(EU) 2023/1542 · Annex XIII(2)(c)
Warnings about damaging parts: the one conditional item, and the line to safety measures
This is the only one of the six items in point 2(c) that is conditional: warnings are required if a risk of damaging parts exists. An empty entry is therefore legally possible — but only as the outcome of an assessment, not because nobody asked. The second peculiarity is the subject: the trigger is damage to parts, not harm to persons. Personal safety is its own item in point 2(d), and Article 77(2) names it specifically as safety measures to be taken during dismantling. Drawing that line is the whole work here.
Conditional, but the condition has to be assessed
The text reads: warnings if risk of damaging parts exist. Where no such risk exists, no warnings need be given. But an empty entry must be the outcome of an assessment, because Article 77(4) puts accuracy and completeness on the economic operator placing the battery on the market. In practice, for a lithium-ion pack that has to be opened, a damage risk is almost always present at least for seals, sensors and busbars.
Damage to parts is not harm to people
High voltage, arc flash and thermal runaway endanger the person doing the disassembly. Those measures belong in point 2(d), not here. What belongs here are warnings about the component that gets destroyed by the wrong move: a torn seal, a cut harness, a bent cooling plate, a snapped sensor connector. Filling this indent with personal safety leaves point 2(d) almost empty — and the other way round.
Why this item has the most tangible commercial consequence
Article 3 defines remanufacturing so that capacity must be restored to at least 90 % of the original rated capacity, with the state of health of all individual cells differing by no more than 3 % between cells. One cell damaged while prying open a lid can put the pack outside that definition. The criteria in Article 77(9) are precisely the evaluation of the battery's status and residual value and the choice between preparation for re-use, repurposing, remanufacturing and recycling. A missing warning therefore does not merely damage a part — it closes the route to the more valuable form of reuse.
A warning without a step and a consequence is not a warning
A usable warning says three things: which part is at risk, at which step of the disassembly sequence from the second indent it arises, and what happens if it does. A general sentence about care says none of that. Referring to a numbered step also makes it visible, when the design changes, which warnings have to be revised — without that link, warnings quietly go stale along with the sequence.
Where it goes wrong
- Filling the field with general high-voltage warnings; those are safety measures under point 2(d).
- Leaving the field empty with no record that the risk was ever assessed.
- A warning that names a risk but not the sequence step at which it arises.
- Considering only cell damage; sensors, busbars, harness, cooling plate and seals are parts too.
- Warnings written once for a product family, although they follow the specific joint design declared in the third indent.
Frequently asked
May the field be left empty?
Only where there genuinely is no risk of damaging parts. The entry is the outcome of an assessment, and Article 77(4) places accuracy and completeness on the economic operator placing the battery on the market.
How does this differ from the safety measures in point 2(d)?
The fifth indent of point 2(c) is about the risk of damaging parts. Safety measures are a separate item; Article 77(2), third subparagraph, names them as safety measures to be taken during the dismantling.
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