What do I do if the same battery comes from different suppliers?
Different manufacturers, different digital product passports
If the same battery — same type, same specifications, same appearance — arrives via multiple suppliers, the first question is not what the battery looks like but who made it. If the battery comes from the same manufacturer and it is truly the same model, then one and the same digital product passport data can apply to those batteries, regardless of which intermediary they were purchased through. However, if the 'identical' battery comes from different manufacturers — which is common in the e-bike and scooter market with generic cells and look-alike packs — then in practice these are different products. Each of them requires its own digital product passport, even if the difference is not visible to the naked eye. The digital product passport is namely linked to the battery model and the manufacturer behind it, not to how a battery looks or performs.
For whom this matters and for what it does not
This issue arises especially for importers and battery traders who purchase the same article from multiple factories or intermediaries to ensure supply security — a common practice for e-bike and scooter batteries and for industrial batteries above 2 kWh. It does not apply when one manufacturer supplies via different distributors or wholesalers to the same customer: that is the same battery via a different route, and that does not change the digital product passport itself. So it is about the distinction between 'different supplier, same manufacturer' (usually not a problem) and 'different supplier, different manufacturer' (worth paying attention to). For batteries that do not fall under the regulation — for example industrial batteries below the 2 kWh threshold — this question does not arise anyway, because there is no digital product passport obligation for those.
Mandatory from 18 February 2027
The digital product passport obligation itself will come into force from 18 February 2027, as laid down in Article 77 of Regulation (EU) 2023/1542. Until that date, there is no legal obligation to maintain a digital product passport for these batteries, and therefore no urgent need to determine per delivery whether the digital product passport from supplier A and supplier B should be the same. What is relevant now: the administration needed to later demonstrate the correct manufacturer, specifications and origin per battery (model) is built up from today's purchasing practice. Anyone who already keeps track of which supplier is responsible for which batch will not have to reconstruct that retrospectively in a few years' time.
How to approach this per delivery
The practical sequence starts with establishing the manufacturer behind each delivery, not with the appearance or specifications of the battery. A first step is to ask each supplier who the actual manufacturer is and whether it is exactly the same battery model as with the other supplier — a declaration or technical documentation from the supplier is the starting point for this. A second step is to look at the specific identification number or batch number of the battery: the regulation and digital product passport work with a unique identification code per model or per battery, and that code reveals whether it is the same source. A third step is, once that is established, to determine whether the incoming batteries can fall under one digital product passport (same manufacturer, same model) or whether a separate digital product passport must be compiled per manufacturer. A fourth step is to record this in your own purchasing administration, so that on the next delivery of the 'same' battery it is immediately clear whether it is a known or a new source. Anyone who keeps track of this per supplier instead of per article number prevents batteries from different manufacturers from being incorrectly assigned to one digital product passport.
Where this is set out: Articles 38 to 44, and 77
That each market participant — manufacturer, importer, distributor — has its own role and own responsibility in the chain, follows from Articles 38 to 44 of Regulation (EU) 2023/1542. It follows from this that anyone placing a battery on the market or trading in it must be able to verify whether the associated documentation belongs to the correct manufacturer and the correct model. That the product passport itself is linked to the battery model and the associated data is set out in Article 77 of the same regulation. From the combination of these provisions it follows that a product passport cannot simply be "reused" for a battery from a different manufacturer, even if that battery looks identical.
What to do now
Anyone purchasing batteries from multiple suppliers that resemble each other is well advised to document now, for each delivery, who the manufacturer is and whether it is the same model — this is the basis on which, upon the start of the product passport obligation on 18 February 2027, the correct product passport can be compiled for each battery. Batpas.eu compiles that product passport on the basis of data supplied by the manufacturer or importer; the sooner it is clear which supplier belongs to which batch, the less investigation work it will cost later.
What this is based on
- Regulation (EU) 2023/1542, Articles 38 to 44 (obligations of economic operators)
- Regulation (EU) 2023/1542, Article 77 (battery passport)
The Regulation itself is on EUR-Lex. We refer for each statement; you need not believe us.
What you need to do concretely
It happens more often than not: the same battery, identifiable by the same model number and the same specifications, is offered by two or three different suppliers. Sometimes via a distributor in Europe, sometimes directly from the factory, and sometimes via an intermediary that itself sources from somewhere else. For the purchase price, this often makes little difference. For the battery passport, it makes quite a difference, because the data associated with that battery can differ per supplier — even if the physical product is identical.
