Safety measures in the passport: two words with no list, but a defined scope

The scope is not open; the purpose of access sets it

Article 77(2), third subparagraph, point (a) provides that the purposes of access concern dismantling of the battery, including safety measures to be taken during the dismantling, and the detailed composition of the battery model, and must be essential to allow repairers, remanufacturers, second-life operators and recyclers to conduct their respective economic activities. The words “during the dismantling” are what separate this field from every other safety document already on the shelf.

What this is not: Annex V and Article 12

Article 12(1) requires stationary battery energy storage systems to be safe during normal operation and use. Article 12(2) required the technical documentation in Annex VIII, by 18 August 2024, to demonstrate that compliance, to include evidence of successful testing for the safety parameters in Annex V, an assessment of possible hazards not addressed in Annex V, and evidence that those hazards were successfully mitigated and tested. Annex V lists eleven safety parameters, from thermal shock and cycling through overcharge and thermal propagation protection to the fire test and the emission of gases. That is product safety in operation, in a different document, for a different reader.

The addressee did not build the pack

A measure written for your own line refers to internal work instructions, workstation equipment and training the external reader does not have. A recycler or remanufacturer needs measures that stand on their own next to the disassembly sequence from point 2(c). If a measure points to a document the recipient cannot obtain, it is formally present and practically unusable.

Two different audiences read the same field

Article 77(2)(b) opens the information in points 2 and 3 of Annex XIII to notified bodies, market surveillance authorities and the Commission. Article 77(2)(c) opens the information in points 2 and 4 to persons with a legitimate interest. Point 2 therefore sits in both. Article 78(b) provides that access is free of charge and based on the access rights set out in Annex XIII and the implementing act under Article 77(9), and Article 78(f) restricts the rights to access, introduce, modify or update information on the same basis.

What is still unknown about the addressee

Article 77(9) requires the Commission to adopt, by 18 August 2026, implementing acts specifying which persons count as persons with a legitimate interest under points 2 and 4 of Annex XIII, to which information they have access, and to what extent they may download, share, publish and re-use it. The criteria are in the same paragraph: necessity for evaluating the status and residual value of the battery; necessity for preparation for re-use, repurposing, remanufacturing or recycling and for choosing between them; and limiting access to commercially sensitive information to the minimum necessary.

Where it goes wrong

• Attaching a UN 38.3 transport test summary as “safety measures”; that answers a transport question, not a dismantling one.
• Reusing Annex V evidence; that is operational safety under Article 12 and belongs to the technical documentation, not to this field.
• Measures that cross-refer to internal work instructions the reader cannot access.
• Personal-safety measures written into the fifth indent of point 2(c), which is about the risk of damaging parts.
• Assuming the field can be answered once for a product family; the measures follow the specific pack construction described in point 2(c).

Frequently asked