(EU) 2023/1542 · Annex XIII(1)(f)
Share of renewable content: a field with no definition and no method
This is the one field in point 1 of Annex XIII that nobody holds for you — not the cell supplier, not a laboratory. The Regulation asks for the “share of renewable content” and says nothing further: the word occurs exactly once in the entire text, here. There is no definition, no unit, no reference method and no empowerment for the Commission to set one. So you will publish a figure against which no external yardstick exists — and the only thing that defends such a field is a written, disclosed method.
What the text says, and what it does not
Point 1(f) of Annex XIII requires the “share of renewable content”. That is the whole provision. It does not say whether the share is by mass or by energy, whether it refers to materials in the battery or to energy used in manufacturing, and it does not list what counts as renewable. Nowhere is there a delegated or implementing act to settle it later. Unlike almost every other field, there is no document you can demand from a supplier — the question is interpretive first and evidential second.
Do not borrow the recycled content regime
The most common approach we see is to apply the recycled content method from Article 8. That article has its own documentation, its own metals, its own dates and its own delegated act — and none of it refers to renewable content. The two fields sit next to each other in Annex XIII, but all they share is that both are shares. Enter recycled content under the renewable label and you have published a wrong figure; with no external yardstick, it will surface only when a reviewer asks for your method.
How the field can be defended at all
Article 77(4) requires the economic operator placing the battery on the market to ensure the passport information is accurate, complete and up to date. That duty applies to a field with no prescribed method too. In practice: record your reading of the term, the system boundary, the data source and the calculation date, and keep that note with the value. Change the reading later and the value changes — if the reason is not recorded, it looks like a number being adjusted. The deadline gives no relief: Article 77(1) requires a passport from 18 February 2027 for every LMT battery, every industrial battery above 2 kWh and every electric vehicle battery placed on the market or put into service.
Where it goes wrong
- Copying a recycled content share, or a renewable energy share from the carbon footprint study, into the renewable content field.
- Publishing a value without recording what was counted and within which system boundary.
- Asking the cell supplier for a “renewable content certificate” — the Regulation knows no such document, and the supplier will issue it on their reading, not yours.
- Citing a delegated act that the Regulation does not provide for this field.
Frequently asked
Is there a prescribed method for calculating the share of renewable content?
Not in the Regulation. The term appears only in point 1(f) of Annex XIII, with no definition, no unit and no reference to a delegated or implementing act.
May I use the recycled content figure?
Not as a substitute. Recycled content has its own Article 8 with its own documentation and its own dates. They are two distinct Annex XIII fields.
Who can issue this data to me?
Nobody, with any document the Regulation prescribes. The figure originates with you, from supplier inputs and your reading of the term — which is why only a written method supports it.
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