Whether the Battery Regulation applies to your company does not depend on how large your company is, but on which product you place on the market. The obligation to attach a digital product passport to a battery from 18 February 2027 applies to specific product groups: batteries for electric vehicles, batteries in light means of transport such as e-bikes and scooters, and industrial batteries above 2 kWh. If your company places such a product on the market, the obligation is relevant, regardless of whether you are a sole proprietor or an importer with hundreds of colleagues.
Conversely: if you only sell products that fall outside these three categories, or you only come into contact with a battery after it has already been placed on the market by another party and remains unchanged, then the obligation probably does not rest with you. That is a first, quick assessment. For a more precise understanding of your own situation, you can go through a few targeted questions that indicate whether this applies to you.
Which products trigger the obligation
The Regulation focuses on the battery itself, not on the device around it. An importer of e-bikes with an integrated battery above the relevant threshold falls under the light means of transport rules. A machine builder who installs an industrial battery of, for example, 5 kWh in an installation falls under the industrial batteries category. A company that imports electric commercial vehicles with a propulsion battery comes into contact with the EV batteries category. In all three cases, it is not the size of your enterprise that is decisive, but the fact that you make the product available on the European market first, or as a representative of a manufacturer outside the EU.
Batteries that fall outside these three categories, such as small consumer batteries in mobile phones or tools, are subject to other rules within the same Regulation. These do not fall under the digital product passport obligation as treated on this platform. If you are unsure which category your product belongs to, that is precisely the kind of question for which the knowledge base per product group has been compiled.
When it probably does not apply to you
There are a few situations in which companies often think they are affected, when a closer look shows that they may not be. A shop that only resells e-bikes that have already been placed on the Dutch market by an importer, without making any changes to them, usually has a different position than that importer itself. A company that uses batteries exclusively in its own operations, without selling or leasing them to third parties, usually does not 'place them on the market' in the sense of the Regulation. And an undertaking that only exports batteries from the EU to countries outside the Union is, in principle, affected by a different aspect of the rules than the importer doing the opposite.
These examples are indicative, not conclusive. The Regulation works with a number of roles, such as manufacturer, importer, authorised representative and distributor, and the precise role your company takes on determines which obligations actually apply. This is a different question from the question of whether your product falls under the Regulation at all, and deserves its own investigation.
What you can check now
Even if you are not yet sure whether the obligation applies to your company, it is useful to map out now which batteries or battery-containing products you place on the market, who you source them from, and whether you are the first party in the EU to make them available. That inventory takes little time and prevents you from having to find out where you stand just before the implementation date. Answers to frequent uncertainties, for example about mixed assortments with both EV and consumer batteries, can be found in the frequently asked questions about who must provide which data.
A definitive assessment of your own situation is up to you, possibly with a legal advisor, or to the competent supervisory authority. This article describes the general distinction that the regulation makes, not the outcome for a specific company.
Would you like to get a first indication within a few minutes of whether your products fall under this obligation? Do the free quick-scan or browse through the topics in the knowledge base to see which situation comes closest to yours.