Economic operator checklist by role: a single check sheet for manufacturer, importer, distributor and representative

A checklist by role allows each economic operator to check the duties that belong to that role, and only those duties, before a battery is placed or made available. A single checklist for all roles invites two errors: an operator checks duties that belong to another role and assumes the other role has checked them, or an operator omits a duty because the checklist presents it as another role’s task.

The checklist below is organised by role, with a result column for each item: done, not done, not applicable with reason. The checklist is a working tool, not a record, and a completed checklist does not prove compliance. It proves that the checks listed were performed, on the date stated, for the battery or consignment stated.

What does the manufacturer section check?

The manufacturer section checks design and manufacture in accordance with Articles 6 to 10 and Articles 12 and 14, technical documentation under Annex VIII, conformity assessment under Article 17, declaration of conformity under Article 18, CE marking, marking and labelling under Article 13, instructions and safety information in the required language, and passport model data under Article 77 and Annex XIII. Each item requires evidence: the technical documentation reference, the declaration reference, the test report reference, the labelling artwork, and the passport model record. A manufacturer check that records done without an evidence reference cannot be verified later. The section also checks that supplier evidence for composition, carbon and recycled content has been obtained and checked for match, and that version control is in place for specification changes.

What does the importer section check?

The importer section checks that the manufacturer has carried out the conformity assessment and drawn up the technical documentation and declaration, that the battery bears the CE marking and required labelling, that instructions and safety information accompany the battery, that importer identification is present, that the declaration and documentation can be made available, and that the passport record exists, resolves through the carrier, and matches the model and consignment. The importer does not repeat the conformity assessment, but the importer does inspect the evidence listed. An importer check that records a declaration as seen, without the model identifier and date, cannot be matched to the consignment later. The section also checks storage and transport conditions from receipt to placing, because the importer is responsible for ensuring that conditions do not jeopardise conformity while the battery is in its care.

What does the distributor and representative section check?

The distributor section checks due care verification of marking, labelling, instructions and importer and manufacturer identification, storage and transport conditions, carrier readability, and the procedure for non conformity and recall. The authorised representative section checks the written mandate, the tasks delegated, the availability of the declaration and technical documentation, the contact route, and the cooperation procedure with authorities. The two sections are kept separate, because a distributor and a representative are different roles, even where one person holds both roles for different models. A person who holds both roles must complete both sections, and must not treat a check in one role as a check in the other. The table below summarises the checklist structure.

How is the checklist used for a consignment?

The checklist is completed per battery model and per consignment, with the model identifier, the consignment or batch reference, the date, and the checker role stated. A checklist completed for a model in general, without a consignment reference, cannot be matched to units placed. A checklist completed after placing, backdated to before placing, falsifies the check history and must not be used. Where a check cannot be performed before placing, because evidence is awaited, the battery must not be placed until the check is performed, unless the Regulation provides a specific route for the situation. The checklist should state the reason for any not applicable item, so that a reviewer can tell whether the item was considered and found inapplicable, or was overlooked.

How are checklist results retained?

Checklist results are retained with the technical documentation and the record register, for the retention period that applies to the documentation. Retention allows a later check, an authority inspection, or a succession transfer to reconstruct what was checked and when. A checklist that is discarded after placing leaves no evidence of the check, and the operator cannot demonstrate that the check was performed. Retention is part of the check, not an administrative extra. The checklist should be versioned where the duties or the model change, so that a check performed under an earlier version is not presented as a check under the current version.

What limits apply to a checklist pass?

A checklist pass states that the listed checks were performed with the evidence references stated. It does not state that the battery is compliant, that the evidence was correct, or that a duty outside the checklist was met. This guide gives general educational information only and does not give legal advice for a particular operator, battery or consignment.