Industrial batteries
Industrial batteries carry a broad set of obligations under Regulation (EU) 2023/1542, including carbon footprint declarations and supply-chain due diligence comparable to those for EV batteries. The battery passport obligation for industrial batteries above 2 kWh applies from 18 February 2027 under Article 77(1); it is not yet in force. Other obligations (carbon footprint, due diligence, recycled content) apply on their own dates, set out below, and several depend on delegated or implementing acts not yet adopted.
This documentation is provided for informational purposes only. It is not legal advice and does not constitute a compliance guarantee, certification, or attestation of conformity with Regulation (EU) 2023/1542. Operators remain solely responsible for their own compliance and should consult qualified regulatory counsel.
Definition
Industrial batteries are defined in Article 3(1)(13) of the regulation as batteries specifically designed for industrial uses, batteries intended for industrial use after having been prepared for repurposing or repurposed, or any other battery weighing more than 5 kg that is not an EV, LMT or SLI battery. The residual test is weight-based (>5 kg), not capacity-based: the ">2 kWh" figure gates the Article 77(1) DPP obligation and the Article 7/8 obligations, not the Article 3(1)(13) definition.
Industrial is also the residual category for "any other battery that weighs more than 5 kg and that is neither an electric vehicle battery, an LMT battery, nor an SLI battery" (Article 3(1), point (13)), whether or not it is rechargeable. 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) |
Battery Passport Date: 18 February 2027
The battery passport obligation for industrial batteries above 2 kWh applies from 18 February 2027 under Article 77(1) — the same single start date as LMT and EV batteries. It is not yet in force. Every industrial battery above 2 kWh placed on the market or put into service on or after that date must have a battery passport, created before the battery is placed on the market. Supporting technical documentation must be retained for 10 years after the battery is placed on the market (Article 38 and Annex VIII). Operators in scope should prepare their product data now, but no battery passport is legally required before 18 February 2027.
Governing Data Requirements: Annex XIII
The battery passport of an industrial battery with a capacity greater than 2 kWh contains the information in Annex XIII of the regulation, which Article 77(2) applies to every battery that must have a passport (LMT batteries, industrial batteries with a capacity greater than 2 kWh and electric vehicle batteries) "to the extent applicable to the category or sub-category of battery concerned". Annex XIII is not specific to industrial batteries; its only category-specific item is point 1(k), "capacity threshold for exhaustion (only for electric vehicle batteries)". Industrial batteries with a capacity of 2 kWh or less have no battery passport under Article 77(1). For the full field-by-field reference, see Annex XIII.
Carbon Footprint
Under Article 7(1), carbon footprint declarations are required for rechargeable industrial batteries with a capacity greater than 2 kWh, from the dates below:
| Obligation | Applies From |
|---|---|
| Carbon footprint declaration (value in kg CO₂e/kWh) — industrial >2 kWh, except exclusively external storage | 18 February 2026 or 18 months after the date of entry into force either of the delegated act or of the implementing act respectively referred to in the fourth subparagraph, points (a) and (b), whichever is the latest (Article 7(1), second subparagraph, point (b)) |
| Carbon footprint declaration (value in kg CO₂e/kWh) — rechargeable industrial >2 kWh with external storage | 18 August 2030 or 18 months after the date of entry into force either of the delegated act or of the implementing act respectively referred to in the fourth subparagraph, points (a) and (b), whichever is the latest (Article 7(1), second subparagraph, point (d)) |
| Carbon footprint performance class (classes set by Commission delegated act under Article 7(2); category A is the best class, Annex II, point 8) | 18 August 2027 or 18 months after the date of entry into force either of the delegated act or of the implementing act respectively referred to in the fourth subparagraph, points (a) and (b), whichever is the latest, for rechargeable industrial batteries except those with exclusively external storage; 18 February 2032 or 18 months after the date of entry into force either of the delegated act or of the implementing act respectively referred to in the fourth subparagraph, points (a) and (b), whichever is the latest, for rechargeable industrial batteries with external storage (Article 7(2), third subparagraph, points (b) and (d)) |
The carbon footprint must be calculated using the methodology established in the Commission delegated act under Article 7(1). It must cover the life cycle stages in Annex II, point 4: raw material acquisition and pre-processing, main product production, distribution, and end of life and recycling. The use phase is excluded unless it is "demonstrated that choices made by battery manufacturers at the design stage can make a non-negligible contribution to that impact" (Annex II, point 4).
The carbon footprint declaration must be supported by technical documentation (LCA or PEF study) retained for 10 years after the battery is placed on the market (Article 38 and Annex VIII). Conformity with Article 7 is assessed under Module D1 or Module G of Annex VIII (Article 17(2)). These dates are tied to the entry into force of the relevant Commission delegated act or implementing act and may move.
