The Battery Regulation is a separate EU regulation, distinct from the broader ecodesign regulation that the digital product passport is most often discussed in relation to. It primarily affects companies that place batteries or accumulators on the market themselves: manufacturers and importers of industrial batteries, batteries for electric vehicles, batteries for light mobility devices such as e-bikes, and portable batteries. If you only sell end products that happen to contain a battery, you are not automatically the party responsible for the product passport for that battery.
Whether your company falls under this regulation therefore depends mainly on your role in the supply chain of the battery itself, not of the device around it. An installation company that sells tools with batteries, an employer that leases company cars with batteries, or an office with laptops: for them, the responsibility usually rests with the party that manufactures or imports the battery, not with the user or reseller of the end product. This does not alter the fact that there may be information obligations in the supply chain that extend beyond the manufacturer alone.
Why this regulation stands apart
The ecodesign regulation is the broader framework within which a digital product passport will apply to an increasing number of product groups. The Battery Regulation exists alongside it and has already come into force earlier on a number of points, with its own timeline and specific requirements for, among other things, carbon footprint, recycled material and the digital product passport for batteries. This sometimes creates confusion for companies: one regulation does not align with the other, and a product group may already fall under its own rules while the broader framework is still being developed. In the overview per product group in the knowledge base it is indicated per category which regulation applies and what specifically applies there.
For whom this can be concretely relevant
The regulation is primarily aimed at parties that manufacture batteries, import them from a country outside the EU, or process batteries on a large scale, for example for recycling or for a second life in another product. Market participants who have batteries produced under their own brand and placed on the market can also be designated as the responsible party, even if physical production takes place elsewhere. Those who are uncertain whether any of these roles applies to their own company should check this against the roles that the regulation itself distinguishes, and not against the turnover or size of the company.
Companies that exclusively sell or use end products with a built-in battery typically do not find a direct product passport obligation for that battery in themselves. However, an indirect relationship may arise, for example when a supplier requests data about the use or lifespan of the product in which the battery is installed. This is a reason to also discuss this subject with your own procurement, and not to leave it only to the question of who is legally responsible.
What is not yet settled
The exact dates on which certain categories of batteries must have a digital product passport, and the precise scope of the data that must be contained in it, are laid down in the regulation itself and in the implementing rules that go with it. Part of this is still under development at the time of writing. For the current, official text, EUR-Lex is the appropriate source; for questions about application to a specific situation, the competent supervisory authority or a lawyer is the right point of contact. This article describes the main points, not advice about your own company.
How you verify this for your own products
Because the batteries regulation stands apart from the broader ecodesign rules, it is advisable to examine separately for each product category which obligations apply and when. in a few questions see whether this affects your products provides a first, non-binding indication of that. If you also want to know where the information on prodpas.eu comes from and how it is kept up to date, you can read that on the page about how we keep that information up to date for you.
If you have a concrete question about your own product category after this article, you may find in answers to other frequently asked questions already an answer. If you prefer to go straight to see where your company stands, the free quick-scan on prodpas.eu is the fastest first step: in a few questions you get an indication, without needing an account for that.