--- title: "EU Batteries Regulation Conformity Assessment" canonical_url: "https://www.sorena.io/artifacts/eu/batteries-regulation/conformity-assessment-and-ce-marking" source_url: "https://www.sorena.io/artifacts/eu/batteries-regulation/conformity-assessment-and-ce-marking" author: "Sorena AI" description: "Article 17 and Annex VIII guide to EU Batteries Regulation conformity assessment, EU declarations of conformity, CE marking, notified bodies, and release evidence." published_at: "2026-05-09" updated_at: "2026-05-09" keywords: - "EU Batteries Regulation" - "conformity assessment" - "CE marking" - "Article 17" - "Annex VIII" - "EU declaration of conformity" - "notified bodies" - "technical documentation" - "Batteries Regulation" - "Conformity Assessment and CE Marking" --- **[SORENA](https://www.sorena.io/)** - AI-Powered GRC Platform [Home](https://www.sorena.io/) | [Solutions](https://www.sorena.io/solutions) | [Artifacts](https://www.sorena.io/artifacts) | [About Us](https://www.sorena.io/about-us) | [Contact](https://www.sorena.io/contact) | [Portal](https://app.sorena.io) --- # EU Batteries Regulation Conformity Assessment Article 17 and Annex VIII guide to EU Batteries Regulation conformity assessment, EU declarations of conformity, CE marking, notified bodies, and release evidence. *Batteries Regulation* *Workflow* *EU* ## EU Batteries Regulation Conformity Assessment and CE Marking A release checklist for selecting the Article 17 procedure, completing Annex VIII evidence, drawing up the EU declaration of conformity, and affixing CE marking. Use it before placing a battery on the EU market, putting it into service, importing it, or making it available through distribution. The EU Batteries Regulation treats CE marking as the visible result of a completed conformity assessment, not as a label-only task. Article 17 selects the assessment module; Annex VIII defines the technical documentation, manufacturer declaration, notified-body involvement where required, and records that must be available to authorities. ## Select the Article 17 conformity assessment route before release 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, the route is narrower: Module D1 for series production or Module G for non-series batteries. 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. - Module A: internal production control, with the manufacturer drawing up technical documentation and declaring conformity on its own responsibility. - Module D1: quality assurance of the production process, with a notified body assessing and surveilling the approved production quality system. - Module G: unit verification, with a notified body carrying out or arranging examinations, calculations, measurements and tests for the battery concerned. - Language gate: records and correspondence for a notified-body procedure must use the official language of the Member State where the notified body is established, or a language accepted by that body. Sources for this answer: - [Regulation (EU) 2023/1542, Articles 17 and 18](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Primary legal source for selecting Module A, D1, or G and for the EU declaration of conformity obligations. ## Build the Annex VIII technical file and EU declaration of conformity Annex VIII requires technical documentation that lets assessors and authorities evaluate conformity. For all modules, the file 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. - Minimum release file: module selection memo, technical documentation index, risk assessment, label specimen, standards or common-specifications matrix, test reports, and EU declaration of conformity. - Carbon and recycled-content add-ons: Article 7 study for carbon footprint values and class, and Article 8 study for recycled-content share where those requirements apply. - Retention gate: Annex VIII keeps technical documentation and declarations available to national authorities for 10 years under the relevant module rules. - Traceability gate: the EU declaration should identify the battery model or battery and match the model, batch, serial number, or product number used on the battery or accompanying documentation. Sources for this answer: - [Regulation (EU) 2023/1542, Annex VIII and Annex IX](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Primary legal source for the technical documentation content, retention rules, and declaration of conformity model. ## Affix CE marking only after the required module is complete 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. - Do not affix CE marking until the selected Article 17 procedure is complete and the EU declaration of conformity has been drawn up. - For Module A, confirm that internal production control evidence supports the applicable Articles 6, 9, 10, 12, 13 and 14 requirements. - For Module D1, retain the notified-body quality-system approval, change approvals, periodic audit reports, visit reports and any test reports. - For Module G, retain the notified-body certificate of conformity and the test, calculation, measurement or examination evidence behind it. Sources for this answer: - [Regulation (EU) 2023/1542, Articles 19 and 20](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Primary legal source for CE marking placement, timing, and notified-body identification-number rules. - [Single Market Compliance Space notified bodies search](https://webgate.ec.europa.eu/single-market-compliance-space/notified-bodies/free-search?ref=sorena.io) - Official EU search page for checking notified-body records by legislation, procedure, article