(EU) 2023/1542 · Annex XIII(2)(c)
Tools for disassembly: a list that doubles as a self-assessment under Article 11
It looks like the most harmless item in the set — a list of tools. It is in fact the only one that can speak against you. Article 77(2) justifies access to this data on the basis that it lets repairers, remanufacturers, second-life operators and recyclers carry out their activities. A tool only you sell, or a software unlock without which the pack cannot be opened, defeats that purpose — and because it has to be named, it stays on the record in the passport.
The tool list is also a statement about accessibility
The addressees follow from the Article 3 definition of an independent operator, which covers repairers as well as manufacturers and distributors of repair equipment, tools and spare parts. If disassembly requires a tool a third party cannot obtain, the list fills the field but not the purpose set out in Article 77(2). For LMT batteries, Article 11(8) is also in play: software shall not be used to impede the replacement of the battery or of its key components.
The regulation's tool vocabulary sits elsewhere, and for another category
The only place the regulation classifies tools is Article 11(1): a battery is considered readily removable where it can be removed with commercially available tools, without requiring specialised tools unless provided free of charge with the product, proprietary tools, thermal energy, or solvents. That paragraph is written for portable batteries, whereas the passport under Article 77(1) covers LMT, industrial above 2 kWh and electric vehicle batteries. The vocabulary is useful as a classification; the test itself cannot be carried across to categories it was not written for.
A tool must be obtainable, not merely named
An internal fixture number from your own line identifies the tool but tells a third party nothing about where to get one. Give a description and a source — which links this indent to point 2(b), which asks for contact details of sources for replacement spares anyway. Handling both fields together avoids the situation where a tool is named and disassembly is still not feasible for anyone outside the company.
Where it goes wrong
- “Standard tools” as the entire answer; the field asks which tools.
- Software and unlock codes left off the list, although the pack cannot be opened without them.
- Personal protective equipment listed as tools; PPE belongs with the safety measures in point 2(d).
- In-house fixtures given by internal number with no source from which a third party could obtain one.
Frequently asked
Do software and diagnostic access count as tools?
If disassembly cannot be performed without them, omitting them makes the entry incomplete for the purposes of Article 77(4). For LMT batteries, Article 11(8) also applies: software shall not be used to impede replacement of the battery or of its key components.
Does personal protective equipment belong in this field?
The fourth indent of point 2(c) asks for the tools required for disassembly. Safety measures are a separate item — point 2(d), which Article 77(2) names specifically as safety measures to be taken during dismantling.
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