lists the date of manufacture and where appropriate the date of putting into service, energy throughput, capacity throughput, the tracking of harmful events such as deep discharges and time spent in extreme temperatures, and the number of full equivalent charge-discharge cycles. In practice these are the same data your system must log.
Access is restricted; the duty to collect is not
Point 4 of Annex XIII places this data among information accessible only to persons with a legitimate interest. Who those are is to be set by the implementing act under Article 77(9), due by 18 August 2026. Restricted access does not mean a lighter collection duty — you must hold the data even if not everyone will see it.
Why this is an architecture decision
A record across the service life means on-device storage or a cloud link, timestamps, retention and a way to export. If the battery cannot do this at the point of sale, the data cannot be created retrospectively. This field therefore belongs in the product roadmap, not in a compliance project.
Where it goes wrong
- Treating this field as a document — it is a record that accumulates over time.
- Logging cycle counts without negative events and operating conditions.
- Data held in a closed system with no export path for persons with a legitimate interest.
- Deferring it in the roadmap: for batteries already on the market the data cannot be recovered.
Frequently asked
Which use data are required?
The number of charging and discharging cycles, negative events such as accidents, and periodically recorded operating environmental conditions including temperature, and the state of charge. Point 4(d) of Annex XIII.
Is a snapshot at the point of sale enough?
No. The text speaks of periodically recorded information and of data resulting from use — that is, a record over time.
Who will have access to this data?
Persons with a legitimate interest. Who those are must be specified by the Commission in an implementing act under Article 77(9) by 18 August 2026.
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