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Article 47 says Chapter VII does not apply to economic operators that had net turnover below EUR 40 million in the financial year preceding the last financial year, provided they are not part of a parent-subsidiary group whose consolidated turnover exceeds EUR 40 million.

Article 47 also excludes economic operators, for Chapter VII purposes, in relation to batteries that have been prepared for re-use, prepared for repurposing, repurposed, or remanufactured, if those batteries had already been placed on the market or put into service before those operations.

Once Chapter VII applies, Article 48 focuses on economic operators that place batteries on the market or put them into service. Those operators must set up and implement battery due diligence policies covering the Article 49 management-system duties, Article 50 risk-management duties, and Article 52 disclosure duties.

The raw-material list for Chapter VII is in Annex X: cobalt, natural graphite, lithium, nickel, and chemical compounds based on those materials when they are necessary for manufacturing battery active materials.

Keep enough evidence to show why Chapter VII was treated as in scope or out of scope. For the Article 47 turnover route, that means the operator's net turnover for the relevant financial year and whether it is part of a consolidated parent-subsidiary group above EUR 40 million.

For the battery-specific exclusion, keep records showing the battery had already been placed on the market or put into service before preparation for re-use, preparation for repurposing, repurposing, or remanufacturing. If Chapter VII applies, the evidence file then needs to shift from threshold proof to policy, supply-chain, verification, audit, and disclosure records.

If Chapter VII applies, the operator's battery due diligence policy must be verified by a notified body and periodically audited. Article 51 says third-party verification covers the activities, processes, and systems used to meet Articles 49, 50, and 52, and results in a verification report; an approval decision is issued when the policy fulfils the relevant duties.

Article 52 then creates the disclosure route: make verification, approval, audit, and recognised-scheme evidence available to authorities on request; provide relevant due diligence information to immediate downstream purchasers while respecting confidentiality; and publish an annual internet-accessible report on the battery due diligence policy. If covered raw materials in the battery are from recycled sources, Article 52 requires public disclosure of that conclusion in reasonable detail.

An economic operator is not only the original battery maker. The Regulation includes manufacturers, authorised representatives, importers, distributors, fulfilment service providers, and other persons with obligations linked to manufacturing, preparation for re-use, preparation for repurposing, repurposing, remanufacturing, making batteries available, placing batteries on the market, online supply, or putting batteries into service.

For implementation, build a role table for each battery model and sales route. A single group can hold several roles at once: for example, a company can be an importer for third-country batteries, a producer for first supply in a Member State, and a manufacturer if it sells the battery under its own trademark or changes its purpose.

The manufacturer owns the core product-compliance file. Before placing a battery on the market or putting it into service, the manufacturer must address the applicable design, sustainability, safety, labelling, information, technical documentation, conformity assessment, EU declaration of conformity, CE marking, identification, contact-detail, battery-management-system data, corrective-action, authority-cooperation, and record-retention duties.

Importers and distributors do not simply pass through the file unchecked. Importers must verify the conformity file, CE marking, required documents, safety information, labelling, manufacturer identification, and importer contact details before placing third-country batteries on the market. Distributors must act with due care, check producer registration, CE marking, labelling, accompanying documents, instructions, and manufacturer/importer identification before making batteries available.

Role-change triggers are the part most teams miss. An importer or distributor is treated as a manufacturer if it places a battery on the market or puts it into service under its own name or trademark, modifies a battery in a way that could affect compliance, or modifies the purpose of a battery already placed on the market or put into service.

Second-life work can also reset obligations. Economic operators that carry out preparation for re-use, preparation for repurposing, repurposing, or remanufacturing and then place the battery on the market or put it into service are considered manufacturers for the Regulation. They also need quality control and safety instructions for examination, performance testing, packing, and shipment, and must ensure the battery complies with applicable Batteries Regulation and other relevant product, environmental, health, and transport-safety requirements.

Producer is an extended producer responsibility role, not just another word for manufacturer. The producer definition turns on first supply in a Member State, own-name or own-trademark supply, resale where the original maker's name or trademark does not appear, cross-border supply into a Member State, and direct distance sales to end-users in a Member State.

A producer must register in each Member State where it makes batteries available on the market for the first time. Batteries, including batteries incorporated in appliances, light means of transport, or other vehicles, may only be made available in that Member State if the producer or its authorised representative for extended producer responsibility is registered there.

Keep the role decision close to the battery model, supply route, and Member State. A useful record says which company is acting as manufacturer, authorised representative, importer, distributor, fulfilment service provider, producer, producer responsibility organisation, authorised representative for extended producer responsibility, or second-life operator for the specific battery and transaction.

The evidence should be practical enough for a market-surveillance question: who supplied the battery, who received it, how many and which exact models moved, which conformity and registration checks were completed, and which actor owns corrective action if a risk or non-conformity appears.

