The battery is built into my product — who creates the passport then?

The market operator placing the battery on the EU market is in charge

Who compiles the passport does not depend on where the battery is physically located, but on who places the battery — loose or built-in — on the European market for the first time. In the case of an e-bike, scooter or machine with a fixed battery, this is in practice usually the party that imports the end product or sells it under its own name. The Battery Regulation assigns different roles to "market operators": manufacturer, importer, authorised representative and distributor. Which obligations belong to which role is set out in Articles 38 to 44 of Regulation (EU) 2023/1542. A built-in battery does not change the fact that someone in the chain is responsible for these obligations — it only makes it less obvious who that is, because the battery itself is not traded separately.

For which batteries this applies, and for which it does not

This subject is relevant for batteries that fall within the scope of the passport: EV batteries, batteries for light transport vehicles (LTV, such as e-bikes and scooters) and industrial batteries above 2 kWh. If such a battery is permanently built into a product, the battery itself remains the object on which the obligation rests — not the product around it. This means that an importer of, for example, e-bikes with batteries will have to deal with battery obligations, even if formally he imports "bicycles" and not "batteries". It does not apply to batteries that fall outside the weight or capacity limits, and not to components that are not batteries but look like them (such as a loose power adapter). If there is any doubt about whether a specific battery falls within the scope, the text of Article 77 and the description of the product categories in the Regulation shall be the starting point.

Mandatory from 18 February 2027, until then preparation is all that counts

The obligation for a digital battery passport becomes effective from 18 February 2027, as laid down in Article 77 of Regulation (EU) 2023/1542. Until that date, there is no legal obligation to show the passport to a customer or supervisory authority, but the data that must go into it — origin, composition, performance, repair and recycling information — usually already comes into being during the production and import of the battery. Those who wait until 2027 to collect this data run the risk that crucial information (such as the exact cell chemistry or test results from the manufacturer) may then no longer be easily traceable, especially if the battery supplier has changed in the meantime or is no longer available.

How this is handled in practice

For an importer of a product with a built-in battery, this begins with determining their own role: does the company place the product on the market under its own brand, or does it trade a product that has already been registered elsewhere? Whoever introduces a product under its own name or brand in the EU thereby typically acts as the market operator on whom the obligations of Articles 38 to 44 rest, even if the battery itself has been manufactured by another party. The next step is to request the underlying battery data from the manufacturer or supplier of the cell or battery pack: chemical composition, capacity, origin of raw materials, CO2 footprint where applicable, and information on dismantling and recycling. Without this data from the original battery manufacturer, a passport is not complete, so this should be arranged early in the procurement process, not just before the mandatory date. Subsequently, it is determined who actually compiles and hosts the passport — this can be the importer itself, or a platform that takes on this task on the basis of the data provided. Finally, the passport includes a physical QR data carrier on the battery or product, so that the data can be consulted even after sale.

Where this follows from: Articles 38-44 and Article 77

This division of responsibility follows from Articles 38 to 44 of Regulation (EU) 2023/1542, which establish the obligations of manufacturers, importers, authorised representatives and distributors. Article 77 of the same regulation specifically governs the battery passport: what information it must contain and from when it is mandatory. Together, these articles determine that the obligation is linked to a role in the supply chain, and not to the physical location of the battery within a product.

Anyone importing a product with a built-in battery or selling it under their own brand should check now which battery data are available from their own supplier, and which are missing. Batpas.eu converts this data into a passport and hosts it for ten years, including the QR data carrier — but the first step, collecting the correct data from the battery manufacturer, is the responsibility of whoever places the product on the market.

What this is based on

The Regulation itself is on EUR-Lex. We refer for each statement; you need not believe us.

What you need to do concretely

What is expected of you

A battery built into an e-bike, a scooter or a machine remains fundamentally a battery as intended by the Battery Regulation. The obligation to have a digital product passport drawn up does not change by virtue of the fact that the battery is not sold separately. What does change is the question of who in practice bears primary responsibility first: this is not automatically the manufacturer of the bicycle or machine, and nor is it automatically the cell or pack supplier. The Regulation establishes this through the roles of economic operators in Articles 38 to 44 of Regulation (EU) 2023/1542.

