(EU) 2023/1542 · Annex XIII(2)(c)
Fastening techniques: type and number are required, even where nothing can be unlocked
This is the only item in the set that asks for a count. It does not ask how the pack is built, but how many joints must be broken and of what kind. The second peculiarity is the verb: it speaks of techniques to be unlocked, which presumes a reversible joint. Adhesive, ultrasonic or laser welds and rivets are not unlocked — they are broken by destroying them. Which is precisely why this item is the most honest record of how hard your pack is to open.
Type AND number are two data points, not one
The wording requires the type and number of fastening techniques. Writing “screws, adhesive, cable ties” answers half the question. The count is what makes the field checkable: a recycler estimates disassembly time from it, and a market surveillance authority can compare it against the exploded diagram in the first indent and the sequence in the second. Internal joints count too, not just the fasteners of the outer casing — the pack does not end at the lid.
What cannot be unlocked still has to be declared
Bonded joints, welds and rivets are not unlocked but destroyed. Omitting them because the text says unlocked means declaring fewer joints than must actually be broken, which runs straight into the completeness requirement of Article 77(4). For LMT batteries it goes further: Article 11(5) requires the battery and the individual cells in the pack to be readily removable and replaceable by an independent professional, and Article 11(6) defines readily replaceable as substitution without affecting functioning, performance or safety. A declared welded cell interconnect is therefore your own record on that question. Article 11(9) requires the Commission to publish guidelines for the harmonised application of that Article.
Where it goes wrong
- Types listed without numbers — the field requires both.
- Bonded and welded joints left out because they cannot be “unlocked”.
- Counting only the outer casing fasteners and not the internal joints down to cell level.
- Treating the commercially-available-tools test in Article 11(1) as the governing standard; that paragraph is written for portable batteries, while the passport under Article 77(1) covers LMT, industrial above 2 kWh and electric vehicle batteries.
Frequently asked
Does adhesive count as a fastening technique?
The field requires the type and number of fastening techniques to be unlocked. A bonded joint is a fastening technique and has to be broken; leaving it out makes the entry incomplete for the purposes of Article 77(4).
Is a count of screws enough?
No. Type and number are both required, and beyond screws a pack has internal joints — connectors, busbars, ties and bonded interfaces.
How does this field bear on Article 11?
For LMT batteries, Article 11(5) requires the battery and the individual cells in the pack to be readily removable and replaceable by an independent professional. What you write here is evidence of how feasible that is.
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