EU Batteries Regulation Conformity Assessment and CE Marking

Start with the requirement set being assessed. For Articles 6, 9, 10, 12, 13 and 14, Article 17 allows Module A or Module D1 for batteries manufactured in series, and Module A or Module G for batteries not manufactured in series. For Articles 7 and 8, Article 17(2) specifies Module D1 for series production or Module G for non-series batteries. Article 96 delays Article 17(2) until 12 months after the first publication of the Article 30(2) notified-body list, so verify that application date before treating D1 or G as an operative Article 7 or 8 release route.

If a battery has been prepared for re-use, prepared for repurposing, repurposed, or remanufactured and is being placed on the market or put into service again, Article 17 calls for an additional Module A assessment against Articles 6, 9, 10, 12, 13 and 14. Keep the module choice with the battery model file so importers and distributors can verify it before release.

Annex VIII requires technical documentation that lets assessors and authorities evaluate conformity. For all modules, the record should cover the applicable requirements and the battery's design, manufacture and operation, with a risk analysis, intended use, design and manufacturing drawings, label specimen, applied harmonised standards or common specifications, alternative technical solutions where standards are not used, design calculations, examinations, documentary evidence and test reports.

For Module D1 and Module G files linked to carbon footprint or recycled-content requirements, include the supporting studies, calculations, input-data evidence and methodology references required for Articles 7 and 8. The EU declaration of conformity must follow the Annex IX model structure, identify the battery model or battery, state the Union acts and specifications used, and stay up to date in the required market language.

Articles 19 and 20 apply the general CE-marking principles and require CE marking to be visible, legible and indelible on the battery. If the nature of the battery makes that impossible or unwarranted, the marking goes on the packaging and accompanying documents. It must be affixed before the battery is placed on the market or put into service.

Where Annex VIII requires notified-body involvement, the CE marking is followed by the notified body's identification number. Under Module D1 this follows the production quality-system assessment and surveillance route; under Module G it follows unit verification and the certificate of conformity for the battery concerned.

Manufacturers own the conformity assessment, EU declaration of conformity and CE marking. Importers and distributors still need their own release checks: importers may place on the market only compliant batteries and must verify the declaration, technical documentation, Article 17 procedure, CE marking, labelling, accompanying documents, instructions, safety information and manufacturer identification.

Distributors must act with due care and verify producer registration, CE marking, marking and labelling, required documents, instructions and safety information, plus manufacturer and importer contact information. If an importer or distributor places a battery under its own name or trademark, modifies it in a way that could affect conformity, or modifies its purpose, the manufacturer obligations apply to that actor.