Calendar Life Declarations
Under Article 10(1), rechargeable industrial batteries with a capacity greater than 2 kWh, like LMT and EV batteries, must be accompanied by a document containing the Annex IV, Part A, parameters, including the expected life-time "in terms of cycles, except for non-cycle applications, and calendar years" (Annex IV, Part A, point 5). 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 | Not an Annex XIII item for industrial batteries: point 1(k) is "capacity threshold for exhaustion (only for electric vehicle batteries)" |
| 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(1) requires that, from 18 August 2024, "up-to-date data for the parameters for determining the state of health and expected lifetime of batteries as set out in Annex VII shall be contained in the battery management system of stationary battery energy storage systems, LMT batteries and electric vehicle batteries"; among industrial batteries this covers stationary battery energy storage systems. No provision requires a state of health (SoH) methodology description in the battery passport: Annex XIII, point 4(b), requires "information on the state of health of the battery pursuant to Article 14" for the individual battery, accessible only to persons with a legitimate interest. This information 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
Where an operator documents how SoH is determined (a practice, not a requirement of the Regulation), the description can cover:
- 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.
The Traceable industrial template provides the following fields; of these, only the storage temperature range is required:
- Charge and discharge temperature ranges
- Idle temperature range, minimum and maximum (°C)
- Storage temperature range
- Thermal management type
Stationary Storage Safety Standards
For stationary battery energy storage systems, Article 12(2) requires the technical documentation to "demonstrate that the stationary battery energy storage systems are compliant with paragraph 1 and include evidence that they have been successfully tested for the safety parameters set out in Annex V". The regulation does not mandate a specific standard. 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 EU declaration of conformity, which the battery passport includes (Annex XIII, point 1(r)), gives "References to the relevant harmonised standards or the common specifications used or references to the other technical specifications in relation to which conformity is declared" (Annex IX, point 6).
Recycled Content Requirements
Recycled content is governed by Article 8 and applies to industrial batteries with a capacity greater than 2 kWh, except those with exclusively external storage (alongside EV, LMT and SLI batteries), that contain cobalt, lead, lithium or nickel in active materials. The recycled-content declaration is required from 18 August 2028 or 24 months after the date of entry into force of the delegated act referred to in the third subparagraph, whichever is the latest (Article 8(1)); the enforceable minimum shares apply from 18 August 2031, rising from 18 August 2036. The same materials and figures as for EV batteries apply:
| Material | First minimum shares — from 18 August 2031 | Second minimum shares — from 18 August 2036 |
|---|---|---|
| Cobalt | 16% | 26% |
| Lithium | 6% | 12% |
| Nickel | 6% | 15% |
| Lead | 85% | 85% |
The figures are set in Article 8(2) and (3); consult the current Official Journal text for the values applicable to each material and date. Declarations must be independently verified by a third party — self-declaration alone does not satisfy the requirement.
Supply Chain Due Diligence
The supply-chain due diligence obligation under Article 48 (Chapter VII, Articles 47–53) applies from 18 August 2027 (as amended by Regulation (EU) 2025/1561), subject to the exemption in Article 47, first paragraph, for economic operators that had a net turnover of less than EUR 40 million in the financial year preceding the last financial year and that are not part of a group which, on a consolidated basis, exceeds the limit of EUR 40 million. It applies to industrial batteries with the same material scope as EV batteries:
| Material | Requirement |
|---|---|
| Cobalt | The supply-chain documentation includes "the country of origin of the raw material" (Article 49(2), point (c)) |
| Natural graphite | The supply-chain documentation includes "the country of origin of the raw material" (Article 49(2), point (c)) |
| Lithium | The supply-chain documentation includes "the country of origin of the raw material" (Article 49(2), point (c)) |
| Nickel | The supply-chain documentation includes "the country of origin of the raw material" (Article 49(2), point (c)) |
Operators must implement and maintain a supply chain due diligence policy incorporating standards consistent with the internationally recognised due diligence instruments listed in point 4 of Annex X, which include the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, and must have their battery due diligence policies verified by a notified body and periodically audited by that notified body (Article 48(2)).
Traceable's Industrial Battery Template
The Traceable industrial battery DPP template provides fields that map to the Annex XIII information categories and is organised into the following sections in the DPP Builder. Using it helps you capture and structure the required data, but it does not by itself make a product compliant — this is not a compliance guarantee.
| Section | Content |
|---|---|
| Battery Details | Identity, model, configuration, specifications |
| Carbon Footprint | Value, lifecycle breakdown, performance class, methodology, verification certificate |
| Recycled Content | Cobalt, lithium, nickel, lead — declared shares |
| Performance & Durability | Capacity, cycle life, calendar life, temperature, state of health at issuance |
| Safety | UN 38.3, applicable standards, extinguishing agent, warnings |
| Supply Chain | Sourcing declarations for cobalt, lithium, nickel and graphite, due diligence statement and report |
| Compliance | DoC reference, REACH declaration, IEC 62619 certificate, safety certification standard |
| End of Life | Collection point locator, recycling instructions, dismantling guide, second-life SoH threshold |
Fields the template requires are marked with a red asterisk. The template also includes optional fields for BESS applications that go beyond Annex XIII.