Determining who is the "manufacturer" of the battery

The Regulation confers the role of manufacturer on the party that produces the battery, or that places a battery on the market under its own name or brand — even if that battery is composed of components from another party. For a company of 10 to 100 employees that imports or assembles e-bikes or scooters, this means in practice: if the final product is sold under its own brand name and the battery pack in it is a fixed, non-replaceable component, the role of manufacturer of that battery often falls with the same importer or assembler — not with the factory abroad that only supplies the cells. Who exactly is responsible here depends on the contractual and factual situation; see also does the battery passport apply to my batteries? for the steps to work through that for a specific product.

Establishing whether the battery itself falls under the Regulation

Not every built-in battery needs to receive a digital product passport — that depends on the type of battery and its capacity. An LMT battery in an e-bike or scooter falls under a different category than an industrial battery above 2 kWh in a machine, and the obligations do not take effect on the same date for each category. In practical terms, this means that a company first establishes which category its own product falls into, before the passport process is set up. More information on this is available at which batteries fall under the battery regulation?, at what is a light electric vehicle battery (LMT battery)? and at what does the 2 kWh threshold mean for industrial batteries?.

Collecting data from the battery supplier

Whoever fulfils the role of manufacturer is not necessarily the party that already has all the technical data in-house. An importer of e-bikes typically purchases a complete battery pack from a supplier in Asia or elsewhere in the EU, without that supplier routinely providing data on material origin, chemistry or performance. For a mid-sized company, this means that agreements are needed with the sub-supplier on which data are to be provided, in what form and with what update frequency — this is typically the most time-consuming part of the process, rather than the technical assembly of the passport itself.

Having the passport drawn up and linked to the product

Once the role of manufacturer has been established and the data are in hand, the digital product passport is drawn up and linked to a QR code that is affixed to or placed with the battery. In the case of a built-in battery, the question arises where that QR code practically finds a place — on the battery itself it is not always accessible without opening the product, on the casing of the end product is then often the more practical option. Article 77 of Regulation (EU) 2023/1542 (Battery Regulation), Article 77 sets out the obligation for the digital product passport and the data carrier, without prescribing how a manufacturer organises this operationally within its own assembly process.

Where things go wrong in practice

An importer assumes that the Asian cell manufacturer will take care of the passport, because after all that party "makes" the battery — while the Regulation links the role of manufacturer to whoever places the brand on the market, not to whoever physically produces it.

A machinery manufacturer incorporates an industrial battery from an external supplier into its machine, and only discovers late that this battery is above the 2 kWh threshold, while the rest of the machine does not fall under the Regulation — with the result that the passport process is started after the first machines have already been delivered.

An e-bike brand works with multiple battery suppliers for different models and treats the product passport as a one-off project rather than a recurring process per supplier and per model change — so when switching to a new supplier, the data request starts from scratch every time.

A company assumes that because the battery is "permanently built in and non-replaceable", no separate product passport is needed — an assumption that does not hold as a rule, because replaceability of the battery is not the criterion that the regulation uses to determine when a product passport is required.

An importer switches battery suppliers without updating the product passport, even though the underlying data (cell chemistry, origin, capacity) has changed.

What you can record

An overview per product line of which battery is included, from which supplier, and under which category (LMT, industrial, portable) that battery falls according to the company's own assessment.
A documented agreement with each battery supplier on which data are to be supplied, in what format, and who is responsible for updating that data if the product changes.
An internal designation of who within the company fulfils the role of battery manufacturer for each product — this may differ per product line if multiple brands or OEM designs are used.
A log of model changes and supplier switches, so that it is traceable which product passport corresponds to which product version.
If in doubt about your own role or the applicable category: the first steps as described in does the battery passport apply to my batteries?, and for the broader context what is changing with the new battery regulation?.

This is not legal advice. This page provides general information about the legislation that this platform covers. We do not know your situation. If in doubt about your own case, consult a lawyer or the competent supervisory authority.

Written with AI based on the sources above, checked by a human on 2026-08-22. Is something wrong? Let us know — corrections take priority.