Battery passport for importers
duties under control
Whoever imports batteries into the EU carries the battery passport responsibility, not the manufacturer in the third country. DPP Hero turns data capture based on DIN SPEC 99100 into self-service.
Your obligations as an importer
EU Battery Regulation 2023/1542: Article 41
- 1
Battery passport available and accessible?
Verify before placing on the market
- 2
Data complete and correct?
All required fields according to Annex XIII
- 3
QR code on the battery?
Check labeling before sale
- 4
Registered in EU DPP registry?
Mandatory for each battery placed on the market
- 5
Documentation secured?
Keep evidence for 10 years
- 6
Stop if non-compliant
No placement on market without a valid passport
Why importers hold the responsibility
If the manufacturer sits in a third country, the EU Battery Regulation does not let you off. Importing EV, industrial or LMT batteries means taking on the duties of the economic operator. The details: battery passport for importers: your duties from 2027.
Legal basis
Article 41 EU 2023/1542
Pre-market checks and due-diligence duties
Responsibility
Importer
Responsible for data accuracy and completeness
Retention period
10 years
Documentation and evidence obligations after market placement
Sanctions
Up to €100,000
Missing registration: up to €100,000; faulty passport or labeling: up to €10,000
From supplier data sheet to complete battery passport
Importer challenge: critical data often sits with third-country manufacturers and arrives incomplete. This workflow closes the gap.
Request data from manufacturer
Through the share link your supplier enters cell chemistry, materials and carbon data themselves. They need no account of their own.
Make gaps visible
The guided workflow shows which required fields are still missing.
Capture in structured format
All required information according to DIN SPEC 99100.
Publish with QR code
Publish product, then download public URL and QR code as PNG or SVG.
Export evidence
JSON and PDF exports for documentation, audits and internal filing.
Handle multiple brands and suppliers
Manage organization data, sites and contacts centrally across products.
No passport means no market access
From 18 February 2027, a battery passport is mandatory for market placement. Violations can lead to significant penalties and sales restrictions.
See non-compliance risksCollect supplier data instead of researching it
DPP Hero requests the missing details from the manufacturer in the third country and merges them into the passport: self-service, no rollout project, hosted in German data centers.
Capture with a checklist
Seven steps show on every field which detail you need from the manufacturer before the goods enter the EU.
- Auto-save with conflict detection
- Supplier links for direct partner input
- CSV import and REST API for full catalogs
Exports for your records
JSON and PDF sit with you, not with your supplier: the basis for the ten-year retention of your evidence.
- JSON in BatteryPass Data Model format
- PDF for internal documentation
- Data export at any time
QR code per imported battery
Every imported battery gets a public passport page and a downloadable QR code.
- GS1 Digital Link identification standard
- QR code as PNG or SVG
- Hosting and product pages included in all plans
What you must check before the first import
Article 41(2) names four points you settle before market entry. They are not a recommendation. Anyone who cannot settle them may not place the battery on the market. And anyone suspecting a gap waits until conformity is established.
1. Conformity assessment and technical documentation
Annex VIII sets out what the technical documentation contains, Article 17 sets the procedure for it. For batteries made in series the manufacturer chooses between internal production control under Module A and quality assurance of the production process under Module D1. So do not just ask whether an assessment happened, ask which module it followed. Both belong in a document, not in an assurance by email. Under Article 41(7) you keep the declaration available to national authorities for ten years from placing on the market.
2. CE marking and label
The battery carries the CE marking under Article 19 and is labeled under Article 13. The label is not the same as the battery passport. It carries the mandatory data on the product, the passport hangs on the QR code. Both have to be right.
3. Documents and instructions in the right language
The battery must come with the required documentation, instructions and safety information. What counts is the language set by the member state where you make it available. English instructions do not automatically satisfy this for the German market.
4. The manufacturer's registration duties
You also check the manufacturer duties under Article 38(6) and (7). If they sit in a third country, EU market surveillance can hardly reach them. The check therefore really rests with you.
Your own labeling duty as an importer
Article 41(3) requires details from you, not from the manufacturer. Required are name, registered trade name or trademark and the postal address with a single contact point. Where available, web and email address are added. These details belong on the battery.
