(EU) 2023/1542
Battery importer: what to demand from your supplier before you sign
An importer carries the manufacturer's obligations while somebody else holds the data — often on another continent and with no legal interest in handing it over. The only moment you hold negotiating power is before the supply contract is signed. After that, every request depends on goodwill, and experience shows goodwill runs out exactly where disclosure means revealing how the product is built.
Why you are legally in the manufacturer's role
Whoever places a battery on the market under their own name or brand assumes the manufacturer's obligations. That includes drawing up the EU declaration of conformity, by which you assume responsibility for compliance, and keeping technical documentation for ten years. Pointing at your supplier does not relieve you of that.
Three classes of evidence, and who holds them
The first class you issue yourself — the declaration of conformity, markings. The second you obtain by measurement at a laboratory and can order later, if at greater cost. The third exists only with the manufacturer and is created in development: exploded diagrams, disassembly sequences, detailed composition, plant-level carbon footprint. The third class is in practice unobtainable after the fact.
Fields whose evidence sits with the supplier
Computed from the rule set. These are the items that belong in the contract, not in a letter sent after delivery.
What the contract must actually contain
Listing documents is not enough. The contract should set the format and level of detail, the language, the delivery deadline, a duty to update when the material source or plant changes, and a consequence for non-delivery. Without the last, the clause is a wish rather than an obligation. For data that is annual by nature — recycled content is one — the contract must require annual reporting, not a single handover.
What a contract cannot solve
Some requirements cannot be obtained contractually because they are not documents. State-of-health data must sit in the battery management system, and access to it must be non-discriminatory, including for independent operators. Use logging must exist in the product. A supplier cannot email that — it has to be built in before the battery goes into production.
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The free check runs through every mandatory field for your battery category.
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