Importing Batteries From China: a Battery Passport Compliance Checklist

Most e-bike, e-scooter and light electric vehicle batteries sold in Europe are manufactured in Asia, and China is the dominant source. That sourcing choice is entirely normal. What it changes is where the compliance duty sits: buying from outside the EU makes you the importer, and the importer carries obligations that cannot be delegated back to the factory. This checklist covers what to verify, when to raise it, and what to keep.

Why buying abroad puts the duty on you

The regulation defines an importer as a person established in the EU who places on the market a battery from a third country (Art. 3 of Regulation (EU) 2023/1542). That definition is the whole point. Once a battery enters the EU market through you, you are the economic operator answerable for it, and from 18 February 2027 that includes the battery passport. See who is responsible for the battery passport.

A factory can hold a certificate, run the tests and print a CE mark. None of that moves the legal duty to a manufacturer outside the EU.

Before the battery is placed on the market

The regulation sets out specific importer checks (Art. 41). Work through these for every model, not every shipment:

• The manufacturer has done the conformity work. Confirm the EU declaration of conformity has been drawn up, the technical documentation exists, and the conformity assessment was carried out.
• The battery carries the CE marking and is marked and labelled as required. See how the passport, CE marking and UN 38.3 fit together.
• The required documents travel with the goods, and the instructions and safety information are in a language your end users understand. For a multi-market business, that means planning translations rather than discovering them at the border.
• Your own details are on the battery. As importer you must add your name, registered trade name or trade mark, and a postal address as a single contact point.
• Storage and transport do not compromise conformity, which matters for batteries in particular.

Two record-keeping points sit alongside this: keep the EU declaration of conformity for ten years, and be ready to hand documentation to a market surveillance authority on request. If a battery you placed on the market turns out to be non-conforming, you are the party that has to take corrective action, up to withdrawal or recall.

The passport-specific additions

On top of the checks above, the passport brings its own work:

1. Confirm scope per model. LMT batteries are in scope at any capacity; industrial batteries above 2 kWh are in scope. See is my battery in scope or run the scope checker.
2. Collect the Annex XIII data, which mostly originates at the factory. See what your supplier must send you. When the reply is a datasheet, work through how to collect passport data from a supplier who only sends a spec sheet.
3. Agree QR marking with the plant. The code must be printed or engraved on the battery itself unless its size or nature genuinely prevents it, so this is a tooling and artwork change at the factory.
4. Have the passport hosted before the labels print, because the code has to point at a working, stable address.

Timing is the part people underestimate

Distance adds lead time to every step, and the passport work sits upstream of production rather than after it:

• Marking changes go into a production run. Adding a QR code to a pack is an artwork and tooling job the plant schedules, so raise it a run ahead, not a run behind.
• Data requests cross a language and function barrier. The person who answers your emails is usually in sales, while the composition and dismantling detail sits with engineering. Ask for the field list to be routed internally.
• Cell-level data may sit one tier further up. If your supplier assembles packs from bought-in cells, some composition detail belongs to the cell maker.
• Factory calendars are real. Plan around production schedules and holiday shutdowns when you set data deadlines.
• Batteries have their own shipping rules. Transport safety testing for lithium batteries is a separate regime from this regulation and does not substitute for the passport.

Put it in the purchase terms

The single most effective step is contractual rather than technical. Make the passport data a condition of the order:

• List the required fields as an annex to the purchase order.
• Require the supporting documents, not just the values, so declarations are evidenced.
• Require notice of any change to cell supplier, chemistry or pack construction, since that can change the passport.
• Set the data deadline before your production and shipping dates, not alongside them.

A supplier that will commit to this in writing is one you can carry to 2027. A supplier that will not is telling you where the risk is.

The short checklist

For each model you import:

1. Confirm it is in scope and by when.
2. Confirm the conformity documentation, CE marking and labelling exist.
3. Add your importer details to the battery.
4. Collect the Annex XIII data with its evidence.
5. Agree QR placement and marking with the plant.
6. Build and host the passport, with a stable web address.
7. Keep the declaration of conformity for ten years and the data on file.

In short

Sourcing from China or any third country makes you the importer, and the importer carries the conformity checks, the labelling duties, the record-keeping and the battery passport from 18 February 2027. Verify the manufacturer's conformity work, put your own details on the battery, collect the Annex XIII data with its evidence, and agree QR marking with the plant a production run ahead. Write all of it into the purchase terms, because that is what makes it happen on time.