The Battery Regulation distinguishes several roles that a company can have in relation to a battery: manufacturer, importer, distributor and authorised representative. All these roles fall under the broader concept of supplier, the party that places a battery on the market or makes it available. Which role applies to your company also determines, in part, who is responsible for drawing up and keeping the digital product passport up to date.
The detail most frequently overlooked in this question is this: anyone who sells a battery under their own name or brand is considered a manufacturer under the Regulation, even if that battery was produced elsewhere. For many e-bike and scooter importers operating under their own house brand, this means that they do not automatically have the lighter role of importer or distributor, but are in practice classified as manufacturers with the associated obligations.
The three main roles at a glance
The manufacturer is the party that manufactures a battery, or has it manufactured, and places it on the market under their own name or brand. The importer is the person who places a battery manufactured outside the European Union on the market within the EU for the first time, without putting their own brand on it. The distributor, finally, is the party that offers a battery further down the supply chain without being a manufacturer or importer — think of a wholesaler or shop that resells a product from another party without making any changes to it.
This classification seems straightforward, but in practice in machine building and battery trading, roles often overlap. One company can be a distributor for one product and a manufacturer for another, depending on how the product is purchased and under what name it is sold.
Why the private label detail so often comes as a surprise
For an installation company that purchases batteries from a wholesaler and resells them as is, the role is usually clear: distributor. It becomes more difficult when an importer has battery packs assembled by a factory outside the EU and then places those packs on the Dutch market under its own product name. In that case, the Regulation may regard this party as a manufacturer, with all the associated obligations — even if the company has always seen itself as an importer.
This is not a theoretical point. Precisely in the light transport sector, where many parties have battery packs manufactured and sold under their own name, this detail determines who must supply the data for the digital product passport and who remains responsible if something is missing. the concepts of manufacturer, importer and distributor explained per situation provides a more concrete picture per scenario than a general definition can offer.
What the role means for the passport
The role in the supply chain determines not only who has obligations, but also who must supply which data for the product passport: material composition, origin, performance and instructions for maintenance and end-of-life are usually the responsibility of whoever is considered the manufacturer. An importer who is not classified as a manufacturer often has a different, more limited set of obligations, for example regarding checking whether the passport is present. Batpas.eu compiles the passport based on the data supplied by the responsible party, hosts the passport for ten years and supplies the QR data carrier that is linked to the battery.
Because the question of who has which role directly determines who must act, it is worthwhile for companies with their own brand or own product name on batteries to clarify this early, well before the obligation on 18 February 2027 comes into force. Companies that only look at this shortly beforehand may discover that more data needs to be collected than expected.
When the role is not immediately clear
In collaborations with multiple parties — a factory outside the EU, an importer, a wholesaler selling under its own name — it can happen that it is not immediately clear which party fulfils which role. The regulation itself provides the definitions, but their application to a specific chain of purchase and sale is not always unambiguous. For assessing your own situation, it is advisable to consult the official text or involve a lawyer; the competent authority in the Netherlands is also a contact point for this.
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