What Is Conformity Assessment for Batteries?

Conformity assessment is the procedure by which a battery is assessed against the sustainability, safety, labelling and information requirements in Regulation (EU) 2023/1542, before the battery is placed on the market. Article 17 sets the conformity assessment procedures, by reference to the modules in Annex VIII, and the procedure that applies depends on the battery type, the requirements in question, and whether the battery is manufactured in series. Conformity assessment is the evidence route to CE marking and to the EU declaration of conformity, and it must be completed before placing, not after sale.

Conformity assessment is often mistaken for a single test or a single certificate. In the battery Regulation, assessment is a structured procedure that combines technical documentation, testing, quality system control where the module requires it, and, where the module requires it, notified body involvement. The procedure, the module and the evidence must match the battery and the requirements, and a procedure carried out under the wrong module, or for the wrong set of articles, does not prove conformity even when the battery itself is sound.

What does Article 17 require?

Article 17 requires that conformity assessment for batteries be carried out in accordance with one of the procedures in Annex VIII, for the requirements laid down in the articles specified for each procedure. Batteries manufactured in series, for requirements in Articles 6, 9, 10, 12, 13 and 14, follow Module A, internal production control, or Module D1, quality assurance of the production process. Batteries not manufactured in series, for the same requirements, follow Module A or Module G, conformity based on unit verification. Batteries for requirements in Articles 7 and 8, on carbon footprint and recycled content, follow Module D1 or Module G. Batteries previously subject to preparation for reuse, repurposing or remanufacturing follow Module A for the relevant requirements.

A procedure map should list the battery type, the series status, the articles in question and the module chosen, with the choice justified in the technical documentation. A map that lists only the module, without the articles and series status, cannot show that the module was the correct route. A map with all four elements allows a reviewer to check the route without reconstructing it from the test reports.

What are Modules A, D1 and G?

Module A, internal production control, is a manufacturer procedure in which the manufacturer prepares technical documentation, carries out or has carried out testing, and draws up the declaration of conformity, without notified body involvement for that module. Module D1, quality assurance of the production process, is a procedure in which the manufacturer operates an approved quality system for production, inspection and testing, and a notified body assesses the quality system and carries out surveillance. Module G, conformity based on unit verification, is a procedure in which a notified body examines an individual battery or batch and issues a certificate for that unit.

Worked check: a series manufactured portable battery is assessed under Module A for labelling and safety requirements, with manufacturer testing and documentation. The same battery type, for carbon footprint requirements where they apply, would need Module D1 or G, with notified body involvement. A file that applies Module A to the carbon footprint requirement, without notified body involvement, uses the wrong module for that article, even though Module A was correct for the labelling articles. The module follows the article, not the battery alone.

How is technical documentation prepared?

Technical documentation for conformity assessment is prepared in accordance with Annex VIII, and must contain the information needed to assess conformity, including design and manufacturing descriptions, test reports, calculations, quality system documentation where the module requires it, and the list of harmonised standards or other specifications applied. Documentation must be kept current, must cover the battery model and variant as placed on the market, and must be available to market surveillance authorities on request. A documentation file that describes an earlier variant, or that omits a test report for a requirement, is incomplete for the battery in hand.

Documentation control should include versioning, a contents list, a test report index and a change log. A file without a contents list is difficult to review, and a file without a change log cannot show whether a design change was assessed. The documentation should be reviewed before each placing, with the review dated, so that a change in design, supplier or test method is caught before the battery is placed, not after an authority query.

What testing is required?

Testing for conformity assessment covers the sustainability, safety, performance and durability requirements that apply to the battery, using the test methods in the harmonised standards or other specifications cited in the technical documentation. Testing must be carried out by a competent laboratory, with the test reports forming part of the technical documentation. A test report that covers a different model, a different chemistry or a different test method from the one cited does not prove conformity for the battery in hand, even when the result is favourable.

Test planning should map each requirement to a test, a method, a laboratory and a report, with the mapping filed as a test matrix. A matrix that lists tests without requirements, or requirements without tests, leaves a gap that a reviewer must fill by inference. A complete matrix allows a reviewer to check, requirement by requirement, that a test exists and that the report supports the declaration. The matrix should be updated when a requirement, a method or a laboratory changes.

When is notified body involvement required?

Notified body involvement is required where the module chosen requires it, principally for Module D1 and Module G procedures, and for the carbon footprint and recycled content requirements in Articles 7 and 8. Notified bodies are conformity assessment bodies notified by Member States, listed in the NANDO database, with the scope of notification covering the battery Regulation procedures. A body that is not notified for the relevant procedure, or whose notification does not cover the battery type, cannot carry out the notified body tasks for that procedure, even when the body is competent in a related field.

Notified body selection should be evidenced by the NANDO entry, the notification scope and the contract, with the scope checked at selection and at each surveillance cycle. A selection based on a general reputation, without a scope check, risks a certificate from a body without the relevant notification. A scope check that is carried out once and never repeated risks missing a change in notification scope. The check should be repeated when the procedure, the battery type or the body changes.

What happens after assessment is complete?

After assessment is complete, the manufacturer draws up the EU declaration of conformity, affixes CE marking in accordance with Articles 19 and 20, and keeps the technical documentation and declaration available for the required period. The passport is prepared as a separate record under Article 77, and conformity evidence and passport data must agree, because the passport carries the declaration and test information in the tiers defined in Annex XIII. As checked on 28 October 2026, assessment, declaration, marking and passport preparation should be checked as a combined pre placing sequence, with each step evidenced before placing. 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. The module follows the article and the battery, and the file should show that route before placing.