Knowledge
Who is responsible for the passport?
The obligation lies with the economic operator placing the battery on the EU market. Who that is depends on your role.
The roles at a glance
| Role | Typical situation | Passport |
|---|---|---|
| Manufacturer | Produces and sells under its own name | Responsible |
| Private label | Has products made, sells under its own brand | Generally responsible |
| Importer | Brings batteries from third countries into the EU | Responsible if placing them on the market |
| Distributor | Resells without changing anything | Must check, but usually does not create it |
| Remanufacturer | Remanufactures or repurposes the battery | Responsible for the new passport |
Can I hand over the task?
You may hand the technical implementation to service providers or software. Legal responsibility generally stays with your company.
What applies on repair and repurposing
A simple repair doesn’t change responsibility but belongs in the passport as an event. If the battery is remanufactured or repurposed, responsibility passes to the operator doing so. The passport ends with recycling.
The next step
Clarify your role per product and record it in writing. If in doubt, a legal review is worthwhile, especially for private labels and imports.
Simplified overview, not legal advice. The text of Regulation (EU) 2023/1542 is binding.
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