(EU) 2023/1542 · Annex XIII(1)(l)
Temperature range when not in use: the Regulation wants a test it never names
Two words carry this field: “not in use”. It is not the operating range every datasheet quotes, but the range the battery withstands when it is doing nothing. The bracketed “reference test” also means a value without a named test is incomplete — yet the Regulation nowhere says which test that is. The outcome is predictable: the field gets filled with the cell's operating range, which is two errors at once, both taken from the same supplier document.
Idle is not operating
Cell datasheets quote operating ranges for charge and discharge, often different from each other, and a separate storage range that is usually tied to a duration — one month, three months, a year. Point 1(l) asks for the range the battery withstands when not in use and places no limit on duration. If your source ties the value to a period, you cannot drop that: state the range together with the duration it refers to, or you have turned a conditional figure into an unconditional one.
The Regulation does not name the test
The bracket says “reference test”, but there is no list. Annex V, whose first point describes thermal shock and cycling, is a set of safety parameters attached to the safety of stationary battery energy storage systems under Article 12 — that is not an idle-storage test. Part B of Annex IV explains performance and durability measurements, not storage. Annex III, with charge retention after storage, applies to portable batteries of general use, which the passport does not cover at all. So you name the test yourself and state it with the value.
The narrowest component in the pack decides
At rest, the cell is usually the most tolerant component. The tighter limits come from the management electronics, contactors, seals, adhesives and the coolant loop with its fluid. The value in the passport relates to the battery placed on the market, meaning the pack — and that range is normally narrower than the one the cell supplier quotes. Copy the cell and you publish a wider range than the product actually survives.
Where it goes wrong
- An operating temperature range in place of the idle range.
- The cell datasheet range when the battery in the passport is a pack with tighter limits.
- A value with no reference test named, although the bracketed text requires one.
- Dropping the duration to which the source tied its storage range.
Frequently asked
Which test must I name?
The Regulation does not set one. Annex V is safety parameters and Annex III applies to portable batteries of general use. You choose and name the test yourself, but name it you must, because the bracket in point 1(l) requires it.
Can I state the operating range?
No. The text is explicit about the battery not being in use. The operating range is a different figure and this field does not cover it.
Is the cell datasheet range sufficient?
Only if the battery placed on the market is a cell. In a pack the electronics, seals and cooling also set limits, so the range is usually narrower.
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