(EU) 2023/1542 · Annex XIII(2)(b)
Part numbers and spare sources: the one field that goes stale
Every other item in point 2 of Annex XIII is created at design time and then stops changing. This one is different: it requires part numbers for components and contact details of sources for replacement spares — that is, data about other companies. Suppliers change, part numbers shift with engineering changes, contact people leave. Article 77(4) requires information to be accurate, complete and up to date, and Article 77(8) says the passport ceases to exist only once the battery has been recycled. What follows is a maintenance duty, not a one-time entry.
The shelf life of this data is the life of the battery
Article 77(8) provides that the passport ceases to exist after the battery has been recycled. Until then Article 77(4) demands accuracy, completeness and currency. Article 78(e) goes further: the passport must remain available after the responsible economic operator ceases to exist or ceases its activity in the Union. For an industrial battery with a decade of service and a second life, the list of spare-part sources will have to be refreshed for longer than the original sales network exists.
A “source” is not your own service desk
The field asks for contact details of sources for replacement spares, not merely your service point. The audience is visible in the Article 3 definition of an independent operator: a person independent from the manufacturer and the producer, directly or indirectly involved in the repair, maintenance or repurposing of batteries, which expressly includes manufacturers or distributors of repair equipment, tools or spare parts. The contact must therefore be one from which a third party can actually order — not an internal purchasing reference.
For LMT batteries, Article 11 adds a five-year duty
Article 11(7) requires anyone placing on the market products incorporating portable or LMT batteries to ensure those batteries are available as spare parts of the equipment they power for a minimum of five years after the last unit of the equipment model was placed on the market, at a reasonable and non-discriminatory price for independent professionals and end-users. LMT batteries are within passport scope under Article 77(1), so the passport entry and that obligation must not tell different stories.
Where it goes wrong
- A link to a general webshop instead of part numbers that identify the components of this battery model.
- Giving a purchasing contact inside your own company rather than a source a third party can actually order from.
- Part numbers frozen at series start and never updated after an engineering change — Article 77(4) requires currency.
- Keeping the old passport after remanufacturing or repurposing; Article 77(7) requires a new passport linked to the original, and with it new part numbers.
Frequently asked
Must we name our suppliers?
The field requires contact details of sources for replacement spares. How far that extends towards persons with a legitimate interest is to be set by the implementing act the Commission must adopt by 18 August 2026 under Article 77(9), together with the extent of downloading, sharing, publishing and re-use.
How long must this data be maintained?
Article 77(8): the passport ceases to exist after the battery is recycled. Until then the currency requirement in Article 77(4) applies, and Article 78(e) requires the passport to remain available even after the responsible operator ceases to exist.
Does the five-year availability in Article 11(7) apply to us?
It applies to those placing on the market products incorporating portable or LMT batteries — a minimum of five years after the last unit of the equipment model was placed on the market. That paragraph is not written for industrial or electric vehicle batteries.
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