(EU) 2023/1542 · Annex XIII(1)(r)
EU declaration of conformity for batteries: what belongs in it
This is the only field in Annex XIII that you issue yourself. Everything else you obtain from others. That is precisely why it is most often underestimated: signing the declaration means you take responsibility for the battery's compliance, not that you completed a form.
What the declaration actually attests
Article 18(1) is precise: the declaration states that compliance with the requirements in Articles 6 to 10 and Articles 12, 13 and 14 has been demonstrated. That covers substance restrictions, carbon footprint, recycled content, performance and durability, safety, labelling and state-of-health data. If you lack any of that evidence, you cannot honestly sign.
The format is not free-form
Article 18(2) requires the model structure in Annex IX and the elements specified in the relevant modules of Annex VIII. It must be translated into the language of the Member State where the battery is placed on the market, drawn up in electronic format, and provided on paper on request.
One document for several acts
Where several Union acts require a declaration of conformity for the battery, Article 18(3) requires a single declaration listing all those acts and their publication references. This is a common failure in practice: companies issue separate declarations and none of them lists every act.
It must be kept current
Article 18(2) explicitly requires the declaration to be kept up to date. A change of cell supplier, plant or chemistry means a fresh assessment, not simply a new date on the old document.
Where it goes wrong
- Signing before the evidence for Articles 6 to 10 has been collected — attesting to something that does not exist.
- Separate declarations per act instead of one that lists them all.
- No translation into the language of the Member State where the battery is sold.
- An old document with a new date after switching cell supplier.
Frequently asked
Who signs the EU declaration of conformity?
The manufacturer. Article 18(4) provides that by drawing up the declaration the manufacturer assumes responsibility for the battery's compliance. An importer placing the battery on the market under their own name acts as manufacturer.
Is a declaration from a third-country supplier enough?
Not by itself. The declaration must follow Annex IX and attest compliance with this Regulation. Supplier documents are inputs, not a substitute for your declaration.
Must the declaration be electronic?
Yes. Article 18(2) requires electronic format; paper is provided only on request.
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