Regulation (EU) 2023/1542 assigns the battery passport obligation to the economic operator that places the battery on the market or puts it into service. Which role that is depends on the supply chain: for a battery manufactured inside the EU it is usually the manufacturer, while for a battery manufactured outside the EU it is usually the importer who first brings it onto the EU market.
| Question | Manufacturer | Importer |
|---|---|---|
| Typical situation | Produces the battery, EU-based | Brings a non-EU battery onto the EU market |
| Responsible for the passport? | Yes, if it places the battery on the market | Yes, when it is the operator placing it on the market |
| Must ensure data accuracy | Yes | Yes — cannot rely blindly on the supplier |
| Holds the supporting data | Usually directly | Often must obtain it from the foreign manufacturer |
| Liable to market surveillance | Yes | Yes |
Practical difference for importers
An importer carries the same passport obligation as a manufacturer but rarely holds all the underlying data first-hand. Carbon footprint figures, recycled-content shares and due-diligence information often sit with the foreign manufacturer, so the importer must contractually secure access to that data and verify it before publishing the passport.
- Identify the single operator placing each battery on the EU market.
- For imports, secure data-supply clauses with the foreign manufacturer.
- Verify supplied figures — the responsible operator is liable for accuracy.
- Keep the passport accessible for the full retention period regardless of role.
Frequently asked
If I import batteries, am I responsible for the passport?
Yes. When you are the economic operator placing the battery on the EU market, you carry the battery passport obligation under Regulation (EU) 2023/1542, even though the battery was manufactured elsewhere.
Can the obligation be shared between manufacturer and importer?
The legal responsibility rests with the single operator that places the battery on the market. Data can be supplied by the manufacturer, but accountability for a correct, accessible passport stays with the responsible operator.