Operator identification: naming the manufacturer, importer and other actors in a battery record

Operator identification means naming each economic operator connected with a battery by legal name, address and role, in a way that allows a reader to direct an enquiry, a complaint or an authority request to the right person. The Battery Regulation requires manufacturer and importer identification on the battery or in the permitted alternative location, and the passport record carries manufacturer identity in Annex XIII point 1. Other actors, including authorised representatives, distributors and fulfilment providers, are identified through marking, documentation, listings and record systems as their role requires.

Identification is not branding. A trade name, a website or a marketplace store name does not replace a legal name and address, and a reader who is given only a brand cannot establish the legal person responsible.

What identification does the manufacturer carry?

The manufacturer is identified by legal name, registered trade name or trade mark, postal address, and a single contact point where available, including web and email address. The legal name is the anchor. The trade name helps a reader recognise the product, but it does not identify the legal person where the trade name is used by more than one legal person or where the trade name has changed. The postal address must be an address at which the manufacturer can be contacted, not a manufacturing plant address alone where that address is not a contact address, and not a distributor address presented as the manufacturer. The passport record shows the manufacturer name and address as in the technical documentation and the declaration, so that the three sources agree. A mismatch between marking, record and declaration on manufacturer identity is an identity defect, and it blocks reliance on the rest of the record until resolved.

What identification does the importer carry?

The importer is identified by name, registered trade name or trade mark, postal address and single contact point, on the battery or, where that is not possible, on packaging or in accompanying documentation. Importer identification is additional to manufacturer identification, not a substitute for it. The reader should be able to distinguish the two roles from the information provided: the manufacturer made or had made the battery, the importer placed the imported battery on the Union market. Where the importer and the manufacturer are the same legal person, the identification should still make the role clear, so that a reader does not mistake a Union establishment for a third country manufacturer, or vice versa. Where a battery is imported by more than one importer for different consignments, each consignment should carry the identification of the importer who placed that consignment, because importer responsibility follows the placing act for the units concerned.

How are other actors identified?

An authorised representative is identified by name and address, with the role stated, and with the manufacturer on whose behalf the representative acts named alongside. A distributor is identified through commercial documentation, invoices, listings and the information that accompanies the battery, with the distributor role clear from the context of the transaction. A fulfilment provider is identified through warehouse and dispatch records, and through cooperation with authorities, rather than through marking on the battery, unless the provider has assumed an operator role that requires marking. An online marketplace is identified as the platform operator, distinct from the seller, and the seller identification in the listing is the identification that matters for the transaction. Each actor identification should state the role, because a name without a role leaves a reader guessing whether the person named is responsible, is a contact, or is merely a seller.

What does the identification table show?

How is identification checked?

Identification is checked by comparing sources: marking against record, record against declaration, listing against invoice, dispatch record against stock record. The check confirms that the legal name and address agree, that the role is stated, and that the contact route works in principle, meaning that the address and contact point are present and in a usable form. The check does not confirm that the address is current, that the contact point is monitored, or that the person named will respond. Currency of contact information is a separate maintenance duty, and a record that shows an old address for a manufacturer that has moved misdirects enquiries even though the name is correct. Identification checks should therefore include a currency note: the date on which the identification was last verified, and the source of the verification.

What limits apply to identification?

Identification states who an actor is and what role the actor holds. It does not state that the actor is compliant, that the actor will cooperate, or that the actor holds the evidence a reader seeks. A correct name and address are the starting point for an enquiry, not the end of it. This guide gives general educational information only and does not give legal advice for a particular operator, battery or transaction.