Only where that is not possible may they go on the packaging or in an accompanying document. The order is therefore prescribed. It is not a free choice between three equivalent places.
The language requirement applies here too. The contact details must be drawn up in the language set by the member state, and be clear, understandable and legible. On small cells this becomes a design question, not a label question.
What continues after placing on the market
Importing is not the end of it. Article 41(5) to (7) describes duties that last. In practice they are often overlooked.
Sample testing, complaints and registers
Where the risks call for it, you carry out sample testing of batteries placed on the market. You investigate complaints and, where necessary, keep a register. It lists complaints, non-conforming batteries and recalls. You keep your distributors informed about this monitoring.
Corrective measures and notification
If you suspect that a battery you supplied does not conform, you take corrective measures immediately. You withdraw it or recall it. Where a risk is involved, you inform the market surveillance authority of the member state concerned at once. That includes details of the non-conformity and of the measures taken.
On a reasoned request from an authority you hand over all documentation demonstrating conformity. It has to be in a language the authority readily understands. Electronically, on paper if requested. Ten years of retention is therefore not an archiving matter but the ability to answer. One paragraph is often missed: under Article 41(4), storage and transport must not jeopardise conformity. That covers the battery and its labeling. A label that peels off in a damp warehouse is a breach.
When you count as the manufacturer although you only import
Article 44 reverses the roles. An importer or distributor counts as the manufacturer and is subject to the obligations under Article 38 where one of three conditions applies. The consequence is substantial: checking duties turn into manufacturer duties, including the battery passport and the conformity assessment.
Your own brand
That is Article 44(a) and the most common case in retail. It arises without any technical change to the product: your name or trademark on the battery is enough. Relabeling goods of someone else's brand changes your role.
Modification or a new intended use
Points (b) and (c) start from a battery already placed on the market. Point (b) applies as soon as a change could affect conformity: the possibility is enough, nobody has to prove an actual deviation. For point (c) the new intended use alone is enough, without anyone touching the battery. A portable battery pack you resell as an industrial battery falls under it.
The difference is not a formality: as a manufacturer you are responsible for the battery passport yourself instead of merely checking someone else's documents. Conformity assessment, labeling and registration as a producer come on top.
Who else carries duties besides the importer
The regulation spreads the duties over more roles than manufacturer and importer, and it names two of them differently from everyday use. Under Article 3 the term economic operator covers the manufacturer, the authorised representative, the importer, the distributor and the fulfilment service provider. A manufacturer is whoever markets under their own name; producer in the regulation means only whoever first makes a battery available in a member state and registers for that. Anyone filling one of these roles has duties of their own. That holds without any manufacturing.
Authorised representative and fulfilment service provider
Manufacturers without an establishment in the Union appoint an authorised representative for extended producer responsibility. Registration in the member state runs through them. Fulfilment service providers have their own set of duties in the regulation. Storing, packing and shipping without owning the goods can still put you in the chain. Check early which role you fill in law.
The duty does not end at publication
Annex XIII asks for performance and durability values not only at placing on the market. They are due again when the status of the battery changes. So the passport is not a document you hand in once. It stays current across the lifetime. Assign this task in writing, or you end up with passports in the field and nobody in charge. Which providers connect to DPP Hero is on the partners page. Ongoing notes on deadlines are in the blog.
Frequently asked questions from importers
Who is legally considered an importer?
An importer is the entity that first places batteries from a third country on the EU market. This role carries economic-operator obligations. This often applies to e-bike and LMT batteries as well as industrial batteries.
What if our manufacturer does not provide a battery passport?
You must secure and structure the required data before market placement. DPP Hero helps you request data directly via share links. The battery passport software page shows which data the passport contains.
What happens if we sell without a battery passport?
You may face substantial penalties, withdrawal actions and sales restrictions. Details: battery passport penalties overview.
Do we need to register batteries in the EU registry?
Yes. From 18 February 2027, every battery that needs a passport must be registered in the central EU DPP registry: EV batteries, industrial batteries above 2 kWh and LMT batteries placed on the market. See EU battery passport registry obligations.
How much does preparation with DPP Hero cost?
One passport stays free permanently, so you can run the whole process once against a real shipment. For several imported models, paid plans start at €49 per month. Which plan includes the supplier links is listed on the pricing page.
