Industrial batteries
Industrial batteries carry a broad set of DPP obligations under Regulation (EU) 2023/1542, including carbon footprint declarations and supply chain due diligence requirements comparable to those for EV batteries. The DPP obligation for industrial batteries became mandatory on 18 August 2025 and is currently in force.
This documentation is informational only and does not constitute legal advice. Consult qualified legal counsel for compliance decisions specific to your products and market.
Definition
Industrial batteries are defined by Article 3(15) of the regulation as batteries designed exclusively for industrial applications, or as any rechargeable battery that is not classified as an EV, LMT, SLI, or portable battery and has a capacity of more than 2 kWh.
Industrial is effectively the residual category for high-capacity rechargeable batteries outside the other defined categories. This makes it a wide-ranging classification.
Typical industrial battery applications
| Application | Notes |
|---|---|
| Battery energy storage systems (BESS) | Grid-scale, commercial, and industrial stationary storage |
| Forklift and industrial truck batteries | Lead-acid and lithium-ion traction batteries for warehouse vehicles |
| Uninterruptible power supplies (UPS) | Data centres, hospitals, critical infrastructure |
| Marine propulsion batteries | Batteries for electric ferries, harbour vessels, and inland waterway craft |
| Rail traction batteries | Batteries for battery-electric or hybrid rail vehicles (not road vehicles) |
| Telecom backup batteries | Large rack-mounted backup systems |
| Mining and construction vehicle batteries | Off-road electric equipment batteries (not road-type-approved) |
| Portable industrial tools | Large professional tool batteries not carried by hand (>5 kg, >2 kWh) |
DPP Enforcement Date: 18 August 2025
The industrial battery DPP obligation is currently in force. Every industrial battery placed on the EU market must have a valid, accessible DPP. The DPP must be created before the battery is placed on the EU market and must remain accessible for the battery's operational lifetime plus ten years.
Governing Data Requirements: Annex XIII
Industrial batteries are governed by Annex XIII of the regulation, which specifies the minimum data categories for industrial battery DPPs. This is the most detailed set of data requirements of any battery category in the regulation. For the full field-by-field reference, see Annex XIII — Industrial Batteries.
Carbon Footprint
Carbon footprint declarations are mandatory for industrial batteries:
| Obligation | Mandatory From |
|---|---|
| Carbon footprint declaration (value in kg CO₂e/kWh) | 18 August 2025 |
| Carbon footprint performance class (A–E) | 18 August 2026 |
The carbon footprint must be calculated using the methodology established in the Commission delegated act under Article 7(1). It must cover the full lifecycle: raw material extraction, cell and battery manufacturing, transportation, use phase (reference scenario), and end-of-life.
For BESS applications, the use phase carbon footprint contribution depends significantly on the assumed electricity grid mix. Operators must follow the methodology specification exactly — using an assumed grid mix that differs from the Commission methodology will result in an invalid carbon footprint declaration.
The carbon footprint declaration must be supported by a technical study (LCA or PEF study) retained by the operator for the battery's lifetime plus ten years. Third-party verification is strongly recommended and expected to become mandatory under delegated acts.
Calendar Life Declarations
A distinctive requirement for industrial batteries — particularly BESS — is the obligation to declare calendar life in addition to cycle life. This reflects the commercial and regulatory importance of knowing how long a stationary storage system will operate under real-world conditions.
| Parameter | What to Declare | Notes |
|---|---|---|
| Rated cycle life | Number of full cycles to end-of-life threshold | Define test conditions (C-rate, temperature, DoD) |
| Calendar life | Expected operational life in years | Define ambient conditions and SoC assumptions |
| End-of-life capacity threshold | Capacity % defining end of life | Typically 70–80% of rated capacity |
| Operating temperature range | Min/max ambient temperature | In °C |
| Optimal storage temperature | Recommended temperature for non-operational storage | In °C |
BESS operators are increasingly using calendar life as a key commercial metric in power purchase agreements and long-term service contracts. The DPP calendar life declaration must be based on actual test data or a validated degradation model — manufacturers cannot simply state a calendar life figure without a supporting technical basis.
