Who Is Responsible for the Battery Passport? The Importer's Obligation Explained

One of the most common misunderstandings about the battery passport is who has to produce it. Many importers assume the passport arrives with the goods, prepared by the manufacturer. It does not. Under the EU Battery Regulation, the duty sits with the economic operator that places the battery on the EU market, and for most importers that operator is you. This guide explains why, and what it means in practice.

The rule: whoever places it on the market

Regulation (EU) 2023/1542 puts the passport obligation on the economic operator that places the battery on the EU market. "Placing on the market" is the act of making the battery available in the EU for the first time. If you are the one bringing batteries in from outside the EU and selling or supplying them here, you are that operator, acting under your own EORI number.

This is a deliberate design. The regulation attaches the duty to the party inside the EU that puts the product into circulation, because that party is reachable by EU market-surveillance authorities. A manufacturer in another jurisdiction is not.

Why it cannot be handed back to your supplier

A non-EU manufacturer can send you everything you need to build the passport: chemistry, test reports, carbon footprint data, recycled content figures. What it cannot do is carry the legal obligation for you. The duty does not travel back up the supply chain to a supplier outside the EU, and it does not move to the online marketplace that lists your product or the freight forwarder that ships it.

This is the point many importers miss. You can buy a battery that already has a CE mark and a full set of test reports and still be the party responsible for producing and hosting its passport. The supplier's documents are inputs to your passport, not a substitute for it.

What "responsible" actually involves

Being the responsible operator means you are accountable for:

• Producing the passport with the Annex XIII data set for each battery model in scope. See Annex XIII explained.
• Attaching the data carrier, the QR code or equivalent, so the passport is reachable from the physical battery. See the data carrier and QR code rules.
• Keeping it available online for the working life of the battery. See how long a passport must stay online.
• Standing behind the declared data to authorities. The tool hosts what you declare; you remain the operator answerable for it.

What this means for your buying process

If the passport is your responsibility, it belongs in your purchasing conversation, not after it. Two practical moves help:

1. Ask suppliers for the Annex XIII data before you commit an order, so a model that cannot supply the data does not become a compliance gap later. See what your supplier must send you.
2. Confirm scope per model with the scope checker, so you know exactly which products carry the duty.

In short

The battery passport obligation falls on the economic operator placing the battery on the EU market, and for importers that is normally you, under your own EORI. It cannot be handed back to a non-EU supplier or pushed onto a marketplace or carrier. Your supplier's data feeds the passport; the responsibility for building, labelling and hosting it stays with you.