What does a supervisory authority ask for during a battery inspection?
Documents, technical data and sometimes a physical inspection
During an inspection, a supervisory authority first requests the documents that demonstrate that a battery complies with the requirements of the Battery Regulation: the EU declaration of conformity, the technical file, data on the manufacturer or importer, and — for batteries where applicable — the digital product passport with the corresponding QR code. Regulation (EU) 2019/1020 empowers the supervisory authority to request this documentation from the manufacturer, importer or distributor, and to request additional information if the initial set of documents does not provide a complete picture. In addition to document inspection, a supervisory authority may also carry out physical inspection: request a battery, or a sample thereof, inspect it or have it tested in a laboratory to verify that practice matches what is documented. Which of these steps occur depends on the type of battery, the risk assessed by the supervisory authority and the reason why an inspection was initiated — a routine inspection proceeds differently from an inspection following a complaint or incident.
Who this applies to, and who it does not
These powers apply to economic operators in the battery supply chain: manufacturers, importers, authorised representatives and distributors, as indicated by the Battery Regulation. An importer of e-bikes or scooters who places batteries on the EU market falls under this, as does a battery trader who purchases and resells batteries. In practice, a supervisory authority often first addresses the party responsible for placing the battery on the market — usually the manufacturer or importer — but Regulation (EU) 2019/1020 also makes it possible to address distributors, for example if the manufacturer is established outside the EU and is not directly accessible. This does not concern inspections of end users or consumers: these fall outside this regime. Nor does it concern other product rules that are not in the Battery Regulation or the market surveillance regulation, such as tax inspections or inspections under other CE Directives.
When this becomes relevant
The obligations under the Battery Regulation have been phased in, and the digital product passport becomes mandatory from 18 February 2027. The market surveillance powers from Regulation (EU) 2019/1020 already apply: a supervisory authority can now already inspect compliance with the requirements currently in force, and from 18 February 2027 will also include the product passport in the inspection. Until that date, the inspection will focus on the requirements already in force, such as labelling, CE marking and the documentation on which they are based. No specific date for when enforcement of the passport specifically begins is separately laid down — the obligation itself comes into force on 18 February 2027, and supervision of it follows from that date onwards.
How this is handled in practice
When facing an inspection, one first identifies which documents are already available: the declaration of conformity, the technical file, and — if the passport is already mandatory — the link to the digital product passport and the underlying data. The next step is to verify that these documents are current and correspond to the batteries actually placed on the market, as a supervisory authority compares documentation with practice. Subsequently, it is important to know who in the supply chain bears which responsibility: an importer who has the passport compiled by a third party remains the party addressed by the supervisory authority, so the underlying data must be transparent to that importer, even if hosting takes place elsewhere. Finally, it is practical to establish within the organisation who will handle a request from a supervisory authority and within what timeframe documentation can be provided, as Regulation (EU) 2019/1020 gives the supervisory authority the possibility to set a deadline for this.
The basics: articles 79 to 84
These powers and obligations follow from Regulation (EU) 2023/1542, articles 79 to 84, which concern batteries that present a risk, non-compliance and the corrective measures that may follow. The general powers of a market surveillance authority to request documents and information, carry out physical and laboratory checks and require corrective measures, are set out in Regulation (EU) 2019/1020, which applies to market surveillance and product compliance in a broader sense. Together, these two regulations determine what a market surveillance authority may request and what happens if a battery is found not to meet the requirements.
Anyone wishing to check which documents are required for a specific battery should consult the text of Regulation (EU) 2023/1542, articles 79 to 84, and Regulation (EU) 2019/1020 via the links below, or check — if batpas.eu compiles the product passport for that battery — which data has already been recorded there and which additional documentation must otherwise remain available.
