(EU) 2023/1542 · Annex XIII(2)(c)
Dismantling information: six requirements and an open question about who may see it
This is not one field but six separate requirements, and none can be satisfied with a declaration. It is engineering documentation created at design time. An importer who does not demand it with the first order will, in practice, never get it — the manufacturer has no reason to release it, because it exposes how the product is built.
Six requirements the regulation names explicitly
Point 2(c) of Annex XIII requires at least: exploded diagrams of the battery system or pack showing the location of cells, disassembly sequences, the type and number of fastening techniques to be unlocked, the tools required for disassembly, warnings if a risk of damaging parts exists, and the amount of cells used and their layout. Each is a separate item — a partly completed set is not completed.
This data is not public
Unlike most Annex XIII fields, this one is not accessible to everyone through the QR code. Point 2 places it among information accessible only to persons with a legitimate interest and the Commission. Recital 124 explains why: it is commercially sensitive information needed by repairers, remanufacturers and recyclers, not by the general public.
Who counts as a “person with a legitimate interest” is not yet settled
Article 77(9) requires the Commission to adopt, by 18 August 2026, implementing acts specifying which persons are to be considered persons with a legitimate interest under points 2 and 4 of Annex XIII, and to which information they have access. Until that act exists you do not know to whom you will have to disclose this data. We do not resolve that question here — but it explains why this data should be prepared separately from the public part of the passport.
Why this is the hardest field for an importer after state of health
An exploded diagram and a disassembly sequence are produced in development, not in a warehouse. A Chinese or Korean cell manufacturer treats them as protected know-how. The only moment you hold negotiating power is before signing the supply contract; after that, the request depends on goodwill.
The link to Article 11 on removability
Article 11 requires portable batteries in products to be readily removable and replaceable by the end-user, with derogations for certain products where replacement may be reserved to independent professionals. The design decisions you take because of Article 11 shape what your dismantling documentation looks like — so the two requirements are best handled together.
Where it goes wrong
- Attaching general service instructions instead of an exploded diagram showing cell locations.
- Completing three of the six items; the set is complete only when all six are.
- Publishing this data in the public part of the passport when it belongs to a restricted access tier.
- Requesting it from the supplier only after the contract is signed, when leverage is gone.
- Assuming it is known who will be entitled to the data — the implementing act under Article 77(9) has not settled that.
Frequently asked
Which dismantling information is mandatory?
Six items: exploded diagrams showing cell locations, disassembly sequences, the type and number of fastening techniques, the tools required, warnings where parts may be damaged, and the amount and layout of cells. All from point 2(c) of Annex XIII.
Is this data publicly accessible through the QR code?
No. Point 2 of Annex XIII places it among information accessible only to persons with a legitimate interest and the Commission.
Who counts as a person with a legitimate interest?
Not yet determined. Article 77(9) requires the Commission to specify this by implementing act by 18 August 2026, together with the scope of access.
Is the cell manufacturer's documentation enough?
Only if it relates to the battery system or pack as placed on the market. A single-cell drawing does not cover the requirement to show cell locations within the pack.
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