A home battery placed on the EU market is governed by Regulation (EU) 2023/1542. The duties do not attach to the job title "installer" or "distributor" — they attach to the role you play in the supply chain. Classify that role wrongly and you can take on importer or manufacturer obligations without noticing. This guide maps the roles, lists the documents to collect per SKU, and gives the dates worth putting in a project calendar.
It is an operational summary for channel partners, not legal advice. The consolidated regulation and the implementing rules of the member state where the battery is placed on the market govern.
Start with the role, not the product
The regulation uses five economic-operator roles. Which one you occupy can change from shipment to shipment.
| Role | What puts you in it | Core duties |
|---|---|---|
| Manufacturer | You manufacture the battery, or have it designed or manufactured, and market it under your name or trademark | Conformity assessment, CE marking, EU declaration of conformity, technical documentation, label content, battery passport data |
| Importer | You are established in the EU and place a battery from a third country on the EU market | Verify the manufacturer has met its obligations, ensure the importer's name and address are present, keep the declaration of conformity, store and transport correctly, cooperate with authorities |
| Distributor | You make a battery available on the market further down the chain | Verify CE marking, the declaration of conformity, instructions and labels; do not make a non-compliant battery available; identify who supplied you and to whom you supplied |
| Authorised representative | You act on behalf of a manufacturer under a written mandate | Carry out the mandated tasks and hold the documentation available |
| Installer / service provider | You install or commission a battery already placed on the market | Not an economic operator by installation alone, but you must not modify the battery in a way that undermines conformity, must hand over the instructions, and must route waste correctly |
Three practical consequences follow from the table:
- A distributor that buys directly from a non-EU supplier is the importer for that transaction, even if its business card says "installer".
- A company that sells a battery under its own brand takes on manufacturer duties, regardless of who built it.
- An installer whose only action is mounting and commissioning a compliant battery is not automatically an economic operator, but the waste and handover duties in the destination market still apply.
A wall battery is usually an "industrial battery"
The regulation's categories are portable, light means of transport (LMT), starting-lighting-ignition (SLI), industrial and electric vehicle. A stationary home battery above 5 kg that is not intended for light means of transport generally falls into the industrial category. That classification decides which labelling, passport, performance and waste provisions apply, so it belongs in the first line of a specification, not in the footnotes.
It is also why a supplier answer copied from a portable-battery or EV-battery page cannot be relied on. The obligation schedules are different.
The dates worth putting in a project calendar
| Requirement | What it covers | Date to plan for |
|---|---|---|
| Label content and marking | Manufacturer and importer identification, chemistry, capacity, separate collection symbol, and the language required by the destination market | Main labelling requirements from 18 August 2026 |
| QR code | A readable link to the battery passport, carried on the battery | 18 February 2027 |
| Battery passport | A structured data set per battery, identified by a unique identifier | 18 February 2027, for LMT batteries, industrial batteries above 2 kWh and EV batteries |
| Recycled-content documentation | Recovered cobalt, lead, lithium and nickel shares in new batteries | From 18 August 2031, for industrial, EV and SLI batteries |
| Due-diligence policy | Supply-chain risk management for raw materials | Originally 18 August 2025; postponed by Regulation (EU) 2025/1561 — verify the current date |
| Producer registration | Registration in the member state where the battery is first made available | Already in force; register before placing on the market |
Carbon-footprint declarations are phased by category and depend on delegated acts, so check the Commission's current position rather than assuming a date from a secondary summary. The same caution applies to every row: amendments and delegated acts can move a date, and the consolidated text is the reference.
Primary sources: the consolidated Batteries Regulation, the 2025 amendment on due-diligence timing, the Commission's batteries and waste batteries page, and the Commission's battery passport pages.
What to request from a supplier before the first order
A generic certificate pack is not a document set. Ask for these, per model, in writing:
- The EU declaration of conformity naming the exact model or SKU.
- The test reports behind that declaration, not only a certificate cover page.
- The label artwork and the language version for the destination member state.
- Installation, operating and safety instructions in the required language.
