(EU) 2023/1542 · Annex XIII(1)(h)
Minimal, nominal and maximum voltage: a cell figure is not a pack figure
The field looks like copying three numbers from a catalogue, which is exactly why it fails. Point 1(h) of Annex XIII requires minimal, nominal and maximum voltage, with temperature ranges when relevant — yet the Regulation defines none of those terms and never says when temperature ranges are “relevant”. The figures a manufacturer has to hand are almost always cell figures sent by the supplier. The battery placed on the market, however, is a pack, and there the same three numbers mean something else.
The Regulation does not define these terms
Annex IV defines rated capacity, capacity fade, power, power fade, internal resistance and energy round trip efficiency — voltage is not among them. The phrase “rated voltage” appears only incidentally, inside the definitions of capacity fade and power fade. That means your own source must state what counts as the minimum and what as the maximum, and that reading must stay identical everywhere voltage appears.
Cell and pack are different things in the Regulation
Article 3 separately defines a battery cell as the basic functional unit and a battery pack as a set of cells or modules connected or encapsulated in an outer casing forming a complete unit not meant to be split up or opened by the end-user. The passport is issued for the battery placed on the market. If that is a pack, these are pack voltages: series connection multiplies them, parallel does not, and balancing and protection constrain them further. A cell datasheet does not contain those values and cannot.
The minimum is a setting, not a material property
In practice the minimum is not set by chemistry but by the battery management system — under Article 3 an electronic device that controls or manages the electric and thermal functions of the battery. The cut-off is a value in software. Two consequences follow: the evidence for this field is the system specification naming the software version, not the cell datasheet; and if you change the cut-off, you have changed a technical characteristic by which Article 3 defines the model.
“When relevant” is your call
The text adds temperature ranges “when relevant” without saying when that is. Where the Regulation wants a test, it says so plainly: point 1(j) requires the reference test used, point 1(l) names a reference test in brackets. Point 1(h) names nothing. Whether temperature ranges are relevant is therefore your judgement — and because it is yours, it must be recorded with its reason, or it reads as an omission.
Where it goes wrong
- Copying cell datasheet voltages into a passport issued for a pack.
- Cell maximum charge voltage multiplied by the number of cells in series, ignoring the cut-off the battery management system actually applies.
- Changing cut-offs in a software update without checking whether it is still the same model under Article 3.
- Omitting temperature ranges with no note explaining why they were not relevant.
Frequently asked
Can I state the voltages from the cell datasheet?
Only if the battery placed on the market is a cell. For a pack the pack voltages apply; Article 3 defines cell and pack separately.
Does the Regulation define what the minimal voltage is?
No. Annex IV defines capacity, power, internal resistance and round trip efficiency, but not voltage. The criterion must therefore come from your own document and be applied consistently.
When must I add temperature ranges?
The text says “when relevant” and does not elaborate. Since you make the judgement yourself, record it together with the reason and the source of the values.
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