State of Health Methodology
Article 14 and Annex VII require industrial battery DPPs to include the state of health (SoH) methodology — a description of how SoH is calculated for the battery model. This is particularly important for:
- BESS operators who need to demonstrate ongoing performance under long-term service agreements
- Recyclers and second-life operators who need to assess a battery's condition at end of first life
- Market surveillance authorities who may request SoH data as part of compliance verification
The SoH methodology must specify:
- The parameters used to calculate SoH (e.g. capacity-based, resistance-based, energy throughput model)
- The reference conditions under which SoH is measured
- The update interval if SoH is reported dynamically
- Whether SoH is reported by the battery management system (BMS) or estimated externally
Temperature Operating Range
Industrial batteries deployed in demanding environments (outdoor BESS, cold storage facilities, extreme-climate mining operations) must declare their operating temperature range accurately. This field has safety and warranty implications beyond regulatory compliance.
Traceable requires operators to declare:
- Minimum operating temperature (°C)
- Maximum operating temperature (°C)
- Optimal storage temperature range (°C)
- Whether thermal management (heating or cooling) is required to achieve rated performance at temperature extremes
Stationary Storage Safety Standards
For BESS applications, the DPP must reference compliance with applicable safety standards. The regulation does not mandate a specific standard but expects conformity with relevant harmonised standards. Key standards for industrial BESS include:
| Standard | Scope |
|---|---|
| IEC 62619:2022 | Safety requirements for secondary lithium cells and batteries for use in industrial applications |
| IEC 62933 series | Electrical energy storage (EES) systems — including BESS safety |
| IEC 62477 | Safety requirements for power electronic converter systems (relevant for BESS inverters) |
| UL 9540 | Standard for Energy Storage Systems and Equipment |
| EN 50604-1 | Secondary lithium batteries for light EV applications (may overlap for some industrial categories) |
| NFPA 855 | Standard for the Installation of Stationary Energy Storage Systems (relevant where EU installations follow international standards) |
The applicable standard(s) must be listed in the DPP's compliance section.
Recycled Content Requirements
Recycled content declarations are mandatory for industrial batteries from the DPP mandatory date. The same minimum thresholds as EV batteries apply:
| Material | Minimum from 1 January 2030 | Minimum from 1 January 2035 |
|---|---|---|
| Cobalt | 16% | 26% |
| Lithium | 6% | 12% |
| Nickel | 6% | 15% |
| Lead | 85% | 85% |
Declarations must be independently verified by a third party. Self-declaration alone does not satisfy the requirement once third-party verification becomes mandatory.
Supply Chain Due Diligence
The supply chain due diligence obligation under Article 72 applies to industrial batteries with the same scope as EV batteries:
| Material | Requirement |
|---|---|
| Cobalt | Geographic origin (country of extraction) must be declared |
| Natural graphite | Geographic origin (country of extraction) must be declared |
| Lithium | Geographic origin (country of extraction) must be declared |
| Nickel | Geographic origin (country of extraction) must be declared |
Operators must implement and maintain a supply chain due diligence policy consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, and must conduct or commission third-party audits of their supply chain.
Traceable's Industrial Battery Template
The Traceable industrial battery DPP template covers all Annex XIII fields and is organised into the following sections in the DPP Builder:
| Section | Content |
|---|---|
| Battery Details | Identity, model, configuration, specifications |
| Carbon Footprint | Value, lifecycle breakdown, performance class, study reference |
| Recycled Content | Cobalt, lithium, nickel, lead — declared and verified |
| Performance & Durability | Capacity, cycle life, calendar life, temperature, SoH methodology |
| Safety | UN 38.3, applicable standards, fire risk, handling instructions |
| Supply Chain | Geographic origin for all four regulated materials, due diligence policy |
| Compliance | DoC reference, CE marking, notified body, harmonised standards |
| End of Life | EPR scheme, waste code, dismantling instructions, second-life assessment |
All Annex XIII mandatory fields are pre-marked in the template. The template also includes advisory fields recommended for BESS applications that go beyond Annex XIII minimums but are anticipated by the Commission's work programme on industrial battery delegated acts.