Importer Implementation Checklist for the Battery Passport

An importer implementation checklist organises preparation in verification order, starting with role and jurisdiction, moving through the data route from the manufacturer, and ending with verification and a pilot record that proves the route works before shipment. The checklist is for an importer that places imported batteries on the EU market, and it covers the passport duty in Article 77 for electric vehicle batteries, light means of transport batteries and industrial batteries over 2 kWh from 18 February 2027. An importer checklist that starts with ordering, without first settling the data route, will receive batteries that cannot be placed because the passport data is missing, and the cost of that failure falls on the importer at the border, not on the manufacturer at the factory.

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

What role and jurisdiction decisions come first?

Role and jurisdiction decisions come first, because the importer must know, for each battery, whether the business is the importer, the distributor or both, which Member State is the placing jurisdiction, and what producer registration and responsibility arrangements apply in that Member State. The decisions should be recorded in a role and jurisdiction register, with the battery models, the placing Member States, the registration positions and the responsibility arrangements listed by Member State. A register that covers only one Member State, while the business sells in several, is an incomplete register, and the checklist should flag any Member State of sale that has no register entry. The register is the foundation for every later verification step.

How is the manufacturer data route agreed?

The manufacturer data route is agreed in writing before shipment, covering the fields to be supplied, the format, the timing, the identifier scheme, the quality checks and the remedy where data is missing or wrong. The agreement should name the Annex XIII fields by category, using the Commission data points guidance as the reference, and should state who supplies each field, in what format, and by what date relative to shipment. A verbal agreement to supply passport data is weak, because a dispute about a missing field will turn on what was agreed, and a written route with field names and dates lets both parties check performance. The route should be tested on a pilot record before the first commercial shipment, as the pilot guide describes.

What verification happens before placing?

Verification before placing covers conformity, labelling, documentation and passport, in that order, with each check recorded by date, by checker and by evidence seen. The conformity check covers the declaration and the technical documentation, the labelling check covers the Article 13 marking and the QR code, the documentation check covers the information that must accompany the battery, and the passport check covers existence, identifier match, tier access and field completeness for the individual battery. A battery that fails any check should not be placed until the failure is fixed and the fix is verified, because placing with a known failure creates a market surveillance record that a later fix cannot erase. The verification file is the importer evidence file.

What does an importer checklist table look like?

An importer checklist table shows the stage, the output and the evidence that proves completion. The table below uses general stages.

How are missing data and errors handled?

Missing data and errors are handled by pausing placing, recording the gap, requesting the data or correction from the manufacturer, and recording the response, rather than by placing the battery and promising a later record. The gap record should name the field, the battery identifier, the date the gap was found, the request made and the response received, so that a later reader can see whether the gap was closed before placing. A pattern of gaps for the same field, from the same manufacturer, should trigger a route review, because a repeated gap indicates a route failure rather than a single error. The review should be recorded, with the route change and the retest date.

How is the pilot record used by an importer?

The pilot record is used by an importer as a test of the whole route, from manufacturer data supply to importer verification to carrier resolution, on one model and one battery, before commercial placing begins. The importer should read the pilot record as a buyer and as an authority would read it, checking identifier match, public fields, legitimate interest access where applicable, and carrier resolution, and should record the reading with dates. A pilot that the importer cannot read is a pilot that has failed, even where the manufacturer can read it, because the importer is the operator who must verify before placing. The pilot reading, with its findings, belongs in the verification file.

What limits apply to an importer checklist?

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