Battery Regulation: Do You Know How It Affects Your business?

 

Why the new European Battery Regulation does not only apply to manufacturers, but may also affect importers, distributors and service organizations 

What new obligations QR codes, digital battery passports and requirements for traceability of batteries in the supply chain will bring 

What dates and areas should companies prepare for in order to pass inspections, tenders and customer requirements 


The new European Battery Regulation may also apply to companies that do not produce batteries themselves. It affects batteries placed on the EU market or put into service, whether sold separately or incorporated into products. The new regulation creates a practical compliance agenda for the entire supply chain: from manufacturers and importers to distributors to service organizations and entities that deal with collection, reuse or recycling. 

Batteries are fast becoming one of the most important elements of European product regulation. This is not just an environmental issue or an obligation for battery manufacturers. 

For many companies, the biggest challenge will not be the actual reading of the regulation, but the ability to prove that they have control over the  products and batteries they market, import or service. Typically, these will be questions: where do batteries appear in products, who places them on the EU market, whether the necessary declarations and technical documentation are available, how service replacements are recorded, and whether the company will be prepared for the requirements for QR codes, digital battery passports or carbon footprint. 
 

Who may be affected by the regulation 

The regulation applies to a wide range of batteries: portable, SLI, LMT, EV and industrial batteries, including batteries integrated into products. In practice, this means that the topic does not have to be addressed only by the manufacturer of battery cells. It can also affect companies that import or distribute battery technology, sell spare batteries, operate a service network or supply battery storage. 

From the point of view of B2B clients, suppliers of battery storage and BESS solutions, distributors of handling equipment, importers of e-bikes and micromobility, importers of electrified agricultural, forestry, construction or mining equipment, companies with spare batteries and organizations where batteries enter service, lease or fleet management are typically relevant. 
 

Why it's not enough to say "I'm just a distributor" 

The role of a company in a chain is not determined only by its business name. What matters is who first places a product or battery on the EU market, who controls the product, whether it is sold under its own brand or packaging, and whether there are changes to the product or its purpose. In a specific situation, the distributor can thus get into a role with broader responsibility, especially when importing from third countries, private label solutions or selling spare batteries independently. 

In practice, importers and distributors are therefore mainly concerned with the verification of conformity and documentation from the manufacturer, an auditable internal pre-sale inspection process, records of batteries in products, spare parts and service replacements, take-back and the ability to cooperate with supervisory authorities or respond to customer requirements and tenders.

Terms worth paying attention to 


Readiness Quick Test: 12 Management Questions 


If you are unsure about any of the questions below, it is advisable to verify the process settings before the topic appears in the inspection, tender or in the request of a major customer.  

Milestone What to take away from it
From 18/02/2024 General applicability of Regulation (EU) 2023/1542: basic scope, obligations, EA, reporting, conformity assessment and other elements of the framework.
From 2026 Required labels and related data readiness for selected categories.
18. 2. 2027 Requirements for the removable and interchangeable of selected portable and LMT batteries; practical impact on product design, service and aftermarket.
From 2027 QR codes and digital battery passports for relevant categories.
18. 8. 2027 Battery Due Diligence obligations.

How BDO can help?

The first step does not have to be a large-scale implementation project. For many companies, it makes sense to do a short practical verification of the impact of regulation on the specific products, equipment and batteries that your company sells, imports or services, or to verify its role in the chain, documentation, take-back and data readiness.  

Area Control question I know / I don't know
Roles in the chain Can you tell for each major product line whether you are a distributor, importer, manufacturer, or entity selling under your own brand?
Portfolio Do you have a list of all battery SKUs including batteries built into products, replacement batteries, and batteries used in service?
Battery Type Do you know for the main products whether they are portable, SLI, LMT, EV or industrial batteries, including chemistry and capacity?
Hidden batteries Do you know which products contain additional integrated batteries, for example in telematics, sensors, alarm or control units?
Documentation Do you have a declaration of conformity for a representative sample of EU products, or do you clearly know who holds it and how quickly you will get it?
Suppliers Do you have a procedure for a situation where the supplier does not provide documentation, is incomplete or does not meet the requirements?
Sale of replacement batteries Who internally confirms that a separately sold replacement battery is OK for sale, and on what basis?
Service When replacing batteries, do you always use OEM parts, or even alternative batteries, and do you keep track of their origin?
Take-back Do you have a process set up for defective, discarded or returned batteries and for their handover or collection?
Data Do you have a data collection method ready for QR codes, battery passport, reporting or customer requests?
Governance Is it clear who owns the topic outside of take-back: purchase, product, service, legal or compliance?
Evidentiary readiness If you were asked about 10 specific battery products today, would you be able to prove why everything is fine in a few days?

Not sure how to implement the new regulation? Contact us. We can do a turnkey implementation, guide you through the most important milestones or verify your readiness.