Industrial over 2kWh threshold explained

The industrial over 2 kWh threshold is the capacity test in Article 77 that decides whether an industrial battery must have a battery passport from 18 February 2027. An industrial battery with a capacity greater than 2 kWh, placed on the market or put into service from that date, must have a passport. An industrial battery with a capacity of 2 kWh or less does not fall under the passport duty on that basis, although the rest of the Regulation still applies, including labelling and the QR code duty. The record must state the capacity, the basis of measurement, the date of the calculation, and the decision, because a threshold decision without a capacity basis cannot be checked. A system assembled from smaller modules needs a decision on the capacity of the battery as placed on the market, not only the capacity of one module.

The threshold means the greater than 2 kWh capacity test for industrial batteries in Article 77(1). Capacity means the energy capacity of the battery as defined and measured under the Regulation and the applicable test method, for the battery as placed on the market.

How is the stationary category decided?

The industrial over 2 kWh threshold applies within that frame, and the record should not borrow an EV battery rule without checking whether the article applies to industrial batteries. A manufacturer deciding passport scope for a range of industrial batteries should record the category decision, including the capacity calculation and the date, because the threshold decision decides whether a passport is required. A range with models at 1.5 kWh, 2 kWh, and 5 kWh should show three threshold decisions, with the 2 kWh model recorded as not greater than 2 kWh, and the 5 kWh model recorded as in scope, each with the capacity basis stated.

How is the record built in layers?

For the industrial over 2 kWh threshold, each layer should name its source, its date, and its owner. The capacity calculation, test record, and threshold decision should be tied to the identifier, so a maintenance entry, a commissioning test, and a passport entry refer to the same system. Capacity should be stated in kilowatt hours, with the rated or nominal basis named, and the record should not mix ampere hour capacity at one voltage with energy capacity at another voltage when applying the threshold.

How is performance measured in service?

For the industrial over 2 kWh threshold, the record should state the capacity test method, the temperature range, the charge and discharge rates, the depth of discharge, and the end of life criterion used for a durability statement. A manufacturer deciding passport scope for a range of industrial batteries should name the standard or method used for each value and should not present a laboratory value as a site value without stating the difference. A range with models at 1.5 kWh, 2 kWh, and 5 kWh should show three threshold decisions, with the 2 kWh model recorded as not greater than 2 kWh, and the 5 kWh model recorded as in scope, each with the capacity basis stated.

How is safety information recorded?

For the industrial over 2 kWh threshold, the record should state the safety tests applied, the battery management system functions that protect the system, the ventilation or enclosure requirements, and the instructions given to the site operator. The capacity calculation, test record, and threshold decision should include the test reports, the installation instructions, and the handover of safety information, each dated. Capacity should be stated in kilowatt hours, with the rated or nominal basis named, and the record should not mix ampere hour capacity at one voltage with energy capacity at another voltage when applying the threshold.

How are installation and maintenance recorded?

For the industrial over 2 kWh threshold, the commissioning record should state the installer, the date, the tests passed, the settings applied, and any deviations from the design. A manufacturer deciding passport scope for a range of industrial batteries should ensure that maintenance entries update the passport or the linked record where the Regulation requires an update, and that earlier entries are preserved. A range with models at 1.5 kWh, 2 kWh, and 5 kWh should show three threshold decisions, with the 2 kWh model recorded as not greater than 2 kWh, and the 5 kWh model recorded as in scope, each with the capacity basis stated.

How are transfer and end of life decisions recorded?

For the industrial over 2 kWh threshold, a transfer of ownership, a change of application, a repurposing of EV modules into stationary service, or a move to recycling each needs a dated entry, a named operator, and a statement of what was transferred. The capacity calculation, test record, and threshold decision should include the state of health assessment, the safety checks applied, and the new application, where a second life use is claimed. Capacity should be stated in kilowatt hours, with the rated or nominal basis named, and the record should not mix ampere hour capacity at one voltage with energy capacity at another voltage when applying the threshold. A manufacturer deciding passport scope for a range of industrial batteries should check the passport or linked record at transfer, record any gap found, and give the gap an owner and a review date.

How is capacity calculated for a modular battery?

Calculating capacity for a modular battery starts with the module capacity, the number of modules, and the configuration: series, parallel, or a combination. The energy capacity is calculated from the module capacity and the system voltage under the stated method, and the result is recorded in kilowatt hours. A worked calculation for a system of ten modules shows the module capacity, the configuration, the system voltage, and the total energy, with the test or calculation basis. If the system can be configured with different module counts, the calculation is done for the configuration as placed on the market, and each configuration receives its own threshold decision. A calculation based on a maximum possible configuration, where a smaller configuration was placed, misstates the threshold for the battery actually placed.

A threshold is a line, and a battery near the line needs the most careful capacity record, not the least.