Commercial warranty for calendar life: the one commercial field on the list

Both terms stand alone in the Regulation

“Commercial warranty” and “calendar life” appear in the entire Regulation only in this point. There is no definition, no minimum period, no cross-reference to consumer law. The Regulation therefore does not require you to give a warranty and does not say how long it should be — it requires you to publish the period for which the one you do give applies. If you offer no calendar-life warranty, that is itself the answer, and it must not be papered over with a figure copied from elsewhere.

Three lifetimes that are not the same lifetime

Point 1(j) of Annex XIII requires the expected battery lifetime in cycles. Point 5 of Part A of Annex IV requires the expected lifetime under the reference conditions in cycles and calendar years — a technical parameter under Article 10(1), and under point 4(a) of Annex XIII it is not public. Article 3 in turn defines the lifetime of a battery as the period starting when it is manufactured and ending when it becomes waste. None of these three is the warranty period.

Dual limits are not calendar life

Battery warranties are often written with two limits at once, for example years and distance travelled, or energy throughput. This field asks about the calendar limb. If you publish only the number of years and stay silent on the other limit, the published period is longer than the one that actually applies to most users. State the period and, alongside it, the condition that cuts it short.

Model, not customer — and it must be kept current

The passport is issued for a model, which Article 3 defines by identical technical characteristics and the same model identifier. Individually negotiated extensions for a large account therefore do not belong in the public field. Article 77(4) at the same time requires information to be accurate, complete and up to date: a change in warranty terms for new units means a correction in the passport. For repurposed and remanufactured batteries, Article 77(7) requires a new passport — the old warranty period does not carry over automatically. The first entry has to be ready for batteries placed on the market from 18 February 2027, when Article 77(1) makes the passport mandatory.

Where it goes wrong

• Entering the expected lifetime from Annex IV instead of the warranty period.
• Publishing the years without the second limit that actually shortens the warranty.
• One customer's negotiated terms in a field that applies to the model.
• Leaving the field unchanged after sales revised the warranty terms; Article 77(4) requires it to be up to date.
• Adopting the cell supplier's warranty period — your warranty to your buyer is a separate legal arrangement.

Frequently asked