For importers & distributors
Battery passports for importers and distributors
Buying a finished pack does not buy you out of the obligation. Whoever places the battery on the EU market declares the data — and answers for it.
Updated 2026-09-20 · All industries · Guides to the regulation
The part that surprises people
Many importers assume that a battery made by a large, reputable manufacturer arrives compliance-ready. It does not. The passport obligation attaches to the economic operator placing the battery on the EU market. If the manufacturer sits outside the EU, that operator is you — the importer — and with it comes the duty to declare accurate data and to keep the record alive for the battery's lifetime.
This is the same mechanism you already know from CE marking and producer responsibility. The difference is the depth of data: a substance table with CAS numbers and mass percentages, a carbon footprint per kWh with its basis, recycled content shares, and measured performance with the test conditions attached.
What to put in your purchase terms, today
- Structured data, not datasheets. Ask for values in fields you can load, with a named contact responsible for them.
- A delivery deadline that sits comfortably before your first shipment arrives under the new rules.
- Notification of changes. A changed cell supplier changes the composition and the footprint — you must hear about it.
- Evidence. Test reports and declarations, so a claim can be substantiated when an authority asks.
- Serial number discipline. Unique, readable identifiers per unit, agreed in advance, because the passport is per unit.
OrigoPass supports this with supplier requests: you pick the fields you are missing, the supplier fills in only those through a personal link, and nothing lands in your data until you accept it. The acceptance is sealed in the register, so months later you can still show what was declared, by whom and when.
Check what you are told
Declared values become your declarations. A few checks are worth building into your intake:
- Do the substance percentages add up, and is the chemistry consistent with them?
- Is the carbon footprint plausible for that chemistry and that production location, and is the basis stated?
- Is the cycle life given together with the conditions it was measured under? Without conditions it means little.
- Is recycled content stated as a number — including zero — rather than left blank?
- Do the documents match the model you are actually importing, including revision?
An unverifiable claim is a liability that follows the product for fifteen years. Where a supplier has not declared a value, leaving the field empty is safer than filling it with something convenient.
Distributors are not off the hook either
A distributor who sells a battery under its own brand or modifies a product becomes the operator placing it on the market. If you rebrand, relabel or repackage, assume the passport obligation is yours and arrange the data accordingly.
Practical setup for a trading operation
- One product record per supplier model, versioned, so a changed cell supplier becomes a new version rather than a silent edit.
- Bulk registration by Excel or API when a container lands, with duplicate-serial protection.
- Pre-created identifiers when you have labels applied at the factory.
- Your own domain on the code, so a change of supplier never breaks the link on a product already sold.
General information, not legal advice. Verify obligations for your specific products against the regulation and, where needed, with a qualified adviser.
Frequently asked
Who must create the battery passport when the battery is manufactured outside the EU?
The importer placing it on the EU market. The obligation attaches to the economic operator placing the battery on the market, and a manufacturer outside the EU is not that operator. In practice this means you declare the data, keep it current, and are the party market surveillance will contact.
Can a supplier or software provider take over the responsibility?
No. A supplier provides data and a platform provides infrastructure, but neither can assume the legal obligation. What you can do is make data delivery a contractual requirement, and keep evidence of what a supplier declared and when.
What if our supplier refuses to provide composition or carbon footprint data?
Then you cannot complete a compliant passport, and the product cannot be lawfully placed on the market from 18 February 2027. This is a commercial issue to settle now: put the data deliverables in your purchase terms, with a deadline well before the batteries arrive.