One regulation, but not the same point of contact everywhere
Regulation (EU) 2023/1542, the battery regulation, is a regulation and not a directive. This distinction is precisely why this question is often asked. A directive must be transposed into national legislation by each country, and small differences always arise in the process. A regulation applies directly, in every Member State in the same way, without a national parliament making its own version of it. For the content of the digital product passport, this means that an e-bike placed on the market in the Netherlands, Germany or France must meet the same requirements.
Where it does differ is in the way countries organize supervision, and in the existing national arrangements that run alongside the battery regulation. For companies selling in multiple EU countries, this is often the practical question: not 'are there different rules', but 'who do I deal with in each country, and what was already arranged there before this regulation came in'.
What remains the same: the content of the passport
The data that belongs in a battery product passport, the QR data carrier, and the obligation to keep that information accessible for ten years, are set out in the regulation itself and therefore apply in the same way across the EU. An importer bringing batteries onto the market in several countries does not need to collect a different set of data per country. That is one of the few certainties in this matter: the substantive obligation is uniform. Anyone who wants to see exactly which data that is can find the source in the official text in the knowledge base with the obligations by subject.
What can differ: supervision, language and existing arrangements
Three things are organized nationally, and these can vary per country.
First, supervision. Each Member State appoints its own competent authority to check whether companies comply with the regulation and to take action in case of infringements. Which authority this is in a particular country, and how that authority operates, differs. For the Dutch situation, this is something to verify with the competent supervisory authority itself; we do not make a statement about this for your specific case.
Second, the language in which information must be available can be implemented differently per country, depending on how a Member State handles it. Third, and this is often the most important point for practice: the existing extended producer responsibility for collection and recycling of batteries operates through national arrangements that existed before this regulation was introduced. Those arrangements, with their own registrations and their own organizations per country, exist alongside the digital product passport and are not automatically arranged the same way.
Selling in multiple countries? Watch out for these points
Anyone placing batteries, e-bikes or industrial batteries on the market in multiple EU countries would be well advised to check per country which supervisory authority a company should approach, which national collection or producer responsibility scheme applies alongside the regulation, and whether there are local administrative obligations in addition to the EU-wide requirements. This is not a legal task you do on the side; it is precisely the kind of question for which a lawyer or the supervisory authority in the relevant country is the right party.
It helps to first clarify which role your company plays per country. A party that is considered a manufacturer in one country may formally be designated as an importer in another country, simply because the flow of goods is different. With a few questions that immediately give an indication you get an overview of where your company stands for the product passport, per situation you specify.
What this means for you
The key point is this: the passport itself is the same across the EU, but the route to it and oversight of it are not. This distinction is precisely why 'the regulation also applies in Germany' requires a different answer than 'do I need to account for a different competent authority in Germany'. Both answers are relevant, but they are not the same question.
For companies encountering this subject for the first time, an overview of how we collect data and where it comes from is available on the page that shows how we build a passport. Are you uncertain whether your situation falls under the regulation, or would you like an indication before you investigate further what differs by country? Take the free quick-scan or read through the topics in the knowledge bank; that will give you a first, substantiated picture of where you stand in half an hour.