what do I need to arrange as an online shop if I stock batteries for sale myself

As a webshop with your own stock, you are usually a distributor

A webshop that purchases batteries, keeps them in its own stock and sells them directly to the customer is, in most cases, classified as a distributor under the Battery Regulation. This means that the obligations associated with manufacturing or importing the battery — such as drawing up the battery passport — have generally already been fulfilled by a party earlier in the supply chain, but the webshop itself also has a number of compliance tasks once it takes those batteries into stock and sells them in its own name.

For whom this applies, and where the boundary lies

This role applies to webshops that purchase batteries (or products with a built-in battery) from a manufacturer or importer and that themselves, in their own name and for their own account, sell to end-users — including the situation in which the stock is held in their own warehouse or with a fulfilment partner. This is explicitly not about the question of whether someone is a manufacturer: whoever manufactures batteries themselves or places them on the market under their own brand falls under a different set of obligations, which is more extensive. Uncertainty about this is not uncommon, and the difference between am I an importer or manufacturer under the Battery Regulation? and a distributor is precisely where many webshops encounter difficulties. Also, anyone who has batteries manufactured under their own label falls into a different category; this is covered in I sell batteries under my own brand — what obligations do I incur?. And sales via a third-party platform brings its own separate layer, described in what does the Battery Regulation mean if I sell via an online marketplace?.

The distributor role is therefore about reselling a battery that has already been placed on the market by someone else — the webshop does not add its own brand, its own manufacturing or its own import from a country outside the EU to it. As soon as any one of these three is the case, responsibility shifts towards the manufacturer or importer, with corresponding heavier obligations.

From 18 February 2027, a working passport is mandatory

The obligation to produce a digital battery passport applies from 18 February 2027. Until that date, there is no legal obligation to have a passport, but the compliance task of a distributor — to verify that the required documentation and markings are present — is independent of that date and is relevant as soon as a webshop takes batteries into stock and sells them. If someone now purchases stock from a manufacturer that has not yet arranged the passport, it is advisable to discuss this now, simply because stock that is sold after the effective date must comply with the requirements.

What this means in practice, step by step

As a first step, it is useful to establish whether the role is really that of a distributor, or whether there is actually a case of manufacturer, importer or brand owner — because this determines how much has to be arranged by oneself. If the role is distributor, the next step is to check whether the battery is provided with the required CE marking and the associated documentation before the battery is taken into stock and sold. What a valid marking and declaration exactly entail is described under which declaration of conformity and CE marking apply to a battery?.

After that, it is important to know who in the supply chain actually draws up and hosts the battery passport — this is usually the manufacturer or the importer, not the webshop itself, but the webshop has an interest in ensuring that this is done correctly, because a battery without a valid passport may not be sold after the effective date. Who exactly this is in a given supply chain is set out in who is responsible for the battery passport?. For batteries entering via a manufacturer outside the EU, there is often a separate party that performs this role; see for this my manufacturer is located outside the european union — who arranges the battery passport then? and, where relevant, when must I appoint a designated representative for batteries?.

A further step is to check whether registration as a producer is already required — this is linked to the role that is actually being performed, and is set out in must I register as a battery manufacturer, and where?. Finally, it is wise to clarify what happens during storage: who physically manages the inventory (own warehouse, fulfillment partner) can influence which obligations apply, and this also relates to the broader extended producer responsibility, explained in what does extended producer responsibility for batteries entail?.

Where this is derived from: Articles 38 to 44

The obligations of market participants, including distributors, are set out in Regulation (EU) 2023/1542, Articles 38 to 44. Specifically for distributors, fulfilment service providers and the question of when manufacturer obligations transfer to another party in the supply chain, Articles 42 to 44 of that same regulation apply. What exactly is meant by a distributor and how that role relates to other roles in the supply chain is explained in what obligations does a battery distributor have? and, more broadly, in what does the term market participant mean in battery legislation?.

Anyone who does not yet have a clear picture of their own role in the supply chain should clarify this first — the rest of the obligations follow from this fairly logically. For those who want to know what is concretely at stake if this is not in order, this is described in what happens if I do not have a battery passport?.