or annex before relying on a body number. ## Use importer and distributor evidence gates before EU market release 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. - Importer hold: no release if the Article 17 procedure, EU declaration of conformity, technical documentation, CE marking, Article 13 markings and required accompanying documents cannot be verified. - Distributor hold: no making available if the producer registration, CE marking, labelling, documents, instructions, safety information, or required manufacturer/importer contact details are missing. - Risk hold: where the battery presents a risk, escalate to the manufacturer or importer and the relevant market surveillance authorities with non-conformity and corrective-action details. - Change hold: if a private-label, technical modification, or purpose change could affect conformity, treat the importer or distributor as assuming manufacturer duties for that battery. Sources for this answer: - [Regulation (EU) 2023/1542, Articles 38, 41, 42 and 44](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Primary legal source for manufacturer, importer and distributor duties connected to conformity assessment and CE-marked batteries. - [New Legislative Framework](https://single-market-economy.ec.europa.eu/single-market/goods/new-legislative-framework_en?ref=sorena.io) - Commission context for CE marking, conformity assessment, market surveillance, and the product-law framework that the Batteries Regulation follows. *Recommended next step* *Placement: after evidence section* ## Turn Batteries Regulation guidance into an evidence workflow Use this Batteries Regulation guide to turn Article 17 module selection, Annex VIII evidence, EU declarations of conformity, and CE marking checks into a release file. - [Open Research Copilot](/solutions/research-copilot.md): Answer Batteries Regulation implementation questions with cited source material. - [Discuss Batteries Regulation implementation](/contact.md): Review scope, source evidence, and next implementation steps with Sorena. ## Primary sources - [Regulation (EU) 2023/1542 on batteries](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Primary legal text for Article 17 conformity assessment procedures, Annex VIII modules, Annex IX declaration structure, CE marking, and economic-operator duties. - Quote: "Conformity assessment procedures" - [Single Market Compliance Space notified bodies search](https://webgate.ec.europa.eu/single-market-compliance-space/notified-bodies/free-search?ref=sorena.io) - Official EU search page for checking notified-body status and scope before using a body number in a CE-marked battery release file. - Quote: "Free search" - [New Legislative Framework](https://single-market-economy.ec.europa.eu/single-market/goods/new-legislative-framework_en?ref=sorena.io) - Commission context for the EU product-law framework behind conformity assessment, notified bodies, CE marking, and market surveillance. - Quote: "boosts the quality of conformity assessment" ## Related Topic Guides - [Batteries Regulation vs ESPR](/artifacts/eu/batteries-regulation/batteries-regulation-vs-espr.md): Compare EU Batteries Regulation duties with ESPR framework rules: scope, economic operators, DPP overlap, delegated acts, sustainability evidence, and reuse limits. - [Battery Passport Data Model Template for the EU Batteries Regulation](/artifacts/eu/batteries-regulation/battery-passport-data-model-template.md): Template for an EU Batteries Regulation battery passport data model: Article 77 scope, QR-linked identifiers, Annex XIII field groups, access tiers, owners, and evidence. - [Battery passport evidence workflow under EU Regulation 2023/1542](/artifacts/eu/batteries-regulation/battery-passport-evidence-workflow.md): Build a battery passport evidence workflow for Article 77 and Annex XIII: QR code access, access rights, provenance, conformity evidence, lifecycle updates, and ownership. - [Battery Passport vs ESPR Digital Product Passport](/artifacts/eu/batteries-regulation/battery-passport-vs-digital-product-passport.md): Compare the EU Batteries Regulation battery passport with the ESPR digital product passport framework across scope, access rights, QR and data carrier rules, interoperability, and reuse limits. - [EU Batteries Regulation Applicability Test](/artifacts/eu/batteries-regulation/applicability-test.md): Decide whether Regulation (EU) 2023/1542 applies to a battery, battery cell, module, pack, product with an incorporated battery, operator role, or EU market activity. - [EU Batteries Regulation Article 11 removability FAQ](/artifacts/eu/batteries-regulation/faq/removability-and-replaceability.md): FAQ on Article 11 removability and replaceability duties for portable and LMT batteries, including end-user removal, professional replacement, spares, software, and evidence. - [EU Batteries Regulation Article 11: battery removability and replaceability](/artifacts/eu/batteries-regulation/removability-and-replaceability.md): Article 11 guidance for portable and LMT batteries: end-user replacement, independent professionals, instructions, spare batteries, compatible batteries, software limits, and evidence. - [EU Batteries Regulation Article 13 labels and consumer information](/artifacts/eu/batteries-regulation/labeling-and-consumer-information.md): Article 13 guide to EU battery labels, separate collection marking, heavy-metal symbols, QR code links, capacity and duration notices, packaging fallback, and evidence. - 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