輸入事業者向けチェックリスト

If you bring batteries into the EU from a non-EU country and are the first to make them available on the market, you are the importer. That usually makes you the economic operator responsible for the battery passport (Art. 77(4)). The data, however, is almost always held by the manufacturer. This checklist shows what you need and how to get it.

1. Check whether your batteries need a passport

A passport is required for LMT batteries (e-bike, e-scooter, pedelec), industrial batteries above 2 kWh (for example home storage) and electric vehicle batteries placed on the market from 18 Feb 2027. The free obligation check on this site answers this in a few questions.

2. Request this data from the manufacturer

• Manufacturer details: name, brand, postal address, website, e-mail
• Model identifier, battery category, place of manufacture (plant) and date of manufacture
• Weight, capacity (Ah and kWh), nominal, minimum and maximum voltage, power
• Chemistry (for example LFP or NMC), hazardous substances, critical raw materials above 0.1 %, suitable extinguishing agent
• Expected lifetime in cycles with test conditions (C-rate), efficiency, internal resistance of cell and pack, temperature ranges
• Materials of cathode, anode and electrolyte, spare part numbers, dismantling information and safety measures
• EU declaration of conformity and the related test reports
• Per battery: serial or batch number, so that each battery gets its own passport

3. How to get the data

• Ask early. Many manufacturers outside the EU do not yet know the requirements in detail and need time.
• A data sheet alone is rarely enough. Ask explicitly for the Annex XIII fields, ideally as a structured list.
• With Batterypass Online you send your supplier a link. They enter the data themselves, in any of the 24 EU languages or in Chinese; you review it and take it over into the passport.
• Put the data delivery in your contract: which fields, by when, and updates when the model changes.

4. Your other obligations as an importer

• Check that the manufacturer has carried out the conformity assessment, that the technical documentation exists and that the battery bears the CE marking and the required labels.
• Indicate your name and postal address on the battery or, where that is not possible, on the packaging.
• Register in the producer register of each member state where you make batteries available (in Germany with Stiftung EAR) and take part in take-back.
• From 18 Feb 2027, only place batteries that need a passport on the market with a QR code and a valid battery passport.

5. Create the passport and attach the QR code

You create the passport per battery model and add the data of each individual battery. The QR code must be visible, legible and durable on the battery. If that is not possible, it goes on the packaging and accompanying documents (Art. 13(7)). Plan label printing well before 18 Feb 2027.