FAQBatteries RegulationEU

EU Batteries Regulation CE marking and conformity assessment FAQ

Article 17 requires manufacturers to choose the right Annex VIII route before placing batteries on the EU market or putting them into service.

This FAQ helps separate Module A, Module D1, and Module G work, document the , and check where evidence is required.

Author
Sorena AI
Published
May 9, 2026
Updated
Jul 24, 2026
Overview

Under Regulation (EU) 2023/1542, CE marking follows the and supporting technical file. The manufacturer must run the Article 17 conformity assessment procedure, draw up the under Article 18, and affix the CE marking under Articles 19 and 20. Importers and distributors then have their own checks before placing or making batteries available on the EU market.

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5 of 5 questions
Question 1

Which Article 17 conformity assessment module applies to batteries?

Article 17 splits the 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.

Article 17 generally applies from 18 August 2024. The Article 7 and 8 in Article 17(2) has a separate trigger: Article 96 says it applies 12 months after the first publication of the Article 30(2) notified-body list. A manufacturer should record the list-publication date used for its applicability decision instead of assuming that every Article 17 route began on the same day.

  • Series production for Articles 6, 9, 10, 12, 13 and 14: Module A or Module D1.
  • Non-series batteries for Articles 6, 9, 10, 12, 13 and 14: Module A or Module G.
  • Articles 7 and 8 for series production: Module D1.
  • Articles 7 and 8 for non-series batteries: Module G.
  • Re-used, repurposed, remanufactured or similar batteries: additional Module A assessment for the listed product, safety, labelling and information requirements.
Recommended next step

Build a Batteries Regulation conformity evidence file

This FAQ helps turn Article 17 module selection, Annex VIII evidence, EU declaration fields, CE marking checks, and market-actor controls into a reviewable Batteries Regulation file.

Question 2

What must the manufacturer prepare before affixing the CE marking?

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 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.

  • Keep the Article 17 module selection and rationale with the product conformity file.
  • Keep the Annex VIII technical documentation and risk assessment evidence.
  • Prepare one for the battery model or battery, as required by the chosen module.
  • Use the Annex IX fields: battery identification, manufacturer details, responsibility statement, object description, Union legislation, standards or specifications, intervention where applicable, and signature details.
  • Keep the declaration and technical file available for national authorities for the Annex VIII retention period: under Module A, keep both for 10 years after the last battery belonging to the model is placed on the market; under Module D1, keep the technical documentation for 10 years after the battery is placed on the market and the declaration for 10 years after the last battery belonging to the model is placed on the market; under Module G, keep both for 10 years after the assessed battery is placed on the market.
Question 3

When does a notified body become part of the Batteries Regulation CE process?

A is not needed for every battery . 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 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.

  • Use Module D1 when Article 17 points a series-production battery to production-process quality assurance.
  • Use Module G when Article 17 points a non-series battery to unit verification.
  • Record the 's name, address, number, intervention and certificates in the where applicable.
  • Keep approval decisions, audit reports, visit reports, test reports or certificates with the conformity file.
  • Do not add a identification number beside the CE mark unless Annex VIII requires it for the chosen route.
Question 4

What should importers and distributors check before batteries reach the EU market?

Importers cannot rely only on a supplier statement. Before placing a battery on the EU market, Article 41 requires importers to verify that the and Annex VIII technical documentation have been drawn up, that the Article 17 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.

  • Importer evidence: , Annex VIII technical documentation availability, Article 17 assessment confirmation, CE marking, labels, documents, instructions and manufacturer identity details.
  • Importer retention: keep a copy of the for 10 years and ensure technical documentation can be made available to authorities on request.
  • Distributor evidence: producer registration check, CE marking check, label and document check, safety information language check, and manufacturer/importer identity check.
  • Escalation evidence: non-conformity hold, corrective action, withdrawal or recall records, and market-surveillance authority communications where a risk is present.
Question 5

What evidence should a CE and conformity assessment file contain?

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 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.

  • Battery model, product category, batch or serial identifiers, intended use and market-placement status.
  • Article 17 module selection record and Annex VIII module evidence.
  • Technical documentation index, including risk assessment, label specimen, standards or common specifications, calculations, test reports and supporting studies for carbon footprint or recycled content where relevant.
  • using the Annex IX structure and translations required for target Member States.
  • CE marking placement proof and identification number proof where Module D1 or Module G requires it.
  • certificates, approval decisions, audit reports, visit reports and test reports where applicable.
  • Importer and distributor verification records, non-conformity holds, corrective actions, withdrawals, recalls and authority responses.
Primary sources

References and citations

eur-lex.europa.eu6 citations
Referenced sections
  • Binding source for Article 17 conformity assessment, Articles 18 to 20 declaration and CE marking rules, Annex VIII modules, Annex IX declaration fields, and importer and distributor checks.
  • Article 17 and Annex VIII identify the applicable Batteries Regulation conformity assessment modules by requirement and production route.
  • Articles 18 to 20 and Annexes VIII and IX set the declaration, technical documentation, CE marking and retention requirements.
Show 3 more
  • Annex VIII describes the notified body role in Module D1 and Module G, including audits, surveillance, certificates and identification numbers.
  • Articles 41 and 42 set importer and distributor verification duties before batteries are placed or made available on the EU market.
  • The Regulation provides the Article 17 module routes, Annex VIII technical documentation elements, Annex IX declaration fields and economic-operator evidence duties.
"Conformity assessment procedures"
More quoted passages
"EU declaration of conformity"
"Surveillance under the responsibility of the notified body"
"Obligations of importers"
"technical documentation"
single-market-economy.ec.europa.eu3 citations
Referenced sections
  • Commission context for CE marking, conformity assessment, accreditation, market surveillance and the product-law framework that Regulation (EU) 2023/1542 uses.
  • Commission product-law overview explaining the New Legislative Framework context for conformity assessment, accreditation, market surveillance and CE marking.
  • Commission product-law overview supporting the distinction between conformity assessment, CE marking and market surveillance checks.
"boost the quality of conformity assessments"
More quoted passages
"clarifies the use of CE marking"
"conformity assessments"
webgate.ec.europa.eu3 citations
Referenced sections
  • Official search page for checking notified bodies by status, legislation, procedure, article or annex, and products.
  • Official EU search page for checking notified bodies by notification status, legislation, article or annex, procedure and products.
  • Official directory source for verifying notified body status and scope before relying on certificates or identification numbers.
"search options to refine a list of bodies"
More quoted passages
"NOTIFICATION STATUS Active"
eur-lex.europa.eu2 citations
Referenced sections
  • Plain-language EUR-Lex overview of the Batteries Regulation lifecycle, conformity, labelling and market-placement obligations.
  • EUR-Lex plain-language summary of the Batteries Regulation lifecycle, labelling, conformity and market-placement framework.
"sustainability rules for batteries"
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