(EU) 2023/1542 · Annex XIII(1)(a) -> Annex VI, Part A(9)
Usable extinguishing agent: the only public fire data in the passport
This is an unusual field: the regulation demands it but says neither how to reach an answer nor what an acceptable answer looks like. At the same time it is the only fire-response information the passport places on the public side. The detailed safety measures and the test reports are restricted in Annex XIII to persons with a legitimate interest and to authorities, while this sentence can be read by anyone — including whoever is standing in front of a burning cabinet at three in the morning. That is what gives the field a weight its length does not suggest.
Public, while everything around it is locked
Point 1(a) of Annex XIII places the whole content of Part A of Annex VI among the publicly accessible information about the battery model. Point 2 of the same annex, which covers safety measures among other things, is accessible only to persons with a legitimate interest and the Commission; point 3, holding test reports, only to notified bodies, market surveillance authorities and the Commission. The extinguishing agent is therefore the only part of this subject that is public — and, under Article 13(1), label content as well.
The regulation prescribes no method
Annex V lists eleven safety parameters, among them a fire test in which the risk of explosion is assessed by exposing the battery to fire, and the emission of gases. Under Article 12(2) those parameters concern stationary battery energy storage systems and they evaluate hazards; none of them yields a statement of which agent is usable. At point 10 of Part A of Annex VI what was missing was a list of substances. Here something else is missing: any procedure by which the answer could be reached.
The safety data sheet answers a different question
The fire-fighting section of a safety data sheet concerns substances and names suitable and unsuitable media for them. This field asks about the battery as placed on the market — an assembled pack with a housing, electronics and dozens of cells. The safety data sheet is therefore an input, not the answer. We are not a notified body and we do not judge whether your statement is correct; we record which document and page it came from and who wrote it.
The answer has to survive the label and the national language
Article 13(7) requires labels to be printed or engraved visibly, legibly and indelibly on the battery itself; only where that is not possible or not warranted on account of the nature and size of the battery may they be affixed to the packaging and the accompanying documents. Article 38(1)(a) requires the battery to be accompanied by clear, understandable and readable instructions and safety information in a language easily understood by end-users, as determined by the Member State. A paragraph of prose satisfies neither requirement.
Where it goes wrong
- Copying the extinguishing media line from the cell's safety data sheet as the answer for an assembled battery.
- A value as long as a paragraph, although Article 13(7) requires it to be legible and indelible on the battery itself.
- Citing the Annex V tests as evidence for this field — they evaluate hazards and, under Article 12(2), concern stationary systems.
- Safety information supplied only in English, although Article 38(1)(a) requires the language determined by the Member State.
- Filing this field under the 18 February 2027 deadline alone: as label content under Article 13(1) it falls due on 18 August 2026 or 18 months after the implementing act enters into force, whichever is the latest — so possibly before the passport.
Frequently asked
Does the regulation say how to determine the usable extinguishing agent?
No. Point 9 of Part A of Annex VI requires the entry, but the regulation prescribes no method or test for it. The Annex V safety parameters evaluate hazards and, under Article 12(2), concern stationary battery energy storage systems; they designate no agent.
Can we copy the cell supplier's safety data sheet?
As an input yes, as the answer no. The safety data sheet addresses substances while this field addresses the battery as placed on the market. Record which document the statement came from and who approved it.
When does this data point fall due?
For the passport, 18 February 2027 under Article 77(1). As label content under Article 13(1), 18 August 2026 or 18 months after the implementing act enters into force, whichever is the latest; we make no claim on this page about the status of that act.
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