What is expected of you
Determining which economic operator is subject to the regulation
The obligations set out in Articles 38 to 44 of Regulation (EU) 2023/1542 (battery regulation) are linked to a role: manufacturer, importer or distributor. With one battery from multiple suppliers, the first question is not what data there is, but who in that chain fulfils the role that must supply the data. For a company with 10 to 100 employees, this means in practice that each supplier of the same battery is assessed separately on its role, even if the product appears identical. Two suppliers of the 'same' battery may have different obligations, simply because one manufactures directly and the other imports from a third country.
Assess data per supplier separately
A battery that enters through multiple channels carries the risk that the technical data looks slightly different per supplier: a different cell supplier, a slightly different batch composition, or data that is simply incomplete. For the passport, what counts is not the model number on the box, but the actual composition and origin of the battery being sold. Which data belongs with it is described on the page about what data must I request from my battery supplier. That overview is useful as a checklist per supplier, even when it is apparently the same product.
Demonstrate the origin of the batch
When a battery with the same specifications comes from two channels, the distinguishing factor is not the product sheet but the batch: which supplier delivered which shipment, and which passport data belongs to which shipment. For a company that works with inventory, this means that the link between purchase order, supplier and passport must remain traceable at batch level. Without that connection, there is a risk that a passport is linked to the wrong batch — with data that does not belong to the physical product.
Substantiate due diligence in the chain per supplier
The due diligence obligation that follows from the battery regulation is not optional, and applies in principle to every chain through which the battery enters. What this entails is explained on the page about the due diligence obligation for batteries. With multiple suppliers of the same battery, the consequence is that this substantiation is not drawn up once, but per supplier — even if the final conclusion is the same for both suppliers.
Where things go wrong in practice
A first situation that often recurs: an importer orders the same e-bike battery from two suppliers, and assumes that one passport is sufficient for both because it is the 'same item' in its own assortment. On closer examination, the passport data turns out to differ from each other, for example in cell supplier, because the two suppliers themselves also source from different factories.
A second situation: when switching suppliers — for example due to price negotiations or delivery problems — the new supplier is not asked for the same complete set of data as the previous one. The passport is then supplemented with old data that no longer belongs to the new batch.
A third situation arises with batteries that enter via an intermediary who is not the manufacturer himself. The intermediary indicates that they supply "the same product" as the direct manufacturer, but cannot themselves demonstrate which factory they purchased from. Here the subject directly touches on the question of how you obtain the correct data when the factory is not located in Europe, as described on the page about how do I get the correct passport data from a manufacturer in China.
A fourth situation: with two suppliers of the same battery, only one of the two is checked to verify whether the supplied data is correct, because the other supplier is considered "trusted". This distinction is not relevant for the passport — the source of trust does not determine whether data is factually correct.
A fifth situation occurs with repair or conversion: a battery pack is restored with cells from a different supplier, while the existing passport remains unchanged. What this means for the passport is explained on the page about do I need to update the passport if I repair or modify a battery.
What you can record
For a company that procures the same battery from multiple suppliers, it is practical to maintain a separate, traceable file per supplier rather than one shared file per product model. What should definitely have a place in it:
- A supplier overview per battery model, in which for each supplier it is documented which factory or cell supplier is actually used, even if the end product bears the same model name.
- Purchase contracts in which the supply of passport data is included as a condition, per supplier separately. What such an agreement might look like is described on the page about how do I record the supply of passport data in my purchase contract.
- A control step upon receipt of data, whereby for each delivery it is checked whether the supplied data corresponds to the physical product. A procedure for this is described on the page about how do I verify whether my supplier's data is correct.
- A fixed format in which each supplier submits data, so that data from different suppliers remain mutually comparable. See the explanation about in what format must I submit the battery data for the passport.
- A fixed procedure for the case where a supplier does not supply, is late or incompletely supplies data, so that this is not investigated anew in each case. See the page my supplier does not supply the data — what can I do.
With this documentation, it remains traceable per battery via which supplier, which factory and which data a specific unit was actually placed on the market — even when the assortment on paper has one item number, but in reality consists of multiple chains.
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.