What Is the EU Declaration of Conformity for a Battery?

The EU declaration of conformity is the document by which a manufacturer declares, on sole responsibility, that a battery meets the requirements of Regulation (EU) 2023/1542 and any other applicable Union harmonisation legislation. The declaration is drawn up after conformity assessment, in the form set in Annex IX, and it must be kept available to market surveillance authorities, with a copy provided on request. The declaration is a legal statement, not a marketing summary, and every statement in it must be supported by the technical documentation and the assessment evidence.

Declaration work is often treated as a signature at the end of a project, but the declaration is the point at which the manufacturer takes responsibility for the whole conformity file. A declaration signed before assessment is complete, or signed for a model that differs from the assessed model, creates a false statement even when the battery is sound. The declaration should be the last document in the pre placing sequence, signed only when the file is complete and the battery matches the file.

What must the declaration contain?

The declaration must contain the information set in Annex IX, including manufacturer identification, battery identification, the statement of conformity with the Regulation, references to harmonised standards or other specifications applied, notified body information where a notified body was involved, and the signature and date. The battery identification must allow the declaration to be linked to the specific battery model and, where relevant, to the individual battery passport. A declaration that identifies only a product family, without a model link, cannot be matched to a battery in hand, and an authority cannot use it to verify conformity for that battery.

A declaration check should compare each element against the technical documentation, with the element, the value and the source recorded. A declaration that cites a standard that was not applied, or that omits a notified body that was involved, fails the check even when the remaining elements are correct. The check should be carried out for each model and variant, because a variant with a different notified body involvement or a different standard needs a different declaration.

Who draws up and signs the declaration?

The manufacturer draws up the declaration and signs it, taking sole responsibility for conformity. Where the manufacturer is established outside the Union, the authorised representative may be mandated to draw up and keep the declaration, but the manufacturer retains responsibility. An importer or distributor who becomes a manufacturer by placing a battery under a name or trademark, or by modifying a battery, draws up the declaration in the manufacturer role. A declaration signed by a person without the authority to take responsibility for the manufacturer is not a valid declaration for the battery.

Worked check: a private brand battery is placed on the market by a distributor. The declaration is signed by the distributor in the manufacturer role, with the role change record filed, and the technical documentation held by the distributor. A declaration signed by the original manufacturer, without a role change record, would misstate who stands behind the branded battery. The signatory must match the operator who places the battery under the brand, not the operator who made the cells.

How is the declaration linked to the passport?

The declaration is linked to the passport through the Annex XIII information that carries the declaration and conformity information in the passport tiers, and through the battery identifier that links the declaration, the technical documentation and the passport record. The passport does not replace the declaration, and the declaration does not replace the passport: the declaration is the manufacturer statement of conformity, while the passport is the electronic record of battery information. The two documents must agree on manufacturer, model, identifier and notified body information where both carry it.

Linkage should be checked by comparing the declaration, the passport model tier and the technical documentation for the same battery, with any difference treated as a record error. A difference in manufacturer name spelling, model identification or notified body number between the declaration and the passport will be found by an authority, and the operator will need to explain which document is correct. The check should be carried out before placing, so that the difference is corrected before the battery is on the market.

How long must the declaration be kept?

The declaration, together with the technical documentation, must be kept for ten years from the date the battery is placed on the market, or for the period set in the Regulation for the relevant documents, and must be made available to market surveillance authorities on request. Keeping the declaration for a shorter period, or keeping it in a form that cannot be produced on request, fails the keeping duty even when the declaration was correct at signing. The keeping period runs from placing, not from manufacture, and it applies to each battery model placed, with the placing date recorded per model.

Keeping practice should include a declaration register, listing each declaration, its model, its placing date, its storage location and its retention end date. A register that lists declarations without placing dates cannot show when the retention period ends, and a register without storage locations cannot show how a declaration will be produced on request. The register should be reviewed annually, with declarations due for retention end marked and retained or disposed of under a documented decision, not deleted informally.

What happens when a declaration is wrong?

When a declaration is found to be wrong, the manufacturer must correct the declaration, correct the underlying conformity file where the error lies in the file, and, where the battery has been placed on the market, take corrective action under the non-compliance provisions. A wrong declaration that is corrected only in the file, without correcting the declaration itself, leaves a false statement in circulation. A declaration corrected without correcting the file leaves the same error ready to recur in the next declaration. Both corrections are needed, with the correction recorded and dated.

Correction should be treated as a change event, with the original declaration preserved, the corrected declaration issued with a new date, and the change reason recorded. A correction that overwrites the original declaration without preserving it hides the history that an authority may need to understand a battery placed under the original declaration. A correction that issues a new declaration without a change reason leaves the reviewer unable to judge whether the underlying conformity issue has been addressed.

What language and form rules apply?

The declaration must be drawn up in a language that can be easily understood by the market surveillance authority of the Member State where the battery is made available, and must be in the form and with the content set in Annex IX. A declaration in a language that the authority cannot easily understand, or in a form that omits required elements, does not meet the form duty even when the conformity substance is sound. As checked on 28 October 2026, language and form should be checked per Member State of sale, not from a single home state template. 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 declaration is signed last, kept for ten years from placing, and corrected as a preserved change event when wrong.