(EU) 2023/1542 · Annex XIII(2)(c)
Disassembly sequences: a procedure, not a drawing — and how deep it must go
The first indent of point 2(c) already requires exploded diagrams showing cell locations. This indent asks for something else: an ordered procedure. A diagram says where things are; a sequence says in what order the pack can be opened without destroying anything on the way. That difference is why a CAD export does not satisfy the requirement. The regulation also says sequences, in the plural, and that is not a slip — different disassembly purposes stop at different points.
A diagram is not a sequence
An exploded diagram is static. A disassembly sequence is an order: what comes off first, when the pack is electrically isolated, which connections must be broken before mechanical ones, and which step is irreversible. None of that is visible in an exploded view from a CAD tool. Submitting a CAD export answers the first indent, not the second — and since both are separate items of the same point, the set stays incomplete.
How deep the sequence must reach
The answer sits in the Article 3 definition of remanufacturing: a technical operation on a used battery that includes the disassembly and evaluation of all its battery cells and modules and the use of a certain number of new, used or recovered cells and modules to restore capacity to at least 90 % of the original rated capacity, where the state of health of all individual cells does not differ by more than 3 % between cells. Article 77(2) names remanufacturers among those the access must enable. A sequence that ends at module removal does not enable that.
Why this item ages faster than the others
An exploded diagram and a cell count follow the design; a sequence also follows how the pack is actually built on the line. Change a fastener, a harness routing or an assembly order, and the disassembly order changes with it. Article 77(4) requires information to be accurate, complete and up to date, so the sequence version has to be tied to the design revision the passport describes. After remanufacturing or repurposing, Article 77(7) requires a new passport linked to the original — and with it a sequence for the pack as it now is.
Where it goes wrong
- Assembly instructions run backwards and submitted as a disassembly sequence; safely opening a pack is not simply the build reversed.
- The sequence stops at the module, although remanufacturing under Article 3 requires the disassembly and evaluation of all cells and modules.
- A single sequence for every purpose, although the regulation says sequences in the plural.
- The sequence version is not tied to the design revision the passport describes.
Frequently asked
Does an exploded diagram substitute for the sequence?
No. Point 2(c) lists exploded diagrams and disassembly sequences as two separate indents. Satisfying one does not cover the other.
How many sequences do we need?
The regulation uses the plural. The criterion in Article 77(9)(b) mentions preparation for re-use, preparation for repurposing, repurposing, remanufacturing or recycling and the choice between them — each of those ends at a different point of disassembly.
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