Distributors

Battery Passport Obligations for Distributors

A distributor is generally not the operator that creates the passport, but under Regulation (EU) 2023/1542 it must check a battery is accompanied by a digital passport before making it available and must not pass on non-compliant batteries.

Last updated 1 June 2026

A distributor is an economic operator in the supply chain, other than the manufacturer or the importer, that makes a battery available on the market. Under Regulation (EU) 2023/1542 the obligation to establish the digital passport sits with the operator that places the battery on the market — typically the manufacturer, authorised representative or importer — not with the distributor. But the distributor has its own due-care duties: it must act with due care in relation to the regulation before it makes a battery available.

Verify, do not author

A distributor must check that a battery in scope of Article 77(1) is accompanied by the required QR code and a resolvable digital passport before making it available on the market. Where the distributor considers, or has reason to believe, that a battery is not in conformity — for example the QR code is missing or the passport does not resolve — it must not make the battery available until conformity is restored. If a battery presents a risk, the distributor must inform the manufacturer or importer and the market surveillance authorities.

QuestionDistributor position under 2023/1542
Who creates the passport?The operator placing it on the market (manufacturer / rep / importer), not the distributor
What must the distributor check?That an in-scope battery carries a QR code and a working passport
If the passport is missing?Do not make the battery available until conformity is restored
If a risk is identified?Inform the manufacturer / importer and the authorities
When does this apply?From 18 February 2027 for EV, LMT and industrial (> 2 kWh) batteries

There is a line a distributor should not cross unaware: if it places a battery on the market under its own name or trademark, or modifies a battery already on the market in a way that affects compliance, it is treated as a manufacturer and takes on the manufacturer obligations — including establishing the passport. Routine resale does not trigger that, but private-label and rework arrangements can.

For the cases where a distributor does become the responsible operator — own-brand or modified batteries — a self-serve passport platform turns the data you have into a compliant per-battery passport with the QR code, unique identifier and Annex XIII access tiers handled. Published pricing, 10-year retention.

Frequently asked

Does a distributor have to generate the battery passport?

Generally no. The passport is established by the operator that places the battery on the market — usually the manufacturer, authorised representative or importer. The distributor must verify that an in-scope battery is accompanied by a working passport and QR code before making it available, and must not pass on non-compliant batteries.

When does a distributor become responsible for the passport?

When it places a battery on the market under its own name or trademark, or modifies a battery already on the market such that compliance is affected. In those cases it is treated as a manufacturer under Regulation (EU) 2023/1542 and takes on the passport obligation.

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