how do I determine how many charge cycles a battery can handle for the passport

The number of charge cycles comes from the battery manufacturer's own test results

The number of charge cycles a battery can withstand is not calculated by batpas.eu and is not determined by an external party either: that figure comes from the test and production data that the manufacturer or importer already has. Regulation (EU) 2023/1542, Article 14 requires that the battery passport contains information on the condition and the expected life of the battery, but the regulation does not prescribe its own test method that an importer would have to carry out. In practice, this means that the party having the passport drawn up supplies the figures that come from its own quality control, the cell specification from the supplier, or a test report from the producer — batpas.eu processes that data in the passport and the QR data carrier, but does not generate it itself.

Who this applies to and who it does not

This obligation affects every battery for which a digital passport is mandatory: EV batteries, batteries for light electric vehicles such as e-bikes and scooters, and industrial batteries above 2 kWh. For these categories, information on the expected life — including the number of charge cycles the battery can withstand under normal conditions before capacity noticeably decreases — must be a fixed part of the passport. For smaller batteries that fall outside these categories, such as individual batteries for consumer electronics, this passport obligation does not apply and there is therefore no obligation to document charge cycles in this way. It is also important to distinguish from state of health: expected life is a pre-specified expectation based on the design and test results, whereas the state of health of the battery is a current measurement that can change during the battery's service life. Those who confuse these two risk placing incorrect or outdated figures in the passport.

Mandatory from 18 February 2027, nothing recorded until that date

The obligation to maintain a digital battery passport — containing information on expected life — applies from 18 February 2027. Until that date, there is no legal obligation to record this data in a passport. That does not mean there is nothing to do: the underlying test data on charge cycles must be available as soon as the passport is compiled, and collecting that data from existing product documentation is something that can happen in the run-up to that date.

How to approach this

The first step is to check whether the cell manufacturer or the manufacturer of the complete battery already provides a statement of the expected number of charge cycles — at reputable cell suppliers this is usually found in the datasheet or test certificate, expressed as the number of cycles to a certain percentage of the original capacity (often 80%). If this information is available, the next step is to supply that data completely and in the correct form to batpas.eu, together with the other technical specifications needed for the passport.

If an official statement is missing — which can happen with smaller or less well-known manufacturers — the practical route is to ask whether a test report exists, possibly based on a recognised test standard for the battery chemistry in question. Batpas.eu does not carry out this test itself and cannot replace a missing figure with an estimate; the platform processes and hosts the data that is supplied. Anyone in doubt about this would be wise to clarify this directly with the manufacturer or a specialised test laboratory before the passport is compiled, because a passport with a missing or incorrect figure for the expected life is not complete.

A third point to bear in mind: the number of charge cycles does not stand alone in the passport. It is part of a broader block of performance and durability data which also includes items such as capacity, power and temperature resistance. It is therefore practical to collect this data all at once rather than separately for each component, especially since many of these figures come from the same test reports or specification sheets.

Where this is based on

This obligation follows from Regulation (EU) 2023/1542, Article 14, which provides that information on the condition and expected life of a battery forms part of the data that must be known about that battery. Which data exactly must be included in the digital passport itself is detailed in Regulation (EU) 2023/1542, Annex XIII, in which the expected life — with the number of charge cycles as part of it — is named as a data category. A complete overview of all categories that belong in the passport is described on the page on which data must be included in the battery passport.

What to do now

If you wish to prepare now for 18 February 2027, it is advisable to collect the test documentation from cell suppliers and battery manufacturers and check whether it contains a concrete figure for the number of charge cycles. If this figure is missing, now is the time to request it from the manufacturer — not when the passport must already be submitted. Once this data is complete, it can be provided together with the other technical specifications for processing in the battery passport.

What this is based on

The Regulation itself is on EUR-Lex. We refer for each statement; you need not believe us.

