EU Battery Importer Obligations: What Importers Must Do Before February 2027

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If you import batteries into the European Union, the battery passport deadline is your deadline, not just your supplier's. From 18 February 2027, under Article 77 of Regulation (EU) 2023/1542, EV batteries, light means of transport (LMT) batteries and industrial batteries above 2 kWh must not be placed on the EU market without a battery passport. The economic operator placing the battery on the market carries the responsibility — and for batteries manufactured outside the EU, that is the importer.

This guide covers what an importer specifically has to verify and do before February 2027, particularly when sourcing from non-EU manufacturers.

Why the date of import matters more than the date of manufacture

The obligation attaches when a battery is placed on the EU market. A battery manufactured in late 2026 but imported and placed on the market after 18 February 2027 needs a passport. You cannot rely on production dates to escape the requirement, and stock sitting in a non-EU warehouse does not become compliant by aging. Plan your purchasing and logistics around the placing-on-the-market date.

Note the scope carefully: the passport applies to EV, LMT and industrial batteries above 2 kWh — not portable consumer batteries. If your range spans both, only part of it triggers the passport obligation, though other parts of the regulation (such as labelling and collection provisions) still apply across categories.

Obligation 1: Verify the manufacturer has a compliant battery passport

Your first question to any non-EU battery supplier should now be: show me the passport. Before you commit to volumes for 2027 delivery, verify that the manufacturer either has a battery passport in place or has a credible, dated plan to produce one. Concretely, that means checking that:

• A passport record exists for the specific model you are buying, covering the data categories in Annex XIII — identity, compliance documentation, carbon footprint, due diligence, materials and composition, circularity information, and performance data (our battery passport requirements guide breaks these down);
• The record is in a form that will remain accessible for the battery's lifetime — a PDF on a supplier's marketing site does not meet that description;
• Someone is accountable for keeping dynamic data, such as state of health parameters, updatable after sale.

If the manufacturer cannot or will not produce a passport, the responsibility does not evaporate — it lands on whoever places the battery on the EU market. Some importers will respond by creating and hosting the passport themselves from supplier-provided data. That is a legitimate strategy, but it means you need the underlying data contractually guaranteed from the manufacturer.

Obligation 2: Check the QR code and data carrier

The passport is accessed through a QR code on the battery that links to the passport record. As an importer you should physically verify, on samples from each supplier and model:

• The QR code is present on the battery;
• It scans reliably and resolves to the correct passport for that model;
• The linked record actually loads, in a form usable by an EU customer or authority.

Build this into your inbound quality inspection alongside your existing checks. A missing or dead QR code is the kind of defect that is trivial to spot at goods-in and very expensive to discover at a market surveillance inspection.

Obligation 3: Conformity documentation

Batteries under the regulation follow the familiar CE-style conformity logic: the manufacturer draws up technical documentation and an EU declaration of conformity, and the battery carries the required markings. As the importer, your job is the classic importer's role in EU product law: verify that the manufacturer has carried out the conformity assessment, that the declaration of conformity exists and matches the product, that the battery bears the required markings and identifiers, and that you can produce the documentation when an authority asks for it. Keep copies; do not rely on a supplier in another jurisdiction to answer an EU authority's deadline for you.

Obligation 4: Supply-chain due diligence

The regulation requires battery due diligence aligned with the OECD Due Diligence Guidance for four raw materials: cobalt, natural graphite, lithium and nickel. Economic operators placing batteries on the EU market are within the due diligence chapter's reach, subject to the thresholds and exemptions set out in the regulation, so check where your business falls rather than assuming due diligence is purely the manufacturer's problem.

Practically, an importer's due diligence position depends on supplier transparency. If your manufacturer cannot tell you where its cobalt, graphite, lithium and nickel come from, that is a red flag for the due diligence obligations and for the passport's due diligence content alike.

What happens at customs and market surveillance

Compliance is checked at two points. At the border, customs and market surveillance cooperation can stop non-compliant products entering the EU. On the market, market surveillance authorities can request documentation, test products and order corrective action — which can extend to withdrawal or recall of non-compliant batteries. Given the unit value of EV and industrial batteries, a refused consignment or forced withdrawal is a serious financial event, not an administrative nuisance.

Be clear, too, about which role you actually occupy. If you buy from an EU-established manufacturer or another EU importer, you may be acting as a distributor, with lighter verification duties; if you bring the battery in from a third country yourself, you are the importer and the obligations above are yours. Fulfilment models, white-labelling and rebranding can shift these roles in ways that surprise businesses — a company that puts its own name on an imported battery can find itself treated as the manufacturer. Map your actual supply arrangements against the regulation's economic operator definitions before assuming someone else carries the responsibility.

Remember also that the battery passport lands amid a wider set of obligations phasing in under the regulation — carbon footprint declarations for EV batteries (target date 18 February 2025) and rechargeable industrial batteries (18 February 2026) start 12 months after the Commission adopts the calculation delegated act, still outstanding in September 2026, and collection and recycled content targets ramp up over the coming decade. Our summary of the 2027 Battery Regulation changes puts the passport in that fuller context.

The importer's pre-2027 checklist

• Map your range against the scope: EV, LMT and industrial >2 kWh batteries need passports from 18 February 2027.
• Write the passport into contracts: require suppliers to provide a compliant passport, or the full Annex XIII data set so you can host one.
• Sample-check QR codes at goods-in: present, scannable, resolving to the right record.
• Collect conformity files: declaration of conformity, technical documentation references, markings.
• Confirm due diligence coverage for cobalt, natural graphite, lithium and nickel, and your own position under the due diligence chapter.
• Decide who hosts the passport and how it stays accessible for the battery's lifetime — including if you change supplier later.
• Run a dry run before February 2027: take one real shipment through every check above and fix what breaks.

Frequently Asked Questions

My batteries are manufactured outside the EU. Whose job is the battery passport?

The obligation attaches to placing the battery on the EU market. If a non-EU manufacturer will not provide a compliant passport, the importer placing the battery on the market must ensure one exists — which is why the data should be secured contractually from the supplier.

Do batteries manufactured before 18 February 2027 need a passport?

What matters is when the battery is placed on the EU market. A battery imported and placed on the market after 18 February 2027 needs a passport regardless of when it was manufactured.

Do portable consumer batteries need a passport?

No. The passport requirement covers EV batteries, LMT batteries and industrial batteries above 2 kWh. Other parts of the Battery Regulation still apply to portable batteries, including collection targets of 63% by the end of 2027 and 73% by the end of 2030.

A note on sources: obligations summarised here follow Regulation (EU) 2023/1542, in particular Article 77 and the conformity and due diligence chapters; detailed procedures and formats are for the implementing acts, and specific cases should be checked against the consolidated text. This article is general guidance, not legal advice.

If your supplier can give you the data but not the passport, create one free on MyProductPassport and host it yourself, with the QR generated for you.