EvidencePass

(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.

18 February 2027Place of manufacture (geographic location of plant)Legal basis: Annex XIII(1)(a) -> Annex VI, Part A(3)explanation in preparation
18 February 2027CapacityLegal basis: Annex XIII(1)(a) -> Annex VI, Part A(6)explanation in preparation
18 February 2027ChemistryLegal basis: Annex XIII(1)(a) -> Annex VI, Part A(7)Field explained 18 February 2027Hazardous substances present, other than mercury, cadmium or leadLegal basis: Annex XIII(1)(a) -> Annex VI, Part A(8)Field explained 18 February 2027Critical raw materials present in concentration above 0,1 % w/wLegal basis: Annex XIII(1)(a) -> Annex VI, Part A(10)Field explained
18 February 2027Material composition incl. chemistry, hazardous substances and critical raw materialsLegal basis: Annex XIII(1)(b)explanation in preparation
conditionalRecycled content informationLegal basis: Annex XIII(1)(e) · Article 8(1)The deadline depends on a delegated or implementing act, so no absolute date can be confirmed. Applies from 18 August 2028 or 24 months after the act enters into force — whichever is later.Field explained 18 February 2027Rated capacityLegal basis: Annex XIII(1)(g)Field explained
18 February 2027Minimal, nominal and maximum voltage, with temperature ranges where relevantLegal basis: Annex XIII(1)(h)explanation in preparation
18 February 2027Original power capability and limits, with temperature range where relevantLegal basis: Annex XIII(1)(i)explanation in preparation
18 February 2027Expected battery lifetime in cycles and reference test usedLegal basis: Annex XIII(1)(j)Field explained
18 February 2027Temperature range the battery can withstand when not in use (reference test)Legal basis: Annex XIII(1)(l)explanation in preparation
18 February 2027Initial round trip energy efficiency and at 50 % of cycle-lifeLegal basis: Annex XIII(1)(n)Field explained
18 February 2027Internal battery cell and pack resistanceLegal basis: Annex XIII(1)(o)explanation in preparation
18 February 2027C-rate of relevant cycle-life testLegal basis: Annex XIII(1)(p)explanation in preparation
18 February 2027Detailed composition incl. materials used in cathode, anode and electrolyteLegal basis: Annex XIII(2)(a)explanation in preparation
18 February 2027Part numbers for components and contact details of sources for replacement sparesLegal basis: Annex XIII(2)(b)explanation in preparation
18 February 2027Results of test reports proving compliance with this RegulationLegal basis: Annex XIII(3)explanation in preparation
18 August 2024Rated capacity and capacity fadeLegal basis: Annex XIII(4)(a) -> Annex IV, Part A(1) · Article 10(1)Already applies since 18 August 2024 — a retroactive gap for most obligated parties.Field explained 18 August 2024Power and power fadeLegal basis: Annex XIII(4)(a) -> Annex IV, Part A(2) · Article 10(1)Already applies since 18 August 2024 — a retroactive gap for most obligated parties.Field explained 18 August 2024Internal resistance and its increaseLegal basis: Annex XIII(4)(a) -> Annex IV, Part A(3) · Article 10(1)Already applies since 18 August 2024 — a retroactive gap for most obligated parties.Field explained 18 August 2024Energy round trip efficiency and its fade, where applicableLegal basis: Annex XIII(4)(a) -> Annex IV, Part A(4) · Article 10(1)Already applies since 18 August 2024 — a retroactive gap for most obligated parties.Field explained 18 August 2024Expected lifetime under reference conditions, in cycles and calendar yearsLegal basis: Annex XIII(4)(a) -> Annex IV, Part A(5) · Article 10(1)Already applies since 18 August 2024 — a retroactive gap for most obligated parties.Field explained

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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