EU Batteries Regulation CE marking and conformity assessment FAQ

Article 17 splits the conformity assessment route by requirement type and production pattern. For the requirements in Articles 6, 9, 10, 12, 13 and 14, batteries manufactured in series can use Annex VIII Module A, internal production control, or Module D1, quality assurance of the production process. Batteries not manufactured in series can use Module A or Module G, conformity based on unit verification.

For Article 7 carbon footprint requirements and Article 8 recycled content requirements, Article 17 points series production to Module D1 and non-series batteries to Module G. Batteries that have been prepared for re-use, prepared for repurposing, repurposed or remanufactured need an additional Module A assessment covering Articles 6, 9, 10, 12, 13 and 14.

The manufacturer should treat the CE mark as evidence-backed output. Annex VIII requires technical documentation that lets authorities assess conformity, including the applicable requirements, design and manufacturing information, label specimen, standards or common specifications used, alternative technical solutions where needed, calculations, examinations, technical or documentary evidence, and test reports.

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. The declaration must follow the Annex IX model structure, stay up to date, be translated into the language required by the relevant Member State, and be available electronically and, when requested, on paper.

A notified body is not needed for every battery conformity assessment. Module A is internal production control by the manufacturer. Module D1 and Module G involve a notified body: Module D1 assesses and surveils the production quality system, while Module G verifies an individual battery through examinations, calculations, measurements and tests and issues a certificate of conformity.

Where Annex VIII requires notified body involvement, Article 20 requires the CE marking to be followed by the notified body's identification number. The public notified-body directory should be checked for the body, notification status, Batteries Regulation legislation scope, module, procedure and battery categories.

Importers cannot rely only on a supplier statement. Before placing a battery on the EU market, Article 41 requires importers to verify that the EU declaration of conformity and Annex VIII technical documentation have been drawn up, that the Article 17 conformity assessment has been carried out, that the battery bears CE marking, and that required marking, labelling, documents, instructions and safety information are present.

Distributors have a narrower but still concrete gate under Article 42. Before making a battery available on the market, they must verify producer registration, CE marking, required marking and labelling, required documents, instructions and safety information, and the manufacturer and importer identity details. If either actor has reason to believe the battery is non-conforming, it should not proceed until brought into conformity.

A useful Batteries Regulation conformity file should let a reviewer reconstruct the path from battery scope to CE marking. It should show the battery category, whether the product is series or non-series, which Article 17 module applies, which Articles 6 to 10 and 12 to 14 requirements are relevant, and whether Article 7 or Article 8 triggered notified body involvement.

The evidence file should also separate manufacturer evidence from importer and distributor checks. That prevents a downstream actor from treating CE marking as a substitute for verifying the declaration, technical documentation availability, labels, instructions, producer registration and identity details.