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Use the Article 3 category definitions in this order because the definitions exclude each other in important places. Route as an EV battery when it is specifically designed to provide electric power for traction in a hybrid or electric vehicle of category L under Regulation (EU) No 168/2013 and weighs more than 25 kg, or is designed for traction in a hybrid or electric vehicle of categories M, N, or O under Regulation (EU) 2018/858. Route as an LMT battery when it is sealed, weighs 25 kg or less, is specifically designed for traction in a wheeled vehicle powered by an electric motor alone or by motor and human power, and is not an EV battery.

Route as an SLI battery when it is specifically designed for starting, lighting or ignition, including auxiliary or backup use in vehicles, transport or machinery. Route as a portable battery only when it is sealed, weighs 5 kg or less, is not designed specifically for industrial use, and is not EV, LMT or SLI. Route as an industrial battery when it is specifically designed for industrial use, intended for industrial use after repurposing, or weighs more than 5 kg without falling into the EV, LMT or SLI categories.

No. The Batteries Regulation says its scope covers batteries placed on the market or put into service in the Union regardless of whether they are incorporated into appliances, light means of transport or other vehicles, added to products, or supplied separately. Category routing should therefore classify the battery itself and then add the incorporated-product obligations that apply to the product context.

That matters most for portable and LMT batteries. Products incorporating portable batteries must support end-user removability and replaceability unless a stated derogation applies. Products incorporating LMT batteries must support removal and replacement by an independent professional, including the battery cells in the battery pack.

Do not choose the lowest-burden label while facts remain unresolved. The safer operational approach is to record every plausible category, identify the facts that would decide between them, and block release or reporting until the product owner, regulatory owner and supplier can support one classification with evidence.

Once the category is resolved, route every obligation triggered by that category, capacity and use case. For example, Article 7 carbon-footprint obligations focus on EV batteries, rechargeable industrial batteries above 2 kWh and LMT batteries. Article 8 recycled-content obligations cover industrial batteries above 2 kWh, EV batteries, SLI batteries and later LMT batteries when the specified active materials are present. Article 77 battery passports apply to LMT batteries, industrial batteries above 2 kWh and EV batteries.

After classification, route obligations by category, capacity, chemistry, active materials, incorporated-product context and economic-operator role. The category decides which teams own product design, technical documentation, supplier data, conformity assessment, CE marking, declarations, passport data, end-of-life collection and public information.

For market access, manufacturers should expect technical documentation and an EU declaration of conformity to reflect the applicable requirements. Where conformity assessment applies, Article 17 separates procedures for safety, performance, durability, labelling and information requirements from procedures for carbon footprint and recycled content requirements.

Keep enough evidence for a reviewer to understand why the battery was treated as portable, LMT, SLI, EV or industrial and which obligations were then triggered. The evidence should be maintained at battery-model level and linked to the finished product or vehicle only where that context affects classification or incorporated-product obligations.

For each battery model, retain the facts used to classify the battery, the obligation list produced from that classification, and the owner for each follow-up artifact. Evidence should be updated when weight, intended use, vehicle category, battery-management features, active materials, repurposing status, supplier data or incorporated-product design changes.

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. The turnover test uses a moving financial-year reference, so an out-of-scope conclusion should be reassessed for each year in which batteries will be placed on the market or put into service.

From 18 August 2027, 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.

The Regulation's economic-operator definition extends beyond the original battery maker. It 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. Record the legal entity for each role; assigning the roles to a corporate group or brand name alone does not show which entity holds the duty.

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 have their own verification duties. 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.

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. Article 46 requires economic operators to be able to provide supplier and customer identities, quantities, and exact models for 10 years after they receive a battery and for 10 years after they supply it.

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.