From August 18, 2024, the first set of requirements under the EU Battery Regulation will come into effect. Economic operators, including manufacturers, importers, distributors, authorised representatives, and fulfilment service providers, are obligated to fulfil the specific requirements mentioned in Chapter VI, such as compliance with documentation, CE marking, and labelling standards. This blog explores these crucial obligations in-depth, providing comprehensive insights and practical guidance for navigating regulatory compliance effectively.
Manufacturers
Before placing a battery on the market or in service, the manufacturer should ensure that it is designed and manufactured in compliance with regulation requirements.
Manufacturers must prepare the technical documentation and carry out relevant conformity assessment procedures.
Manufacturers are required to draft an EU declaration of conformity and affix the CE marking.
Manufacturers must ensure that batteries placed on the market bear a model identification, batch or serial number, product number, or another element for identification.
Manufacturers must label the battery with their name, registered trade name or trademark, postal address with a single contact point, and, if available, web and email addresses.
Economic operators engaged in preparing batteries for reuse, repurposing or remanufacturing, and placing them on the market or in service, will be considered manufacturers under this Regulation.
Importers
Before placing a battery on the market, importers must verify that:
The manufacturer has completed the EU declaration of conformity, technical documentation, and relevant conformity assessment procedures.
The battery bears the CE marking and is labelled accordingly.
The manufacturer has met the following requirements:
The battery bears a model identification, batch or serial number, product number, or another identification element.
The battery is labelled with the manufacturer’s name, registered trade name or trademark, postal address with a single contact point, and, if available, web and email addresses.
Importers must label the battery with their name, registered trade name or trademark, postal address with a single contact point, and, if available, web and email addresses.
Importers must ensure that storage or transport conditions do not jeopardise the battery’s compliance while under their responsibility.
Distributors
Before making a battery available on the market, distributors must verify that:
The producer is registered in the register of producers.
The battery bears the CE marking and is labelled accordingly.
The battery is accompanied by the required documents for each requirement with instructions and safety information in a language easily understood by end-users.
The manufacturer and importer have met the following requirements:
The manufacturer ensures that the battery bears a model identification, batch or serial number, product number, or another identification element.
The manufacturer and importer label the battery with their name, registered trade name or trademark, postal address with a single contact point, and, if available, web and email addresses.
Distributors must ensure that storage or transport conditions do not jeopardise the battery’s compliance while under their responsibility.
General note for Manufacturers, Importers and Distributors:
Where it is not possible to mention the required information on the batteries, it shall be provided on the packaging or in a document accompanying the battery
If the battery placed in the market is not in conformity with the requirements, corrective actions will be required to either bring that battery into conformity, withdraw it, or recall it, as appropriate.
EU declaration of conformity should be kept at the disposal of national authorities for 10 years.
Further to a reasoned request from a national authority, the economic operators must demonstrate the conformity of a battery in electronic format and, on request, in paper format.
Authorised Representatives
A manufacturer may designate an authorised representative by a written mandate. The EU declaration of conformity, technical documentation, verification report, and audit reports of battery due diligence by notified bodies must be at the disposal of national authorities for 10 years after the battery has been placed on the market or in service. Further to a reasoned request from a national authority, provide it with all the information and documentation necessary to demonstrate the conformity of the battery. This information and the documentation shall be provided in electronic or paper format.
Fulfilment Service Providers
Fulfilment service providers are responsible for handling the batteries and managing the conditions during warehousing, packaging, addressing,or dispatching without jeopardising battery compliance.
Note:
The authorised representatives and fulfilment service providers should cooperate with the national authorities, at their request, on any action taken to eliminate the risks posed by batteries.
If the battery presents a risk, authorised representatives shall immediately inform the market surveillance authorities.
Obligations of suppliers of battery cells and battery modules
Suppliers of battery cells and battery modules shall provide the information and documentation necessary to comply with the requirements of this Regulation when supplying battery cells or modules to a manufacturer. This information and documentation shall be provided free of charge.
Case Where Obligations of Manufacturers Apply to Importers and Distributors
An importer or distributor will be considered a manufacturer and subject to the obligations of a manufacturer if:
A battery is placed on the market or put into service under that importer’s or distributor’s own name or trademark.
A battery already placed on the market or put into service is modified by the importer or distributor in a way that could affect compliance with the relevant requirements of this regulation.
The purpose of a battery already placed on the market or put into service is modified by the importer or distributor.
Obligations of Economic Operators for Batteries Subject to Preparation for Re-use, Repurposing, or Remanufacturing
Economic operators must ensure that the examination, performance testing, packing, and shipment of such batteries and their components are conducted after following adequate quality control and safety instructions.
Economic operators must ensure that the battery complies with this Regulation and any relevant product, environmental, human health protection, and transport safety requirements.
For remanufacturing operations, economic operators should provide market surveillance authorities with the documentation necessary to demonstrate that the battery has been subject to remanufacturing in accordance with this regulation.
At Battery Associates (B.A), we offer comprehensive compliance solutions for European battery regulations, guiding you through the industry's evolving landscape. Our expert team offers tailored solutions and insights to navigate these requirements seamlessly. Reach out to us for detailed support and information on meeting compliance standards.
About the Author
Junior Analyst - Battery Associates
Gokul is currently a Junior Analyst at Battery Associates. He holds a master's degree in energy engineering from Politecnico di Milano and a bachelor's degree in mechanical engineering. His expertise lies in power generation, renewable energy, and energy storage. Gokul is passionate about battery technology and its ability to fulfill the changing needs of the energy sector. He is particularly interested in battery energy storage systems (BESS) , Electric vehicles (EV) , and promoting a circular economy throughout the battery value chain.
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