What you need to do concretely

What is expected of you

Article 14 of Regulation (EU) 2023/1542 (Battery Regulation) concerns information on the condition and expected life of a battery. Annex XIII to that regulation details which data on this must specifically appear in the battery passport. For charge cycles, this amounts in practice to a couple of separate obligations.

Stating the number of charge cycles to a specified capacity level

Expected life is expressed as the number of times a battery can be charged and discharged before its capacity drops below an established level. For a company with 10 to 100 employees, this means there must be a test result on which this figure is based — not an estimate based on comparable products, but a value that can be traced back to a test or a specification from the cell manufacturer. For those who import batteries and do not test themselves, this figure depends on what the manufacturer supplies abroad. That data must be present, and it must be traceable to the party that established it.

Stating the test method or standard on which the figure is based

A figure alone is not enough: it must be clear under which conditions that number of charge cycles was established. This is relevant because a charge cycle test under constant, mild load produces a different result than a test that puts heavier load on the battery. For a company that procures batteries from multiple manufacturers, this means that figures from different suppliers cannot simply be compared with each other if the underlying test method is not the same. This is especially important when compiling one passport from contributions from multiple parties.

Distinguishing expected life from actual condition

The number of charge cycles stated in the passport is an expectation based on a test at delivery — not a continuous measurement. This is different from the state of health, which indicates the condition of a specific battery at a given moment during use. Both pieces of data belong in the passport, but they answer a different question: one is an expectation at sale, the other is an actual measurement. More about that distinction is in the section on the state of health of a battery and why it must be included in it.

Keep this data consistent with the rest of the passport

The number of charge cycles does not stand alone in the battery passport; it is part of a set of performance data that together provide a picture of how the battery behaves. For an importer having the passport compiled from manufacturer data, it is important that this figure is consistent with the other performance and durability data provided, and is not adopted as an isolated fact from a different manufacturer document than the one on which the other data are based. Which data precisely these are is described at which performance and durability data belong in the battery passport.

Where things go wrong in practice

A number of situations regularly arise when filling in this part of the battery passport.

An importer adopts the number of charge cycles from a general product brochure of the manufacturer, while the brochure does not state at what capacity level that number was determined. Without that reference level, the figure cannot be properly assessed and cannot be properly justified if questions are raised about it.

A trader sells the same battery under different model names, sourced from two manufacturers who each use a different test protocol. The number of charge cycles differs between the two batches, but in their own administration a single figure is used for both models, because the batteries are "in practice the same".

A machine builder incorporates an industrial battery and uses the charge cycle figure for the individual cell, whereas the battery passport is intended for the assembled battery as it is sold. Cell and battery level are thus confused here.

When a product is modified — a new cell supplier, a different battery chemistry — the existing charge cycle figure in the battery passport is not updated, because the modification does not seem significant at first glance. What a new battery chemistry for this figure means is then not reviewed.

A supplier provides a number of charge cycles without an underlying test report existing — the figure was mentioned somewhere at some point and has been adopted ever since, without anyone in the chain knowing where it originally came from.

What you can record

The test report or manufacturer specification on which the stated number of charge cycles is based, including the indication of the capacity level at which the test was carried out.
The name of the test method or standard used in the test, so that the figure remains traceable and comparable.
An overview of which party in the chain — cell manufacturer, battery assembler or importer — has established and supplied the charge cycle figure.
A note at every product modification (cell supplier, chemistry, cell type) whether the charge cycle figure has been reviewed or confirmed.
A link between the charge cycle figure and the other data that according to the data that must be in the battery passport are provided, so that performance data are mutually consistent.
Correspondence with the manufacturer requesting justification for the stated figure, for situations where that figure does not obviously come from the manufacturer's own test work.

This is not legal advice. This page provides general information about the legislation that this platform covers. We do not know your situation. If in doubt about your own case, consult a lawyer or the competent supervisory authority.

Written with AI based on the sources above, checked by a human on 2026-09-05. Is something incorrect? Let us know — corrections take priority.