(EU) 2023/1542 · Annex XIII(4)(a) -> Annex IV, Part A(1)
Battery performance parameters: an obligation running since August 2024
Together with state of health, this is the most overlooked obligation in the whole regulation. It does not fall due with the passport deadline — it was required back in 2024, and anyone who has placed a battery on the market since then without this document carries a retroactive gap.
What Article 10(1) requires
From 18 August 2024, rechargeable industrial batteries above 2 kWh, LMT batteries and electric vehicle batteries must be accompanied by a document containing values for the electrochemical performance and durability parameters in Part A of Annex IV. There are five: rated capacity and capacity fade, power and power fade, internal resistance and its increase, energy round trip efficiency and its fade where applicable, and expected lifetime in cycles and calendar years.
Stating numbers is not enough
The same article requires the technical documentation under Annex VIII to contain an explanation of the technical specifications, standards and conditions used to measure, calculate or estimate those values. That explanation must cover at least the elements in Part B of Annex IV: applied discharge and charge rate, the ratio between nominal power and energy, depth of discharge in the cycle-life test, power capability at 80% and 20% state of charge, and any calculations performed.
What is still to come
Articles 10(2) and 10(3) introduce minimum values for these parameters — for industrial batteries from 18 August 2027 or 18 months after the delegated act, for LMT batteries from 18 August 2028. Today the duty is to disclose the values, not yet to meet thresholds.
Where it goes wrong
- Filing this field under work for the 18 February 2027 deadline — it has applied since 18 August 2024.
- Stating values without the method explanation from Part B of Annex IV.
- Confusing the duty to disclose (in force) with the duty to meet minimums (still to come).
- Using cell catalogue data instead of measurements on the battery as placed on the market.
Frequently asked
Since when has this document been mandatory?
Since 18 August 2024, under Article 10(1), for rechargeable industrial batteries above 2 kWh, LMT and electric vehicle batteries.
Which parameters must be stated?
The five in Part A of Annex IV: rated capacity and capacity fade, power and power fade, internal resistance and its increase, energy round trip efficiency and its fade where applicable, and expected lifetime.
Do minimum values already apply?
No. Minimum values under Article 10(2) start for industrial batteries on 18 August 2027 or 18 months after the delegated act, whichever is the latest.
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