The anatomy of a stationary record follows Annex XIII of Regulation (EU) 2023/1542, adapted to the structure of a stationary system. The record holds identity, composition, carbon footprint, recycled content, performance and durability, due diligence, and end of life information, with access levels that differ by category. A stationary system adds a layering question that an EV pack does not pose in the same way: information can sit at system level, at rack level, at module level, or at cell level, and the record must state which level holds each item. The passport for an industrial battery over 2 kWh is an electronic record for the battery, accessible through a QR code, and the record must link the levels by identifier so a maintenance entry for one module does not appear to describe the whole system.
Stationary record anatomy means the structure of the passport and linked records for a stationary battery system, including the levels, categories, and access rules. The scope is industrial batteries over 2 kWh used for stationary storage, under Article 77 and Annex XIII.
How is the stationary category decided?
Stationary record anatomy applies within that frame, and the record should not borrow an EV battery rule without checking whether the article applies to industrial batteries. A data manager designing the record for a containerised storage system should record the category decision, including the capacity calculation and the date, because the threshold decision decides whether a passport is required. A system record should hold the system identifier at the top, rack and module identifiers below it, and maintenance entries linked to the module identifier, so a module replacement updates the module history without rewriting the system history.
How is the record built in layers?
For stationary record anatomy, each layer should name its source, its date, and its owner. The record schema, level definitions, and identifier links should be tied to the identifier, so a maintenance entry, a commissioning test, and a passport entry refer to the same system. Where a system is assembled on site from modules, the record should state the assembly date, the assembler, and the point at which the system became a battery placed on the market or put into service, since that point starts the passport duty.
How is performance measured in service?
For stationary record anatomy, 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 data manager designing the record for a containerised storage system 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 system record should hold the system identifier at the top, rack and module identifiers below it, and maintenance entries linked to the module identifier, so a module replacement updates the module history without rewriting the system history.
How is safety information recorded?
For stationary record anatomy, 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 record schema, level definitions, and identifier links should include the test reports, the installation instructions, and the handover of safety information, each dated. Where a system is assembled on site from modules, the record should state the assembly date, the assembler, and the point at which the system became a battery placed on the market or put into service, since that point starts the passport duty.
How are installation and maintenance recorded?
For stationary record anatomy, the commissioning record should state the installer, the date, the tests passed, the settings applied, and any deviations from the design. A data manager designing the record for a containerised storage system 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 system record should hold the system identifier at the top, rack and module identifiers below it, and maintenance entries linked to the module identifier, so a module replacement updates the module history without rewriting the system history.
How are transfer and end of life decisions recorded?
For stationary record anatomy, 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 record schema, level definitions, and identifier links should include the state of health assessment, the safety checks applied, and the new application, where a second life use is claimed. Where a system is assembled on site from modules, the record should state the assembly date, the assembler, and the point at which the system became a battery placed on the market or put into service, since that point starts the passport duty. A data manager designing the record for a containerised storage system 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 a module replacement traced through the levels?
Tracing a module replacement starts at the module level, where the old module identifier, the new module identifier, and the replacement date are recorded, with the work order. The rack level is then updated to show the new module in the rack, and the system level is updated to show the change in the system history, without rewriting the system identity. A worked trace shows the three levels, the identifiers, and the dates, with the old module history preserved. The passport entry for the system is updated where the Regulation requires it, and the version history shows the replacement as a new version. A replacement recorded only at system level, without module identifiers, cannot be traced to the module that was removed or installed.
| Record level | Content | Identifier |
|---|---|---|
| System | Capacity, application, operator | System unique identifier |
| Rack or module | Chemistry, state of health, history | Module identifier, linked to system |
| Site | Installation, commissioning, maintenance | Site record, linked to system |
A stationary record is a set of linked levels, and a record that holds only the system level cannot answer a question about a single module.
Sources & further reading
- Regulation (EU) 2023/1542, consolidated text, EUR-Lex ↗
- Regulation (EU) 2024/1781, ESPR framework, EUR-Lex ↗
- Directive 2008/98/EC on waste, EUR-Lex summary ↗
Source links point to primary materials and further reading, including commercial implementation resources where cited. This introductory guide does not replace the legislation.