What do we have to check before importing, besides the passport?
Article 41(2) sets it out exhaustively. You make sure the manufacturer has drawn up the EU declaration of conformity and the technical documentation under Annex VIII. On top comes the conformity assessment under Article 17. The battery carries the CE marking and is labeled under Article 13. This is a duty to check, not to assume: you have to see the documents. You then keep the declaration of conformity available to authorities for ten years.
Do we have to put our own name on the battery?
Yes. Article 41(3) requires the importer to state their name, registered trade name or trade mark, the postal address with a single contact point and, where available, the website and email address. If that does not fit on the battery, the details go on the packaging or in an accompanying document. The manufacturer's name alone is not enough.
What obligations do we have after placing batteries on the market?
Under Article 41(5) you carry out sample testing where the risks call for it. You investigate complaints. Where necessary you keep a register: complaints, non-conforming batteries, recalls. Under paragraph 6 you take corrective measures immediately once you suspect a non-conformity. That extends to withdrawal from the market. The passport helps here because it keeps the data per unit in one place.
When do we suddenly count as the manufacturer ourselves?
When one of three conditions in Article 44 applies. You place the battery on the market under your own name or trademark. You modify it in a way that may affect conformity. Or you change its intended use. Then the full manufacturer duties under Article 38 apply. This hits many private label imports, often unnoticed.
Is the battery passport obligation enough, or do we also have to register?
These are two different things, and both apply. Alongside the passport, Article 55 requires registration in the producer register. It applies in every member state where you first make a battery available. Without it you may not make it available there. In Germany the Stiftung Elektro-Altgeräte Register keeps this list. As an importer the duty usually falls on you, because your manufacturer outside the EU cannot meet it. We supply software for the passport and do not advise on this.
What is an authorised representative for extended producer responsibility?
A person or company established in the member state where batteries are made available. The manufacturer appoints them to carry out its duties under Chapter VIII. Article 55(2) expressly allows registration through this representative. If your third country manufacturer has appointed nobody, the duty stays with you. Settle that before the first import.
Do the supply chain due diligence obligations apply to me as an importer?
Only above a turnover threshold. Article 47 exempts economic operators whose net turnover in the last financial year but one was below 40 million euros and who belong to no group exceeding that limit on a consolidated basis. From 40 million euros the Chapter VII obligations apply, and they take effect on 18 August 2027; the original date was 18 August 2025, and Regulation (EU) 2025/1561 postponed the start by two years. Annex X names exactly four raw materials: cobalt, natural graphite, lithium and nickel. Verification is not by any third party but by a notified body. Below the threshold, you do not need to build a due diligence system.
Which of the data you supply becomes publicly visible?
Annex XIII sets out which data goes into the passport and who may see it. There are three access levels. Public is the smallest part: manufacturer, battery type, general model data. The second level is open to persons with a legitimate interest, so recyclers and repair shops. The third is reserved for notified bodies and authorities. For you that means: you supply in full, only part becomes public. Point 2 holds the detailed composition of cathode, anode and electrolyte. It adds part numbers with spare part supplier contacts and the dismantling information. Point 4 brings, per battery, the state of health, the charging cycles and negative events. Point 3 holds exactly one thing: the results of the test reports. Who counts as a person with a legitimate interest is only settled by the implementing act under Article 77(9).
As importers, do we also have to verify carbon footprint and recycled content?
Yes, they are in the list in Article 41(1). It allows placing on the market only if the battery meets the requirements of Articles 6 to 10 and 12, 13 and 14. That includes Article 7 on the carbon footprint and Article 8 on recycled content. When you can actually check anything depends on timing. The carbon duties are not triggered yet, for lack of a methodology and format act. The Commission guidance of 15 August 2026 lists the carbon footprint declaration and label as not to be filled for February 2027. The recycled content documentation under Article 8(1) comes from 18 August 2028, or 24 months after the delegated act. The minimum shares apply from 18 August 2031, for LMT batteries only from 2036. Until then you check the remaining points, above all the labeling under Article 13.
Request supplier data today
Create an account, send the share link to the manufacturer, capture data along DIN SPEC 99100. One product stays free permanently.