do I also need to create a battery passport for batteries that I import from the United Kingdom

Yes, the United Kingdom counts as "outside the EU"

Batteries entering the EU from England (or Scotland, Wales, Northern Ireland under the applicable rules) are subject to the same rules as batteries imported from China, the US or any other country outside the EU. The origin United Kingdom changes nothing about the obligation: anyone placing an EV battery, a battery for a light means of transport or an industrial battery above 2 kWh from the UK on the EU market is the person who must have the digital battery passport drawn up and maintained. The UK has been a third country for the EU battery regulation since Brexit, and accordingly the same route applies to imports from that country as for imports from any other country outside the Union.

For whom this applies, and what does not change

This applies to any party placing batteries or devices with batteries from the UK on the EU market for the first time — typically the importer as defined in Article 3 of Regulation (EU) 2023/1542. It does not matter whether the battery was originally produced in the UK or whether the British supplier itself only resells from a third country; the party bringing the battery from the UK into the EU assumes the importer obligations. There is no transitional arrangement or exception specific to the UK to be found in the regulation: the text only knows the distinction between "manufacturer established in the Union" and parties supplying from outside the Union, and the UK falls into the latter category. What this does not affect: the status of batteries already located in the EU prior to movement, or batteries whose manufacturer is themselves established in an EU Member State and which happen to pass through a British intermediary — in the latter case the question may be more relevant whether someone is a manufacturer or importer then the question about origin from the UK in itself.

From 18 February 2027, without a separate UK exception

The obligation to provide a digital battery passport applies from 18 February 2027, as set out in Article 77 of Regulation (EU) 2023/1542. For imports from the UK, no separate entry into force or transition period can be found in the regulation — the date of 18 February 2027 applies in full, just as it does for any other battery placed on the EU market. Until that date, the obligations of market actors laid down in Articles 38 to 44 apply, such as CE marking, conformity documentation and the appointment of an authorised representative where necessary, but the passport itself is not yet required. Anyone currently importing batteries from the UK is therefore well advised to use this interim period to get their own position and data chain in order, rather than waiting until the deadline approaches.

What this means in practice for those importing from the UK

The first step is to establish which party in the chain fulfils the role of importer — often this is the party that physically brings the battery into the EU and places it on the market in its own name, but where goods are resold under a different brand the situation may shift, as can be read at who is responsible for the battery passport. The second step is to check whether the British supplier already provides data needed for the passport — chemical composition, origin of raw materials, performance and sustainability data — or whether that data must be collected separately, which due to the distance to a supplier outside the EU often requires more coordination than with an EU supplier. The third step is to assess whether an authorised representative is needed; this matters especially when the British party itself claims a role as manufacturer but has no establishment in the EU, a situation comparable to a manufacturer located outside the European Union and where it also explains when an authorised representative must be appointed in precisely. Only after that follows the actual compilation of the passport: gathering the data, having it hosted for the legally required period, and linking a QR data carrier to the product.

The legal basis: Articles 1, 3 and 38 to 44

That the UK falls under the import rules follows from Article 1 and Article 3 of Regulation (EU) 2023/1542, which sets out the scope and the definitions of manufacturer, importer and market participant — a definition based on establishment within or outside the Union, without distinction according to specific country. The obligations arising from this for those supplying from outside the EU are set out in Articles 38 to 44 on the obligations of market participants, supplemented by Article 40 on the obligations of an authorised representative when the party behind the battery is not itself established in the EU. The obligation for the digital product passport itself, with the date of 18 February 2027, is set out in Article 77.

Those importing batteries from the UK would be best advised to start by recording their own role in the supply chain and drawing up an inventory of which data the British supplier can already provide — this determines how much work remains before the obligation comes into effect on 18 February 2027.

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

The Battery Regulation does not look at the country from which a battery originates, but at the moment when that battery appears on the European market. The United Kingdom has been a third country since Brexit, just like, for example, China or the United States. This means that a battery entering the EU from England is, according to Article 3 of Regulation (EU) 2023/1542, placed on the market at the same moment as a battery coming from Shenzhen. There is no exception for British products, nor even for products that originally had EU certification before Brexit.

