(EU) 2023/1542 · Annex XIII(1)(a) -> Annex VI, Part A(5)
Battery weight: the number that decides which category you are in
Weight looks like a figure you read off the datasheet and move on. In fact it is the one field in Part A that can change the legal status of the product. The definitions in Article 3 classify batteries precisely by weight: 5 kg separates portable from industrial, and 25 kg sets the line for LMT batteries and for electric vehicle batteries in category L vehicles. The number you enter here therefore answers the question of which obligations reach you at all — and Annex VI gives it neither a unit nor a measuring convention.
Where weight becomes a legal boundary
Article 3 defines a portable battery as one that is sealed, weighs 5 kg or less, is not designed specifically for industrial use and is neither an electric vehicle, LMT nor SLI battery. An industrial battery includes any other battery weighing more than 5 kg that is not an electric vehicle, LMT or SLI battery. An LMT battery is sealed and weighs 25 kg or less, while an electric vehicle battery for category L vehicles weighs more than 25 kg. For a product near any of these lines, deciding what is weighed is not a technical detail.
What exactly is on the scale
Point 5 of Part A of Annex VI reads simply “the weight”. No unit, no measuring conditions. By contrast, point 1(g) of Annex XIII states its unit explicitly and requires rated capacity in ampere-hours. Here there is nothing, which is why the figures diverge in practice between the bare pack, the pack with its mounting frame, the pack with the cooling circuit filled, and the gross weight from the shipping paperwork. The last is the easiest to reach and the least suitable, because it includes packaging.
The same weight is the carbon footprint denominator
Annex II defines the reference flow as the weight of battery needed to fulfil a specific function, measured in kg of battery per kWh of the total energy delivered over its service life, and requires all quantitative input and output data collected to quantify the footprint to be calculated in relation to that reference flow. A weight inflated because it includes the crate therefore does not stop at this field — it migrates into the calculation and distorts it.
Where it goes wrong
- Gross weight from shipping or dangerous goods paperwork instead of the battery's own weight.
- A cell or module weight multiplied up, with no housing, BMS, wiring or fasteners.
- Rounding a value close to 5 or 25 kg, where the number decides the category under Article 3.
- One weight for variants that differ in housing or in the number of modules.
- A passport weight that does not match the reference flow used in the carbon footprint calculation under Annex II.
Frequently asked
In which unit do we state the weight?
Point 5 of Part A of Annex VI states no unit. Since Article 3 expresses the category boundaries in kilograms, the classification question is decided in kilograms and it makes sense to stay in the same unit.
Does the weight include packaging?
The Article 3 definitions speak of a battery weighing 5 or 25 kg, that is, of the battery itself. The gross weight in transport documents is a different figure and not a substitute.
Why does weight matter if it is only a label entry?
Because Article 3 uses it to assign the category and Annex II uses it as the reference flow in the carbon footprint calculation. The same number appears in three roles.
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