The short answer
The economic operator that places the battery on the EU market answers for the battery passport: it has to keep the information accurate, complete and up to date, and may authorise another operator in writing to act for it. When a Chinese manufacturer is not established in the EU, the company that places the battery on the EU market is usually an EU importer, and the manufacturer can prepare the passport first. If you are unsure who carries the responsibility, ask a professional.
What the regulation says
Who answers for the content
“The economic operator placing the battery on the market shall ensure that the information in the battery passport is accurate, complete and up to date. It may give written authorisation to any other operator to act on its behalf.”
What an importer is
“‘importer’ means any natural or legal person established within the Union who places on the market a battery from a third country;”
Who stores the passport data
“the data included in the battery passport shall be stored by the economic operator responsible for the fulfilment of the obligations under Article 77(4) or (7), or by operators authorised to act on their behalf;”
Hosts may not use the data for anything else
“if the data included in the battery passport are stored or otherwise processed by operators authorised to act on behalf of the economic operator responsible for the fulfilment of the obligations under Article 77(4) or (7), those operators shall not be allowed to sell, re-use or process such data, in whole or in part, beyond what is necessary for the provision of the relevant storing or processing services;”
Quotes are from the English text of the regulations; the text published in the Official Journal prevails.
The roles and the passport
| Role | How the regulation defines it | Relation to the battery passport |
|---|---|---|
| Economic operator | The manufacturer, authorised representative, importer, distributor and anyone else with duties for making, placing on the market or putting batteries into service (Art. 3(1)(22)) | The umbrella term. The passport duty falls on the one that places the battery on the market (Art. 77(4)) |
| Manufacturer | Whoever makes a battery, or has one designed or made, and markets it under its own name or trademark or uses it itself (Art. 3(1)(33)) | Provides the battery's data and documents; if it places the battery on the EU market itself, it answers for the passport |
| Importer | A person established in the Union who places a battery from a third country on the market (Art. 3(1)(64)) | When a battery is imported from China and placed on the market, the importer is the economic operator that answers for the passport content. EU importers and authorised representatives |
| Authorised representative | A person established in the Union with a written mandate from the manufacturer to act for it on specified tasks (Art. 3(1)(63)) | Does what the written mandate says (Art. 40); whether that includes the battery passport depends on how the mandate is written |
| A company storing the data for you | An operator authorised by the economic operator to store or process the passport data | May not sell, re-use or process the data beyond what the storing or processing service needs (Art. 78(d)) |
The passport must stay available for the whole life of the battery: also after the economic operator responsible has ceased to exist or has stopped its activity in the Union (Art. 78(e)).
Common mistakes
I am a Chinese factory. Does my EU importer not need to care about the passport?
It does. The economic operator that places the battery on the EU market answers for the content of the passport. The factory can prepare the passport first and hand it to the importer.
If a service provider hosts the passport, can it use my data?
No. A company that stores or processes the data on your behalf may not sell, re-use or process it beyond what the service needs (Art. 78(d)).
If I authorise someone to act for me, am I no longer responsible?
The regulation lets you authorise another operator in writing, but the final responsibility for the passport content stays with the economic operator. Ask a professional how to word the authorisation.
Update dates and checks
- First published
- Last updated
- Checked against
- Regulation (EU) 2023/1542 (Battery Regulation), consolidated text; Commission battery passport FAQ (completed September 2026, 1st edition, not law)
- Checked
- Checked 2026-11-07 · by PassBridge
This guide is for reference and is not legal advice. When the rules change we update it and say so here.
