(EU) 2023/1542 · Annex XIII(1)(s) -> Article 74(1)(a)
Waste prevention in the passport: five terms that are not synonyms
Of the six fields in Article 74(1), this is the only one that asks you to write advice rather than describe an arrangement that already exists. The Regulation wants information on good practices and recommendations concerning the use of batteries aimed at extending their use phase, and on the possibilities of re-use, preparation for re-use, preparation for repurposing, repurposing and remanufacturing. Those are five distinct concepts, not five names for one thing. The industry calls all of them “second life” — and that word is the usual reason this field ends up formally empty.
Five possibilities, not one
Re-use, preparation for re-use, preparation for repurposing, repurposing and remanufacturing are separate concepts in the Regulation with separate consequences. A battery moved into stationary energy storage is not being re-used; it is being repurposed. Text that describes only one of the five routes leaves four unanswered. What counts when completeness is assessed is whether each listed possibility is addressed, not how well the paragraph reads.
The obligation does not start with the passport
Article 74 sits in Chapter VIII, and under Article 96(2)(c) that chapter applies from 18 August 2025. So this content is not something you begin preparing for 2027. What arrives on 18 February 2027 is only its placement inside the battery passport: Article 77(1) requires a passport from that date for LMT batteries, industrial batteries above 2 kWh and electric vehicle batteries, and point (s) of part 1 of Annex XIII pulls precisely points (a) to (f) of Article 74(1) into it.
Advice that contradicts your own terms
Recommendations to extend the use phase regularly collide with warranty conditions and with the safety instructions under point (d) of the same paragraph. If one field advises keeping a battery in service longer while another warns about handling aged cells, the relationship between the two texts has to be deliberate. Internal inconsistency across the six public fields is more visible on review than a thin individual paragraph, because all six are read on the same screen.
Where it goes wrong
- Using “second life” as a blanket label instead of the five named possibilities in point (a).
- Marketing copy about product durability instead of usable recommendations to the end-user.
- A recommendation that contradicts the safety instructions under point (d) or your own warranty terms.
- Text written for portable consumer batteries, although the passport covers LMT, industrial above 2 kWh and electric vehicle batteries.
Frequently asked
Is it enough to state that the battery is suitable for a second life?
No. Point (a) of Article 74(1) expressly names re-use, preparation for re-use, preparation for repurposing, repurposing and remanufacturing. A blanket label does not say which of those routes is actually available for your model.
Does this obligation only start on 18 February 2027?
No. Chapter VIII, which contains Article 74, applies from 18 August 2025 under Article 96(2)(c). 18 February 2027 is the passport deadline under Article 77(1) — the date by which this content must also sit inside the passport.
Who has to make this information available?
Producers or, where appointed in accordance with Article 57(1), producer responsibility organisations. It goes to end-users and distributors, for the categories of batteries they supply within a Member State's territory.
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