Establishing who the importer is

For goods from the UK, the person who first makes the battery available on the EU market is the importer within the meaning of Articles 38 to 44 of Regulation (EU) 2023/1542. This is usually the company that purchases the batteries from a British supplier and clears them through EU customs. Those in doubt as to whether this role applies to their own company will find the demarcation between roles in Am I an importer or manufacturer according to the battery regulation?. For companies with 10 to 100 employees, this is usually not an abstract question: someone in the company handles customs clearance, and that factual action is precisely the moment when an importer's obligations arise.

Checking whether there is already a responsible party in the EU

Some British manufacturers have set up their own EU establishment since Brexit, or work with an authorised representative within the Union. If this is the case, that party may already bear responsibilities that would otherwise fall to the importer. This is something to ask the supplier about, not something to assume. When such representation is absent, the question becomes relevant as to whether and when an authorised representative is needed — this is addressed in When must I appoint an authorised representative for batteries?.

Having the battery product passport compiled based on factory data

Even if the factory is in the UK, the product passport must be in place before the battery comes onto the EU market. The data required for this — technical specifications, composition, origin of materials — come from the British manufacturer, regardless of the fact that they are not themselves subject to the EU regulation. For a company of 10 to 100 employees, this often means that additional correspondence is required to obtain this data, because a British producer is not familiar with the EU product passport format as a matter of course. Those wondering who actually performs this task will find a more detailed explanation in Who is responsible for the battery passport?.

Assessing whether the role changes in the case of own brand or resale

Those purchasing British batteries and selling them under their own brand name may thereby acquire the obligations of a manufacturer instead of (or in addition to) those of an importer. This is a separate consideration, separate from the fact that the battery comes from the UK. This situation is described in I sell batteries under my own brand — what obligations do I get?.

Where things go wrong in practice

A recurring issue is the idea that "European quality" or a CE marking already on the British product means that the battery regulation has been complied with. CE marking relates to other legislation and is not a substitute for the digital product passport; see also What conformity declaration and CE marking go with a battery?.

A second situation: companies that have sourced from the same British supplier for years sometimes assume that an existing commercial relationship provides an exemption. The regulation does not contain a transitional rule specifically tailored to the UK; the date on which the battery is placed on the market in the EU is decisive, not the duration of the commercial relationship.

A third pitfall arises with batteries that enter through a Dutch or German intermediary. The company that ultimately resells the battery to the end user then assumes that the intermediary has already handled the passport obligation, without verifying this. The role of intermediaries that resell goods without importing them themselves is described in What obligations does a distributor of batteries have? — that role is not automatically free from responsibility.

A fourth situation occurs when selling via an online shop or marketplace that offers the British product directly to EU consumers. In this case too, the question of who first assumes responsibility in the EU is relevant, and this is explained in What does the battery regulation mean if I sell via an online marketplace?.

A fifth and final recurring point: the idea that a British manufacturer can themselves carry out an EU registration as if that party is established in the EU. Registration obligations are linked to an establishment in the EU or an authorised representative there; anyone wondering how that registration works exactly will find that in Must I register as a battery producer, and where?.

What you can record

Battery source documentation: purchase order, customs papers and the name of the British manufacturer or supplier, so that it can be reconstructed afterwards when and by whom the battery was placed on the EU market.
Correspondence on technical data: emails or documents in which the British manufacturer has provided the composition, origin of raw materials and other data for the passport.
Overview of own role: a short note or internal document in which it is recorded whether the company acts as an importer, as a party selling under its own brand, or as a distributor — with the supporting evidence for this.
Confirmation of any authorised representative: written confirmation from the British supplier as to whether an authorised representative in the EU has already been appointed, and if not, who will perform this role.
Proof of CE marking and conformity, kept separate from the digital product passport, so that the impression does not arise that one replaces the other.

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 2026-09-05. Is something incorrect? Let us know — corrections take priority.