What this is based on
- Regulation (EU) 2023/1542, articles 79 to 84 (batteries that pose a risk, non-compliance and corrective measures)
- Regulation (EU) 2019/1020 (market surveillance and product compliance)
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 check by the market surveillance authority does not proceed at random. Regulation (EU) 2019/1020 (market surveillance and product conformity) gives the surveillance authority a fixed set of powers, and Regulation (EU) 2023/1542, articles 79 to 84, specifically regulate what happens once a battery does not meet the requirements or poses a risk. For a company that imports, trades or processes batteries in its own products, this amounts in practice to a number of recurring obligations.
Being able to show documentation on request
The surveillance authority can request the technical documentation, declaration of conformity and the data that should appear in the battery passport. For a company of any size, this means that these documents must not be scattered among different employees or suppliers, but must be traceable in one place — preferably linked to the battery model or batch that the check concerns. Anyone who still needs to figure out what steps are needed for this will find an overview in how do I tackle the battery passport step by step?.
Being able to identify origin and responsible party
Market surveillance hinges to a large extent on traceability: who has placed the battery on the market, and who is accountable. A company must be able to indicate from which manufacturer or importer a batch originates and what arrangements have been laid down in this regard. This applies in particular to batteries that have been in the assortment for some time; for that situation there is a separate overview on what do I do with batteries already in stock?.
Cooperating in investigation and providing samples
The surveillance authority can, under Regulation (EU) 2019/1020, request samples or further information on a specific model or batch. This requires that a company has someone who recognises this request, knows where the batch in question is located, and does not have to assess for themselves whether the request is justified — that is not the company's role at that point.
Being able to execute corrective measures
When a battery proves to be non-compliant, articles 79 to 84 of Regulation (EU) 2023/1542 provide for corrective measures: modification, withdrawal from the market, or recall. A company with 10 to 100 employees typically has no daily routine for this, which creates the risk that no one knows who will handle it when it occurs. What such a measure means in practice is described on what do I do if a battery must be recalled?.
Being able to demonstrate that the passport works as intended
A surveillance authority can also test whether the QR data carrier actually leads to the correct, up-to-date data. A passport that exists but does not link correctly, or points to outdated information, is in practice just as much a problem as a missing passport. Testing before a passport goes live prevents this from coming to light during an inspection; see how do I check if my battery passport works correctly before I go live.
Where things go wrong in practice
A number of situations recur among companies that undergo an inspection.
The technical documentation exists, but is scattered across a foreign supplier, an old email exchange and a loose Excel file. At the moment the surveillance authority requests access, finding it takes more time than is desirable — not because the information is missing, but because no one knows exactly where it is.
A second recurring situation: the battery is second-hand or refurbished, and the company wrongly assumes that the passport requirement does not apply to it. Whether or not this is the case depends on the precise situation of the product; an explanation can be found on does the battery passport also apply to second-hand or refurbished batteries?.
A third situation occurs among smaller importers who assume that the rules mainly apply to large batches, and not to runs of a few hundred units. This assumption too deserves a separate check, which can be found on can I also create a battery passport if I only sell a few hundred units.
A fourth situation: the QR code on the battery refers to a page belonging to an earlier version of the product, because an update of the product passport was not carried out following a technical modification. During an inspection, this is noticed more quickly than within the organisation itself.
A fifth situation arises when a battery receives a second life in a different field of application, without it being recorded who is responsible for the product passport data from that point onwards. What needs to be arranged in that regard is set out on what do I need to arrange if I give a battery a second life?.
What you can record
- An overview per battery model or batch of the associated technical documentation and declaration of conformity, with a fixed location within the organisation.
- The contact details and agreements with the manufacturer or importer responsible for the underlying product information.
- An internal instruction on who processes a request from a competent authority, and what steps follow thereafter.
- A test log recording when and how the QR data carrier of a battery passport was checked before it was put into use.
- A procedure for updating product passport data when changes are made to the product, including who is responsible for it.
- An overview of batteries that were already in stock before the obligation took effect, with a note on the status of each batch.
- Arrangements regarding collection and take-back, insofar as those data form part of the product passport or are relevant in the event of a corrective measure; see also how do I arrange the collection and take-back of batteries?.
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.