Marking and the declaration of conformity

The declaration of conformity is the signed statement by which the manufacturer declares that a battery meets the requirements of Regulation (EU) 2023/1542 and other applicable Union law, following the conformity assessment procedure in Chapter VI. The marking on the battery, including CE marking and labels, must match the declaration, the battery model, and the technical documentation. The declaration must identify the battery, the manufacturer, the legislation applied, the conformity assessment procedure, and, where a notified body was involved, the body and the relevant certificate. The record must hold the declaration version, the signature, and the date, and must retain the declaration and technical documentation for the period the Regulation requires. A marking without a matching declaration is an assertion without a signed basis.

The EU declaration of conformity means the document drawn up by the manufacturer under Chapter VI, declaring conformity of a battery model. The scope covers the battery model stated, including the conformity assessment procedure and the technical documentation behind the declaration.

What is the legal frame for this marking?

Marking and the declaration of conformity is a physical marking duty and a record duty at the same time. Articles 17, 18, and 38 gives the operative requirement, and Annex VI gives the content and the form. A manufacturer signing a declaration for a new industrial battery model should work from the current consolidated text and check whether an implementing act on harmonised label specifications has entered into force, since Article 13 sets some dates by reference to that act. A new model that changes capacity and chemistry should receive a new or revised declaration, a technical documentation review, and a marking check, before the first battery of the new model is placed on the market.

How are content, placement, and legibility checked?

Content asks whether every required element for marking and the declaration of conformity is present and correct for the battery category. The declaration, technical documentation index, and marking approval should include a photograph or a retained sample label, the artwork version, and the approval date, tied to the battery model. The declaration must be kept up to date where the battery is prepared for reuse, prepared for repurposing, remanufactured, or repurposed, since the technical documentation must be reviewed in those circumstances, and the record should state the review date.

How does category decide content?

Category decides content. For marking and the declaration of conformity, the record should state the category as defined in Article 3, list the label elements that apply to that category, and list the elements that do not apply, with the reason. A manufacturer signing a declaration for a new industrial battery model should be careful where a battery could fall into more than one description, and should record the reasoning for the category chosen. A new model that changes capacity and chemistry should receive a new or revised declaration, a technical documentation review, and a marking check, before the first battery of the new model is placed on the market.

How are measurement and wording recorded?

For marking and the declaration of conformity, a capacity value, a chemistry statement, or a duration value should name the test method, the conditions, and the unit, so the same battery tested again gives a comparable result. The declaration, technical documentation index, and marking approval should include the test report or the calculation sheet, the date, and the person or function that approved the value. The declaration must be kept up to date where the battery is prepared for reuse, prepared for repurposing, remanufactured, or repurposed, since the technical documentation must be reviewed in those circumstances, and the record should state the review date.

What sits behind the marking in the documentation?

For marking and the declaration of conformity, the declaration should identify the battery, the Regulation, and the conformity assessment procedure followed, and the technical documentation should support each marked claim. A manufacturer signing a declaration for a new industrial battery model should check that the declaration date, the battery model, and the marking version are consistent, and that a change to the battery that affects conformity leads to a review of the documentation. A new model that changes capacity and chemistry should receive a new or revised declaration, a technical documentation review, and a marking check, before the first battery of the new model is placed on the market.

How is a marking checked line by line?

For marking and the declaration of conformity, a checker should compare the physical marking, the QR code destination, the passport entry where a passport applies, the declaration of conformity, and the technical documentation, line by line, and record each comparison with a pass, a fail, or a query. The declaration, technical documentation index, and marking approval for the check should include the date, the sample identifier, and the version of each document compared. A manufacturer signing a declaration for a new industrial battery model should keep failed checks on file with the corrective action, the new artwork or record version, and the recheck date. The declaration must be kept up to date where the battery is prepared for reuse, prepared for repurposing, remanufactured, or repurposed, since the technical documentation must be reviewed in those circumstances, and the record should state the review date.

How is a declaration checked before signing?

Checking a declaration before signing means reading the declaration against the technical documentation index, line by line. The battery identity, the manufacturer, the legislation, the procedure, and any notified body details are compared with the documentation. A worked check sheet shows each declaration line, the supporting document, and the result, with the checker and date. A declaration that names a notified body that was not involved, or a procedure that was not followed, fails the check, even when the battery itself passes its tests. The declaration is signed only after every line passes, and the signed version is filed with the documentation version it relies on, so a later documentation change triggers a declaration review.

A declaration is a signed link between a battery and its evidence, and a marking that points to a different model or version breaks that link.