How Does the Timeline Differ by Operator Role?

The timeline by operator role shows how the same Regulation dates produce different readiness dates for manufacturers, importers, distributors, repairers, recyclers and second life operators, because each role enters the battery chain at a different point and carries different duties. A single readiness date for every role misstates the chain, because a manufacturer must be ready at placing, a distributor must be ready at making available, and a recycler must be ready at end of life, which can be years after placing. Role timelines should be drawn as separate lines, anchored to the role entry point, with the same Regulation dates marked on each line where they affect that role.

Role timeline discipline is the discipline of asking, for each date, which role must act, what the role must do, and what evidence the role must hold. A date that requires manufacturer action, such as passport creation, does not require distributor action in the same form, and a date that requires distributor checking, such as carrier resolution, does not require manufacturer action in the same form. A timeline that lists dates without roles cannot be used to assign work, and a timeline that assigns every date to every role creates work that no role owns. The role assignment is the point of the timeline.

What is the manufacturer timeline?

The manufacturer timeline is anchored to placing on the market, with classification, conformity assessment, declaration, CE marking, labelling, passport creation and registry interaction all required at or before placing. The manufacturer readiness date is therefore the earliest in the chain, and it is the date by which the passport system, the data system and the marking system must all be tested. A manufacturer who is not ready at placing cannot place, and a placing without a passport, where a passport is required, is non-compliant from the first battery, not from the first authority check.

Manufacturer readiness should be evidenced by a placing gate file, with classification, data, identifier, carrier, access, declaration and registry checks signed off per batch. A gate file without per batch identifiers cannot show which batteries passed the gate, and a gate file without a checker cannot show who approved the placing. The gate file should be retained with the conformity evidence, so that a later query about a placing can be answered from the gate file.

What is the importer timeline?

The importer timeline is anchored to import placing, with checks on conformity assessment, documentation, labelling, marking, passport existence and registry entry required before the imported battery is placed on the Union market. The importer readiness date follows the manufacturer readiness date by the import interval, but the importer check must be complete at import, even when the manufacturer check was complete at manufacture. An importer who relies on the manufacturer check without carrying out the importer check will miss a labelling, marking or passport failure that occurred during transport or repackaging.

Worked check: an importer receives a shipment with passports created by the manufacturer. The importer checks carrier resolution, label completeness and registry entry for a sample by model, and finds one model with a carrier that does not resolve. The importer holds that model, contacts the manufacturer, and the carrier is corrected before placing. A second importer places the shipment without the check, and the carrier failure is found by a retailer, after the battery is on the market. The first importer check prevents a market failure; the second check, carried out too late, becomes a corrective action.

What is the distributor timeline?

The distributor timeline is anchored to making available, with checks on labelling, CE marking, QR code resolution, storage conditions and accompanying information required at receipt and at display. The distributor readiness date is the date by which the distributor checking procedure, the take back arrangement and the storage procedure must be in place. A distributor who is not ready at making available will make batteries available without the checks that the distributor role requires, and the failure will be found by an authority or by a holder, rather than by the distributor.

Distributor readiness should be evidenced by a checking procedure, a take back procedure and a storage procedure, each dated and filed, with receipt checks recorded per batch. A procedure without receipt check records cannot show that the procedure was followed, and a procedure with records only for some batches cannot show that every batch was checked. The records should cover every batch received, with the batch identifier, the check result and the checker named.

What is the repairer and recycler timeline?

The repairer and recycler timeline is anchored to the life stage event, with access to dismantling, safety and passport status information required at the time of repair, recycling or second life assessment, which can be years after placing. Readiness for these roles means that access routes, tier verification and update routes remain available through the life of the battery, even when the original operator or vendor changes. A system that works at placing but fails at repair, because access credentials have lapsed or the hosting arrangement has ended, fails the life cycle purpose of the passport.

Life stage readiness should be tested periodically, with sample access tests for repairer and recycler roles, and with continuity tests for the hosting arrangement. A test carried out only at placing, without periodic retesting, will miss a lapse that occurs later. The test results should be filed with the passport evidence, with the test date and the actor type recorded, so that a later failure can be traced to the last successful test.

What is the second life operator timeline?

The second life operator timeline is anchored to the new placing after preparation for reuse, repurposing or remanufacturing, with assessment, new passport creation, linkage to the original record, conformity for the new stage and operator responsibility all required at the new placing. The second life readiness date is therefore a new placing date, not a continuation of the original placing date, and the operator must be ready with a new classification, a new duty map and a new passport system for the resulting battery. A second life operator who reuses the original passport without a new assessment and a new record will misstate the new battery.

Second life readiness should be evidenced by an assessment procedure, a classification procedure for the new stage, a passport creation procedure with linkage, and a contract allocation for the new operator responsibility. A procedure without a linkage test, showing that the new record links to the original, is incomplete. A procedure with a linkage test, carried out on a sample battery, shows that the chain from original to new stage is preserved. The test result should be filed with the second life evidence.

How are role timelines coordinated?

Role timelines are coordinated through handover checks, with each handover evidenced by the identifier, the documents passed, the checks carried out and the date. As checked on 28 October 2026, coordination should be reviewed after each change to the chain, the system or the Regulation, with the review dated. This guide gives general educational information only and is not individual legal advice. A reader with a specific battery or market decision should check the current Regulation text and any applicable delegated act, as checked on 28 October 2026, before acting.

This guide gives general educational information only and is not individual legal advice. A reader with a specific battery or market decision should check the current Regulation text and any applicable delegated act, as checked on 28 October 2026, before acting. Role timelines are anchored to entry points, and handover checks link the lines into a single chain.