Importers
You import, you are responsible for the passport, the manufacturer has the data
An importer places a battery from a third country on the EU market. The economic operator that places a battery on the market is responsible for its battery passport. But most of the information is known only to the manufacturer. BatteryPass asks for it precisely and shows where every value came from.
Roles
Who is responsible for what
| Role | Who | For the battery passport |
|---|---|---|
| Importer | established in the EU, places a battery from a third country on the market | as the operator placing it on the market, responsible for the information being accurate, complete and up to date |
| Manufacturer | manufactures the battery or has it manufactured and markets it under its own name, often outside the EU | knows composition, performance values and evidence; delivers the data |
| Authorised representative | authorised in writing by the manufacturer to carry out specified tasks on its behalf | takes over the delegated tasks |
With BatteryPass
How the data gets from the manufacturer to you
Precise requests by link
Ask the manufacturer for exactly the fields that are missing, in German or English. They do not need an account.
Evidence next to the value
Data sheets, test reports and declarations are attached to the values they prove and stay at hand for an inspection.
Provenance of every value
You see which value came from the manufacturer, who reviewed it and what has changed since.
Data fields
What the passport says about the manufacturer
From our field registry: the public identification fields for stationary storage. For imports the manufacturer is the actual manufacturer, not the importer.
| Data field | Requirement | Legal basis |
|---|---|---|
| Product name | optional | |
| Model identifier / SKU | required | Annex XIII 1(a); Annex VI Part A(2); Art. 38(6) |
| GTIN (GS1) | required | Art. 77(3) unique identifier (ISO/IEC 15459) |
| Battery category | required | Annex XIII 1(a); Annex VI Part A(2) |
| Manufacturer name | required | Annex XIII 1(a); Annex VI Part A(1); Art. 38(7) |
| Registered trade name or trademark | optional | Annex XIII 1(a); Annex VI Part A(1); Art. 38(7) |
| Manufacturer address | required | Annex XIII 1(a); Annex VI Part A(1); Art. 38(7) |
| Manufacturer email | optional | Annex XIII 1(a); Art. 38(7) (if available) |
| Manufacturer website | optional | Annex XIII 1(a); Art. 38(7) (if available) |
| Responsible economic operator | required | Art. 77(3)–(4) |
| Battery mass (kg) | required | Annex XIII 1(a); Annex VI Part A(5) |
| Warranty period (months) | optional | Annex XIII 1(m) |
| Product image | optional | |
| Serial number | required | Annex XIII 1(a); Annex VI Part A(2); Art. 38(6); Art. 77(3) |
| Manufacturing date | required | Annex XIII 1(a); Annex VI Part A(4) (month and year) |
| Place of manufacture | required | Annex XIII 1(a); Annex VI Part A(3) |
Frequently asked questions for importers
Can the foreign manufacturer create the passport for us?
You can authorise another economic operator in writing to act on your behalf. The economic operator that places the battery on the market stays responsible for the information being accurate, complete and up to date (Art. 77(4)).
What does an importer check before placing a battery on the market?
Among other things, that the battery bears the labelling under Art. 13 (Art. 41(2)). From 18 February 2027 that includes the QR code, which leads to the passport for batteries that have one.
Do the supply-chain due diligence obligations apply to us?
From 18 August 2027 for economic operators with a net turnover of at least EUR 40 million, also as part of a group (Art. 47, Art. 48 as amended by Regulation (EU) 2025/1561). Our field registry treats the related information as conditionally required.
Does the manufacturer need a BatteryPass account?
No. They get a link, fill in only the fields you asked for and upload evidence. Your team reviews the data before it goes into a passport.
Sources
- Regulation (EU) 2023/1542, Article 3: Definitions · Publications Office of the European Union (EUR-Lex) · accessed 25 October 2026
- Regulation (EU) 2023/1542, Article 41: Obligations of importers · Publications Office of the European Union (EUR-Lex) · accessed 25 October 2026
- Regulation (EU) 2023/1542, Article 77: Battery passport · Publications Office of the European Union (EUR-Lex) · accessed 25 October 2026
- Regulation (EU) 2025/1561 (postponement of the due diligence obligations) · Publications Office of the European Union (EUR-Lex) · accessed 25 October 2026