The European battery regulation is written for battery makers, and that is why so many exporters assume it is not about them. It is. If your product contains a cell — rechargeable or not, removable or not — you are placing a battery on the European market, with everything that follows.
The part that catches people: registration is national
Battery producer responsibility works country by country. A producer not established in a member state must appoint an authorised representative there. Sell into five countries and you have five registrations and five representatives. This is the obligation that stops shipments, because a distributor who cannot show your registration number will not take the stock.
What an importer owes, specifically
- Verify that the conformity assessment was carried out and that the declaration of conformity exists — not assume it.
- Check the marking, and add their own name and address.
- Keep the documentation for ten years.
- Not place a non-conforming product on the market, which includes withdrawing one already sold.
If your European partner is the importer, these are their duties and they will price the risk into the relationship. If you sell under your own brand through a subsidiary, they are yours.
What has moved, and why it matters
Several pieces of this regulation have been pushed back. The supply chain due diligence duty and the battery passport both moved to later dates, and the carbon footprint declaration is effectively suspended while the technical texts are written. Labelling requirements are tied to an implementing act rather than to a date alone.
The practical lesson is not “relax”. It is that anyone quoting you a firm deadline for this regulation is quoting something that has already moved at least once. Verify against the current text before you commit money to a compliance project.
The due diligence duty only reaches operators above a defined turnover threshold, on a short list of raw materials. Most exporters are below it — but their European customers may not be, and will pass the questions down to them anyway.
Where to read it yourself
Official pages, opened and checked on 26 September 2026. Where a rule changes, these are the addresses that change with it — this article does not.