EU Batteries Regulation conformity assessment route workflow

Create one conformity route record for the battery model, batch, or individual battery. Identify the applicable Batteries Regulation requirements first, because Article 17 uses different modules for the general safety, labelling, performance, and information requirements than it uses for carbon footprint and recycled content.

For requirements in 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 Article 7 carbon footprint and Article 8 recycled content requirements, Article 17(2) points series production to Module D1 and non-series batteries to Module G. Article 96 delays Article 17(2) until 12 months after the first publication of the Article 30(2) notified-body list, so the release record must verify that application date instead of assuming the route is already operative.

Use Module A only where Article 17 permits internal production control. Under Annex VIII Part A, the manufacturer draws up technical documentation, controls manufacturing, affixes CE marking, and draws up the EU declaration of conformity on its own responsibility.

Use Module D1 for series-produced batteries when Article 7 or 8 is in scope, or when the manufacturer chooses D1 for the broader Article 6, 9, 10, 12, 13 and 14 requirement set. Annex VIII Part B requires an approved production quality system assessed by a notified body, plus surveillance audits and evidence checks for recycled content and, where applicable, carbon footprint data.

Use Module G for non-series batteries when Article 7 or 8 is in scope, or when the manufacturer chooses unit verification for all applicable requirements. Annex VIII Part C requires the manufacturer to make technical documentation available to a notified body, which carries out or has carried out the examinations, calculations, measurements, and tests and issues a certificate of conformity.

The technical documentation pack should be assembled before the module decision is treated as complete. Annex VIII requires documentation that makes it possible to assess conformity and that covers the battery's design, manufacture, and operation as far as relevant.

The shared documentation baseline includes the battery description and intended use, design and manufacturing drawings, explanations needed to understand operation, a label specimen, standards or common specifications used, other technical specifications, design calculations and examinations, technical or documentary evidence, and test reports. D1 and G add explicit studies for Article 7 carbon footprint values and class and Article 8 recycled content share where those requirements are in scope.

Article 18 requires the EU declaration of conformity to state that compliance with Articles 6 to 10 and Articles 12, 13 and 14 has been demonstrated. It must follow the Annex IX model structure, contain the elements specified in the relevant Annex VIII module, be kept up to date, and be translated into the language required by the Member State where the battery is placed or made available on the market or put into service.

Article 20 requires the CE marking to be affixed visibly, legibly, and indelibly to the battery, or where that is not possible or warranted, to the packaging and accompanying documents. It must be affixed before the battery is placed on the market or put into service, and followed by the notified body's identification number where Annex VIII requires it.