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

An online shop that purchases batteries, keeps them in stock and ships them itself is usually a distributor under the battery regulation. That is a separate role with its own obligations, separate from the manufacturer or importer from whom it purchased. The precise scope of that role is described on the page on what obligations does a battery distributor have; below are the aspects that specifically become problematic once own inventory is involved.

Check before the product goes into stock

Before batteries land in the own warehouse and are sold from the own website, there is a requirement to check that the required markings, documentation and labelling are present — think of CE marking, the name and details of the manufacturer, and the accompanying information. For a company with 10 to 100 employees, this in practice means a fixed inspection point when a new supplier or new article number arrives, not for every box that enters the warehouse. What exactly is checked depends on whether the purchased battery brand is also the company's own brand; see the page on for this selling under own brand.

Know who the manufacturer is and be able to identify them

A distributor is required to know where the battery comes from, so that if a supervisor or customer asks, it is clear who is accountable for what. This requires a supplier registration that is accurate: name, address and contact details of manufacturer or importer, per article number. With larger assortments with changing suppliers, this is one of the first things that goes wrong once purchasing runs through multiple channels (wholesale, directly from factory, occasional batches).

Do not distribute diverging information yourself

What appears on the own website, in newsletters or on product pages counts as information that the online shop itself provides. If that text differs from what the manufacturer has stated — a different capacity, a different warranty period, a different lifespan claim — this creates its own responsibility for that divergence. This happens more often than expected when marketing texts are written separately from the product documentation.

Retention period and availability of documentation

Documentation received during purchase (declarations of conformity, technical information, data for the passport) must remain available as long as the battery is sold and thereafter. For an online shop with its own inventory, this is an archival matter: not only store it, but also make it traceable per article number, even if a supplier no longer exists or no longer responds after a few years.

Appropriate storage and transport conditions

Once batteries are physically in stock and shipped from their own warehouse, storage and transport must not impair the product's properties. This is a practical obligation with consequences for warehouse design (temperature, fire safety, packaging) and for the choice of carriers when shipping to the customer.

Report when a battery does not meet the requirements

If it becomes apparent after receipt that a battery does not meet the requirements — or if there is reason to suspect this — the manufacturer or importer must be informed, and the battery must not be placed on the market until this has been rectified. For a webshop with its own inventory, this is an internal process: who within the company assesses a deviation, and who decides that a batch will not be sold.

Where things go wrong in practice

A webshop purchases a batch of batteries from a wholesaler within the EU without registering who the original manufacturer is. When asked about this, no one in the company can trace this information any longer.

A product page states a lifespan of "up to 1000 charging cycles", while the manufacturer specifies a lower figure in the accompanying documentation. The text was originally taken from a competitor by the marketing department and never fed back to the actual product information.

A batch of batteries is repackaged after one year in own warehouse under own sales name for the webshop, without having checked what this means for own obligations. This touches precisely the question answered on the page about selling under own brand.

A supplier outside the EU supplies directly to the warehouse of the webshop, without having established who acts as contact point within the EU. This is a different issue than distribution alone, and is addressed on the page about a manufacturer located outside the European Union.

A warehouse employee notices that part of a batch has arrived damaged, but the batch is still sold because there is no established procedure for such reports and nobody knows who this should be reported to.

What you can record

A supplier overview per article number: name, address and contact details of manufacturer or importer, including a file with received declarations of conformity and technical documentation.
A fixed control moment when accepting new articles in stock, with a checklist for CE marking, labelling and available documentation.
An internal agreement on who may write or amend product texts on the webshop, and on the basis of which source (always the manufacturer's documentation, never an assumption or competitor text).
A procedure for reporting and temporarily removing a batch from sale in case of doubt about conformity, including who within the company makes that decision.
Storage and shipping guidelines appropriate to the battery type, including agreements with the transport company used.
An overview of your own role per product line — distributor, or manufacturer due to your own brand — as a basis for the question who is responsible for the battery passport for each article in the assortment.

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.