(EU) 2023/1542 · Annex XIII(1)(j)
Expected lifetime in cycles: a number without a test is not data
For this field the regulation does something it does not do elsewhere: alongside the value it explicitly requires the test to be named. The reason is simple. A claim of “6,000 cycles” means nothing until you know at what depth of discharge, temperature and rate it was measured — at 80% depth of discharge and at 50% these are two entirely different batteries.
Two data points are required, not one
Point 1(j) of Annex XIII requires the expected battery lifetime expressed in cycles, and the reference test used. The second part is not a footnote — it is part of the requirement. Entering only the number leaves the field incomplete.
What the test description must state
Part B of Annex IV sets out the elements that explain the measurements: the applied discharge and charge rate, the ratio between nominal battery power and battery energy, the depth of discharge in the cycle-life test, power capability at 80% and 20% state of charge, and any calculations performed. These are the conditions without which the number cannot be compared.
Why this matters when comparing suppliers
Two suppliers can quote the same cycle count and offer materially different durability. When you request this field from suppliers, demand both at once — the number and the conditions. Otherwise you will enter a value into the passport that you cannot defend.
Where it goes wrong
- Entering a cycle count without naming the reference test — the field stays incomplete.
- Taking a marketing figure from a catalogue that does not state depth of discharge.
- Comparing two supplier offers on bare cycle count alone.
- Stating the test in the technical documentation but not in the passport itself.
Frequently asked
Is stating the number of cycles enough?
No. Point 1(j) of Annex XIII also requires the reference test used. Without it the field is incomplete.
Which data describe the test?
The elements in Part B of Annex IV: applied discharge and charge rate, power-to-energy ratio, depth of discharge in the test, power capability at 80% and 20% state of charge, and any calculations performed.
Is expected lifetime also expressed in years?
Part A of Annex IV requires expected lifetime in cycles and calendar years among the performance parameters. Point 1(j) of Annex XIII speaks of cycles; calendar life is covered by the separate field on the commercial warranty.
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