Manufacturers & importers
Understand how your role and activities affect the questions your organization should investigate.
Map activities as well as job titles
A manufacturer, importer, supplier, or service provider may interact with a battery in different ways. Start with what your organization actually does and how it works with partners.
Useful starting points
- Describe who places the product on the market.
- Record who controls product information and evidence.
- Identify unresolved responsibility questions for review.
Guides in this topic
Authorised representative duties: acting for a manufacturer established outside the Union
An authorised representative acts under a written mandate for defined tasks, and the mandate does not transfer manufacturer responsibility.
What Record Does a Built-In Battery Fulfilment Provider Keep?
A fulfilment provider handling a product with a built-in battery keeps a handling record for warehousing, packaging and dispatch that traces the product and its battery without replacing the placer record.
Distance selling and online marketplaces: passport information in offers made at a distance
An offer made at a distance must show the information a buyer needs before purchase, and the seller behind the offer must be identifiable.
Distributor duties: care, storage, and checking before making a battery available
A distributor must act with due care, verify labelling and identity, and protect the battery and its record while it is stored and transported.
Economic operator checklist by role: a single check sheet for manufacturer, importer, distributor and representative
One checklist, organised by role, lets each operator check only the duties that belong to that role, without borrowing another role's checks.
Fulfilment provider duties: warehousing, packaging and dispatch without becoming the placer
A fulfilment provider stores, packs and dispatches batteries for others, and must not jeopardise conformity or obscure the responsible operator.
Importer duties: checking conformity, identity and passport data before a battery enters the Union market
An importer must verify conformity, identity and labelling before placing an imported battery on the market, and must not rely on a supplier statement alone.
Manufacturer duties: design, conformity, labelling and passport duties for battery makers
A manufacturer must ensure design, conformity assessment, labelling and passport duties are met before a battery is placed on the market.
Operator identification: naming the manufacturer, importer and other actors in a battery record
Operator identification names each actor by legal name, address and role, so that a reader can direct an enquiry to the right person.
Operator changes and succession: preserving passport records when a business changes hands
When a manufacturer, importer or brand changes hands, the passport record and its evidence must transfer with the model, with a dated succession note.
Placing on the market explained: the single act that triggers passport and conformity duties
Placing on the market is the first making available of a battery in the Union, and it is distinct from later making available, putting into service and export.
Responsibility when a battery is modified: when a modifier becomes the manufacturer
A modification that affects conformity, safety or the passport record can make the modifier the manufacturer for the modified battery, with fresh placing duties.
Who is responsible for passport accuracy: the operator who places the battery on the market
Passport accuracy rests with the economic operator who places the battery on the market, who must ensure the record is correct and current even when others supply the data.