What Duties Fall on Each Operator in the LMT Battery Chain?

LMT operator duties are the duties that fall on each economic operator in the LMT battery chain, from manufacturer and importer to distributor and fulfilment service provider, as set out in Regulation (EU) 2023/1542. No single operator carries every duty, and the passport duty in particular sits with the operator who places the battery on the market or puts it into service. Understanding the chain means mapping each duty to the operator who performs the relevant act, rather than assuming that the largest operator in the chain carries all duties.

The LMT chain includes actors who design and manufacture packs, actors who import packs or vehicles, actors who fit packs into vehicles, actors who distribute packs and vehicles, and actors who repair, repurpose or recycle packs. Each actor may also take on the duties of another role when that actor performs the defining act for that role, for example by placing a battery on the market under a private brand. Role follows act, not job title, and a duty map that uses job titles alone will misallocate responsibility.

Who is the manufacturer for an LMT battery?

The manufacturer is the person who manufactures a battery or has a battery designed or manufactured and markets it under a name or trademark. For LMT batteries, the manufacturer carries duties on design, conformity assessment, technical documentation, labelling, CE marking and the declaration of conformity, together with the passport duty where the manufacturer is the operator placing the battery on the market or putting it into service. A manufacturer outside the Union who places batteries on the Union market through an importer does not transfer the manufacturing duties to the importer by that arrangement alone.

A manufacturer record should identify the manufacturing site for the battery model, the design and test evidence, and the conformity route followed. Where manufacture is contracted out, the record should show the contracting arrangement and the evidence held by the manufacturer, rather than assuming that the contractor holds the complete file. Conformity evidence held only by a contractor, without access arrangements for the manufacturer and for authorities, is incomplete evidence for the manufacturer role.

What duties fall on the importer?

The importer is the person established in the Union who places a battery from a third country on the Union market. Importer duties include checking that the manufacturer has carried out the conformity assessment, that technical documentation is available, that labelling and CE marking are correct, and that the passport duty has been fulfilled for the battery as placed on the market. The importer must also indicate identity and contact details as required, keep a copy of the declaration of conformity, and cooperate with market surveillance authorities.

Worked check: an importer receives a shipment of e-bike packs with QR codes that do not resolve. The importer duty is to pause placing on the market until the passport link is verified, not to sell the packs and treat the QR failure as a supplier complaint for later. The check is part of the importer role, and the evidence of the check, with dates and results, belongs in the importer file. A later sale without that check leaves the importer without evidence that the duty was performed.

What duties fall on the distributor?

The distributor makes a battery available on the market without being the manufacturer or importer, and distributor duties centre on care and checking. A distributor must act with due care, check that labelling, CE marking and accompanying information are present and correct, and ensure that storage and transport conditions do not jeopardise conformity. Where a distributor has reason to believe a battery is not in conformity, the distributor must not make it available and must inform the manufacturer or importer and the market surveillance authority where required.

Distributor checking is a proportionate check, not a repeat of the full conformity assessment. The check covers the visible and documentary evidence that a distributor can reasonably verify: carrier resolution, label completeness, declaration availability and absence of obvious damage or mismatch. A distributor who records the checks carried out, with dates and battery identifiers, creates evidence that the duty was performed. A distributor who records no checks has no evidence to show an authority, even when the checks were in fact carried out informally.

When does a distributor or importer become a manufacturer?

A distributor or importer is treated as a manufacturer where that person places a battery on the market under a name or trademark, or modifies a battery already placed on the market in a way that may affect conformity. The consequence is that the full manufacturer duties apply, including conformity assessment, technical documentation and passport responsibility for the battery as placed on the market. Private branding and modification are therefore not labelling choices alone; they are role changing acts with a full duty consequence.

A role change should be recorded as a decision with a date, the act that triggered it, and the new duty map that follows. A distributor who adopts a private brand without creating a manufacturer file will lack the technical documentation and conformity evidence that the new role requires. A modifier who changes a pack housing, cell configuration or battery management system without a conformity review will lack evidence that the modified battery still meets the requirements. The record should show the trigger, the review and the resulting file, in that order.

What is the role of an authorised representative?

An authorised representative is a person established in the Union who has received a written mandate from a manufacturer to act on behalf of the manufacturer for specified tasks. The mandate defines the tasks, and the representative carries out those tasks, such as keeping the declaration of conformity and technical documentation available to authorities. The manufacturer retains overall responsibility, and the mandate does not transfer manufacturer duties in full to the representative. A mandate that is vague about tasks, duration or product scope is a weak basis for authority action.

The mandate file should contain the written mandate, the tasks delegated, the products covered, the duration, and the contact route for authorities. Where a representative also provides passport hosting or data services, that service role should be distinguished from the representative role, because the access and data limits in Article 78 apply to data processing on behalf of the responsible operator. Merging the two roles in one undifferentiated agreement creates confusion about data use limits and authority access.

How are duties coordinated across the chain?

Coordination across the chain is achieved through contracts, data handover checks and evidence files that link each operator to the next. A manufacturer handover to an importer should include the passport record, the declaration and the technical documentation access route. An importer handover to a distributor should include the label, carrier and declaration checks. A distributor handover to a repairer or recycler should include the access tier information that the later actor needs. Each handover is a record event, and the chain is only as strong as the weakest handover.

As checked on 28 October 2026, the full operator chapter in Regulation (EU) 2023/1542 should be read alongside the passport articles, because passport responsibility and operator responsibility interact at the placing on the market point. This guide gives general educational information only and is not individual legal advice. A reader with a specific battery or market decision should check the current Regulation text and any applicable delegated act, as checked on 28 October 2026, before acting.

This guide gives general educational information only and is not individual legal advice. A reader with a specific battery or market decision should check the current Regulation text and any applicable delegated act, as checked on 28 October 2026, before acting. Duty mapping is a chain exercise, and the passport record should name the operator who stands behind each placing on the market event.