--- title: Who is responsible for the passport deck: Manufacturers, importers, authorised representatives and software providers all touch the battery passport, but only one party answers for it. Here is where the lines fall. description: Who is responsible for an EU battery passport, what importers must check, what an authorised representative covers, and what stays with you. category: Regulation date: '2026-10-31' image: /assets/tiles/b-3-4.jpg order: 4 --- The battery passport has one responsible party: the economic operator that places the battery on the EU market. That company must keep the passport accurate, complete and up to date (Art. 77(4)). It can hand the work to someone else in writing, but not the responsibility. For batteries made in the EU, that is usually the manufacturer. For batteries made outside the EU, it is usually the importer. ## Importers An importer is the EU-based business that first places a battery from outside the EU on the market. Physically moving the goods is not the test: if you are the first EU entity to make the battery available, you are the importer, even if a freight forwarder handled the shipment. That covers trading companies, distributors importing directly, OEMs sourcing packs abroad and EU subsidiaries of overseas manufacturers. Importers carry nearly the same duties as manufacturers, but they verify rather than create (Art. 41). Before placing a battery on the market, an importer must: - check the manufacturer's EU declaration of conformity, technical documentation and CE marking; - add its own name, address and contact details to the battery, its packaging or an accompanying document; - make sure each battery has a unique identifier and, from February 2027, a passport that exists and is complete; - check the QR code is applied and will stay legible for the battery's life; - keep the declaration and technical documentation for 10 years after the last battery of that type; - stop, withdraw or recall batteries it believes don't comply, and tell the manufacturer and the authorities. Importers that first place batteries on a national market also become producers for extended producer responsibility, with registration and take-back duties in each member state. ## Authorised representatives A manufacturer outside the EU can appoint an EU-based authorised representative by written mandate (Art. 40). The representative can handle administrative tasks, but the mandate can't cover conformity, due diligence or technical documentation. Those stay with the manufacturer, and appointing a representative doesn't relieve an importer of its own checks. ## Distributors and others Distributors may only sell batteries that comply and must report suspected non-compliance. Fulfilment providers can be held responsible when they supply batteries from manufacturers outside the EU. Assembling a new battery from cells or modules makes you the party placing it on the market; fitting a finished battery into a product doesn't. Whoever repurposes or remanufactures a battery takes on the passport for its second life (Art. 77(7)). ## Software and service providers Many companies will use a provider to host passports and register them. That's allowed, with conditions: - The authorisation must be in writing, and responsibility for the content stays with you. - The provider may not sell or reuse the data beyond its service (Art. 78(d)). - The passport must stay available if either of you stops trading (Art. 78(e)). - There is no official list of verified providers yet, and rules for providers registering on a manufacturer's behalf are expected around the second quarter of 2027, after the deadline. Plan to be able to act yourself. Before signing with a provider, settle who controls the address behind the QR code, what export format you get, what happens to the data when the contract ends, and how the access levels are kept apart. ## Practical steps for importers - Write passport data requirements into purchase contracts: the fields, the format and the deadline. - Qualify suppliers against the Art. 41 checklist, and walk away from any that can't supply a declaration of conformity or technical documentation. - Allow three to six months for first data from overseas manufacturers, and ask explicitly for carbon footprint, material origin and recycled-content data. - Run one shipment end to end, from data collection to the labelled battery, before volume arrives. ## FAQ ### Is the importer or the manufacturer responsible for the battery passport? The economic operator that places the battery on the EU market. For batteries made outside the EU that is usually the importer, who must make sure a complete passport exists, even though the manufacturer usually supplies the data. ### Can a software provider take responsibility for our passports? No. You can authorise a provider in writing to do the work, but responsibility for accurate, complete and current data stays with the company that placed the battery on the market. ### Does an authorised representative take over the manufacturer's duties? Only some. A written mandate can cover administrative tasks, but not conformity, due diligence or technical documentation, and it doesn't remove an importer's own duty to check. ## Sources - [Battery passport importer obligations](https://dpphero.com/en/blog/battery-passport-importer-obligations), DPP Hero - [Battery passport registration and service providers](https://dpphero.com/en/blog/battery-passport-registration-service-provider), DPP Hero - [Regulation (EU) 2023/1542](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023R1542), EUR-Lex