A notified body matters when the Batteries Regulation route selected for the battery requires third-party involvement. Article 17 points manufacturers to Annex VIII. For Articles 6, 9, 10, 12, 13 and 14, series batteries can use Module A or Module D1, and non-series batteries can use Module A or Module G. Module A is internal production control, so it does not make NANDO selection the central task.

The notified-body check becomes central when the route is Module D1 or Module G. Module D1 requires assessment and surveillance of the manufacturer's quality system by a notified body. Module G requires a notified body to perform, or have performed, examinations, calculations, measurements and tests for the individual battery. Article 17 also requires Articles 7 and 8 conformity assessment to use Module D1 for series batteries or Module G for non-series batteries.

Use the lookup as a scope confirmation tool. Search for notified bodies under Regulation (EU) 2023/1542, then narrow the result by notification status, article or annex, procedure, and products. The result you need is not simply an active body name; it is an active body whose notification covers the Batteries Regulation task you plan to rely on.

For each candidate, record the body number, legal name, country, notification status, covered legislation, covered procedure, and covered products. If the page or body detail does not show the procedure or product scope needed for your battery model, do not treat the body as confirmed for that task until the scope is verified.

The evidence file should let a reviewer see why a notified body was or was not needed, and why a selected body was in scope. For Module D1, preserve the quality-system application, the declaration that the same application was not lodged with another notified body, the quality-system documentation, the audit decision, later change assessments, surveillance audit reports, visit reports, and any test reports. For Module G, preserve the technical documentation supplied to the notified body, the examination or test basis, the certificate of conformity, and the notified-body identification number used with the CE marking where required.

For due diligence, preserve the notified body's verification report and approval decision under Article 51, audit reports under Article 48, and the public report summary that includes the name of the notified body. Importers should also be able to show that the EU declaration of conformity and technical documentation exist and that the relevant Article 17 conformity assessment was carried out by the manufacturer.

The most common mistake is treating a known laboratory or certification brand as automatically valid for Batteries Regulation work. Regulation (EU) 2023/1542 requires notification for the specific conformity assessment activity. The Commission keeps a public list of bodies notified under the Regulation, including identification numbers and the conformity assessment activities for which they are notified.

Another mistake is collapsing Annex VIII conformity assessment and battery due-diligence verification into one generic supplier check. They can both involve notified bodies, but they support different obligations, records, and outputs. The evidence should show which obligation was being satisfied.

Article 13 sets the label clock first. The separate collection symbol applies from 18 August 2025. General battery labels, capacity labels for rechargeable portable, LMT and SLI batteries, and non-rechargeable portable battery duration and non-rechargeable labels apply from 18 August 2026 or 18 months after the Article 13(10) implementing act enters into force, whichever is later.

The QR code clock is separate. From 18 February 2027, all batteries must be marked with a QR code described in Annex VI Part C. For LMT batteries, industrial batteries above 2 kWh, and electric vehicle batteries, that QR code must provide access to the battery passport under Article 77.

The general label content comes from Annex VI Part A. It includes manufacturer identification, battery category and identifying information, place and date of manufacture, weight, capacity, chemistry, hazardous substances other than mercury, cadmium or lead, usable extinguishing agent, and critical raw materials above 0.1% weight by weight.

Article 13 also adds targeted markings: capacity for rechargeable portable, LMT and SLI batteries; minimum average duration and a non-rechargeable label for non-rechargeable portable batteries; a separate collection symbol for all batteries; and Cd or Pb chemical symbols where cadmium or lead thresholds are exceeded.

For LMT batteries, industrial batteries with a capacity greater than 2 kWh, and electric vehicle batteries, the QR code must open the Article 77 battery passport through a unique identifier attributed by the economic operator placing the battery on the market. Article 77 requires the passport from 18 February 2027 for those battery categories.

For other batteries, Article 13(6) points the QR code to the applicable Article 13 label and marking information, the EU declaration of conformity, the due diligence report where relevant, and waste-prevention and management information. For SLI batteries, the QR code must also provide recovered cobalt, lead, lithium or nickel information calculated under Article 8.

Article 13(10) requires the Commission to adopt implementing acts for harmonised specifications for the Article 13(1), (2), and (3) labelling requirements. That dependency matters because those label obligations apply from 18 August 2026 or 18 months after that implementing act enters into force, whichever is later.

Separate delegated-act powers cover future changes to smart labels and passport information. Article 13(8) allows delegated acts for alternative smart labels instead of, or in addition to, the QR code. Article 77 allows delegated acts to amend Annex XIII passport information and the QR-code or unique-identifier standards. Article 77(9) separately requires implementing acts specifying legitimate-interest access and permitted download, sharing, publication, and reuse rights.

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.