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Importer obligations under the EU battery passport rules

What importers must demonstrate when placing industrial, EV, or LMT batteries on the EU market: passport availability, QR access, restricted data, and coordination with manufacturers.

Importers · 9 min · Updated 17 July 2026 · All guides

Who this page is for

Importers who place industrial, EV, or LMT batteries on the EU market, especially when the manufacturer sits outside the Union. Customs officers and customer compliance teams also use these concepts when they evaluate whether a battery can move and whether the passport is reachable.

Exact duties depend on your role under the Battery Regulation. This guide is a working map for programme owners, not legal advice.

What "placing on the market" means in practice

Placing on the market is the first making available of a battery on the Union market. Importers often trigger that event for non-EU manufacturers. When you do, you need a clear answer to three questions: who is the economic operator named on the record, is the passport available via the required identifier path, and can you show the evidence trail if market surveillance asks.

Importer checklist

Obligation areaWhat good looks like
Economic operator identityLegal name, contact, and role consistent across commercial docs and passport fields
Passport availabilityPublished, versioned record for each in-scope model before volume placement
QR / Digital LinkLabel or packaging path resolves to the live public URI without demo hosts
Restricted data handlingAccess path defined for authorities and entitled parties, not only marketing pages
Manufacturer coordinationWritten allocation of who owns field values, PEF inputs, and supplier evidence
Due diligence linkageArticle 48 programme covers materials in the imported chemistries

Where importers typically get stuck

  • Manufacturer holds the engineering data, but the importer is the party customs sees
  • Passports exist in a vendor portal that is not the attested public URI on the label
  • GTIN and serial schemes were never assigned for EU placement and still show demo values
  • Supplier evidence for Co, Li, Ni, or graphite sits with the overseas plant and never enters an EU-accessible vault
  • Repower or remanufactured stock is treated as the original passport without a new placing-on-market review

A workable split with the manufacturer

  1. Importer owns EU market access, economic operator fields, and publish gate timing
  2. Manufacturer owns cell and pack technical inputs and factory-side evidence files
  3. Shared workspace holds the field map so neither side emails conflicting versions
  4. Supplier portal tokens go to material suppliers without forcing full accounts
  5. Audit pack export is rehearseable before the first customs or customer request

What to prepare before the next import cycle

  • List SKUs entering the Union in the next two quarters and their categories
  • Confirm which entity appears as importer on commercial and customs documents
  • Dry-run one passport publish end to end, including QR scan on a phone
  • Align Article 48 risk register owners with the same supplier list used for passports

For a model-level gap view, start with the readiness assessment. For the wider 2027 worklist, see the 2027 checklist.

Related guides

This guide is operational orientation, not legal advice. Confirm obligations with counsel against the current consolidated text of Regulation (EU) 2023/1542 and related acts. AnnexPass provides workflow infrastructure; the customer remains the economic operator.