What do I need to arrange if I give a battery a second life?

What you need to do concretely

An EV battery no longer suitable for a car can serve for years to come as a home storage system or as a buffer at a charging point. An industrial battery from a machine can begin its second life in another device after a test and minor refurbishment. This is called preparation for reuse or repurposing, and the Battery Regulation attaches a number of obligations to it. Whoever gives a battery a second life becomes a market operator with their own responsibilities — even if the battery was originally placed on the market by another party.

What is expected of you

Determine and document the condition of the battery

Before a battery qualifies for a second life, its condition is assessed: remaining capacity, cell health, and whether the battery functions safely for its new purpose. Article 14 of Regulation (EU) 2023/1542 (Battery Regulation) lists information on condition and expected service life as part of what must be known about a battery. For a company of this size, this means in practice that a fixed test protocol is required, with an employee or external laboratory recording the measurement results per battery or per batch. Without that measurement, there is nothing to base the claim that the battery is suitable for repurposing.

Recognise that you become a market operator for this battery

Article 45 of the Battery Regulation describes the obligations of market operators who trade in batteries that have been prepared for reuse or repurposing. Whoever purchases, refurbishes and resells such a battery therefore falls under the same category of obligations as a manufacturer or importer of new batteries — even if this role was never consciously chosen. For a smaller organisation, this is often the biggest misconception: the thought that it is "merely" a second-hand product, whereas the Regulation does not provide a separate lighter category for batteries with a second life.

Keep the passport current or reassemble it

A battery that becomes or remains applicable (for example an industrial battery above the threshold or an EV battery) carries the obligation to hold a digital product passport. With repurposing, the intended use changes, and this affects data in the passport: the expected service life, the condition, and possibly the field of application. For a company that gives batteries a second life, this means that the passport does not automatically remain correct after refurbishment — it is necessary to identify what exactly needs to be updated and who will do it. Does the battery passport also apply to second-hand or refurbished batteries? provides deeper insight into when that obligation precisely arises.

Document origin and traceability

Article 73 of the Battery Regulation describes the conditions under which a battery may be prepared for reuse or repurposing. This includes ensuring that the origin of the battery and what has happened to it in the meantime can be traced. For a company of 10 to 100 employees, this is an administrative task that is easily underestimated: each battery that comes in receives its own file with origin, test results and the operations performed, rather than a collective record per supplier.

Where things go wrong in practice

The battery is sold as "refurbished" without any measurement underlying it. A visual inspection and a brief charge test are taken for a full condition assessment, while there is no underlying test report that substantiates the claim about remaining capacity.

The original manufacturer's passport is passed on without modification. The battery receives a new application, but the data on expected service life and intended use in the passport remain unchanged — whereas they no longer correspond with the actual condition of the battery.

A company sees itself as a "repair shop" and not as a market operator. Because the battery was not produced by the entity itself, it is assumed that the obligations under Article 45 do not apply. However, the regulation does not make this distinction based on who originally manufactured the battery, but on the basis of who places the battery on the market.

Origin data is lost between purchase and revision. Batteries arrive through multiple channels — returned batteries, batches from third parties, returns — and are merged in the process without recording per unit where the battery came from. In the event of a later request for traceability, this can no longer be restored.

No distinction is made between reuse and repurposing. A battery that is resold unchanged for the same purpose is different from a battery that is adapted for a new field of application. This distinction also determines what information is relevant to record and communicate, and is often confused in practice.

What you can record

• A test protocol per battery type, specifying who performs the measurement, which values are recorded, and how often this is repeated.
• A file per battery or per batch containing origin, test results, operations performed and the date of assessment.
• An internal decision on who within the organisation acts as the economic operator within the meaning of Article 45 of the Battery Regulation, and what tasks are associated with this.
• A procedure for updating or redrafting the digital product passport after revision, including who supplies the data to the platform hosting the passport.
• Agreements with suppliers of batteries being refurbished, regarding which origin data they must provide as a minimum.

For companies setting up these steps for the first time, How do I approach the battery passport step by step? an overview of the order in which this is typically handled, and What does a supervisory authority ask for during a battery inspection? describes which documentation is typically requested first in practice.