Distributor Implementation Checklist for the Battery Passport

A distributor implementation checklist organises preparation in the order in which a distributor handles a battery, starting with the identity and record check on receipt, moving through storage and making available, and ending with the transfer record that passes the battery to the next holder. The checklist is for a distributor that makes batteries available on the EU market without placing them on the market as manufacturer or importer, and it covers batteries within Article 77 from 18 February 2027, as well as batteries outside that duty, where the distributor should still preserve any voluntary record. A distributor who treats receipt as a warehousing act, without a record check, will pass on a battery whose record is broken without ever knowing, and the break will be found by a later holder.

The scope is distributor duties under Regulation (EU) 2023/1542, read as checked on 28 October 2026. The checklist states no advice on pricing, stock or logistics.

What check happens on receipt?

On receipt, the distributor should check the battery identifier against the passport identifier, the model identifier and category against the specification, the data carrier resolution, and the date of the newest record entry, recording each check with the date and the checker. The receipt check is an identity and currency check, not a condition check, and it should be completed before the battery is put into stock, because a battery put into stock without a check becomes indistinguishable from checked stock. A mismatch found at receipt should be raised with the supplier immediately, with the mismatch recorded, rather than being left for the next holder to find. The receipt file, linked by identifier, is the distributor evidence that the check happened.

How is the record preserved during storage?

The record is preserved during storage by keeping the identifier link, protecting the data carrier from damage, storing the battery in conditions consistent with the safety and labelling information, and recording any change of status, damage or repair that occurs during storage. Storage that damages the carrier, obscures the marking or changes the battery without a record entry breaks the continuity that the passport is designed to preserve, even though the battery itself may be unchanged in capability. The distributor should therefore treat carrier protection and status recording as storage duties, not as administrative extras, and should record storage checks at regular intervals with dates. A storage file that contains only stock counts, without record checks, is incomplete.

What check happens before making available?

Before making available, the distributor should repeat the identity and carrier checks, confirm that the record is current to the date of making available, and confirm that any information that must accompany the battery is present. The pre availability check is a fresh check, not a copy of the receipt check, because time has passed, the battery may have been stored, moved or handled, and the record may have been updated. A distributor who relies on the receipt check alone, months later, risks making available a battery whose record has changed or whose carrier has been damaged in the interval. The pre availability check should be dated to the making available date, so that the file shows the check that supported that act.

What does a distributor checklist table look like?

A distributor checklist table shows the handling stage, the check and the record kept. The table below uses general stages.

What transfer record is kept?

The transfer record kept by a distributor should name the battery by identifier, the date of transfer, the outgoing and incoming holder, the status at transfer and any documents that accompany the battery, so that the next holder can read the transfer as the next stage in the same history. The transfer record should be kept with the receipt and storage checks, linked by identifier, forming a distributor file for that battery. Where the transfer involves preparation for reuse or repurposing, the Article 73 documentation should be included, because the transfer then carries a documentation duty beyond the ordinary transfer record. A transfer without an identifier is a transfer that cannot be traced, and it should not be treated as a complete transfer.

How does a distributor handle a broken record?

A distributor who finds a broken record, whether an identifier mismatch, a carrier that does not resolve, a stale record or a status gap, should record the break, notify the supplier, and pause making available until the break is resolved or the position is documented as an open question that the next holder accepts with knowledge. The distributor should not create a new record, overwrite the existing record or invent an entry, because the distributor is not the placing operator and does not own the record. The correct role is to preserve the record as found, to document the break, and to pass the documentation to the supplier and, where the battery is made available, to the next holder with the break disclosed. Disclosure of a break is stronger than silence about it.

What limits apply to a distributor checklist?

The limits are that a checklist is a preparation method, not a conformity assessment, and it does not decide distributor duties for any particular battery. This guide gives general educational information only and is not individual legal advice. A distributor with a specific battery should check the Regulation text as checked on 28 October 2026 before acting.