- Manufacturer identification and the identity of the importer of record for the consignment.
- The producer registration or extended producer responsibility arrangement for that market.
- The waste take-back route, including who collects and who pays.
- The battery identifier format and how it will link to the passport after 18 February 2027.
A document that names a different model number is not evidence for the SKU in your order. Model-level matching matters more than the number of pages in the folder.
Who is the importer of record?
This is the question that catches channel partners most often. Three scenarios are worth checking before a purchase order:
- You buy from an EU-established supplier that already placed the battery on the market. You are normally a distributor, with verification and traceability duties.
- You buy directly from a manufacturer outside the EU and place the battery on the EU market. You are normally the importer, with the duties in the table above.
- You sell under your own brand or trademark. You can take on manufacturer duties even if another company built the product.
Write the answer into the commercial documents. An installer who discovers on the quay that it is the importer of record has no time to fix the paperwork.
The battery passport, seen from the van
From 18 February 2027, the QR code on an industrial battery above 2 kWh should resolve to a battery passport: a structured record tied to a unique identifier, covering performance and durability, carbon footprint, recycled content and other required fields. The Commission publishes guidance and an FAQ on how the system is being prepared.
Installers do not populate the passport. They should, however, be able to read the identifier and record it. Put the battery identifier in the commissioning record next to the inverter model and the serial numbers. When a service call or a warranty claim arrives three years later, that identifier is what connects the physical unit to its documentation. Our guide to reading a home battery datasheet covers the specification side; the passport adds the traceability side.
Take-back: decide the route before the battery leaves the wall
Waste batteries are not mixed waste. The regulation distinguishes collection duties by category:
- For portable and LMT batteries, distributors have point-of-sale take-back duties, with LMT collection obligations increasing in stages.
- For industrial batteries, the producer is responsible for collecting and financing waste management.
- A battery removed during a retrofit still needs a documented route, even if it is replaced by the same brand.
For an installer, the practical test is simple: before the van leaves the site with a removed pack, know where it is going, who is paying, and which serial number left the building. The retrofit guide covers the topology decision; the waste route is a separate line in the job file.
Due diligence: the deadline that moved
The due-diligence obligations were originally scheduled to apply from 18 August 2025. Regulation (EU) 2025/1561 stopped that clock; the Council's announcement of the amendment describes the postponement. Do not build a 2025 compliance deadline into a project plan, and do not assume the obligations disappeared. Check the consolidated text for the current date and the turnover threshold that determines who is in scope.
For a smaller installer, the first contact with due diligence is more likely to be a supplier questionnaire than a direct filing. A questionnaire still needs real answers, so keep the chain of documents clean enough to answer it.
A practical calendar
| Phase | Action |
|---|---|
| Before the first shipment | Classify your role; obtain the declaration of conformity per SKU; identify the importer of record; check label artwork and language; confirm the waste route |
| At each delivery | Match model and serial number to the documentation; record the serial and battery identifier; keep instructions in the destination language |
| Before 18 August 2026 | Confirm that label content and language meet the destination market's requirements |
| Before 18 February 2027 | Confirm with the supplier how the QR code and battery passport will be delivered and how the identifier is read |
| Ongoing | Retain the documents; monitor amendments and delegated acts; re-check the route when the destination market changes |
What Woolii will and will not put in a brochure
The Storage Wall series is a wall-mounted LiFePO4 line from 2.56 to 14.34 kWh, with 48 V and 51.2 V variants and CAN/RS485 communication for pairing with the hybrid inverters in a project. The wider range covers rack, stacked and floor formats, so the enclosure can follow the install site rather than the other way round.
What we will not do is claim a certification for the whole range. Documentation status is SKU-specific and market-specific. Send us the exact model, the destination country and the intended inverter, and we will return the datasheet, the current document list for that model, and a clear note on anything that is not yet available. A UL 1973 listing, where a specific SKU has one, is not inherited by the rest of the range; the same discipline applies to every other market approval. Our guide to what a UL 1973 listing actually covers explains why.
For the shipment itself, the UN38.3 and dangerous-goods guide covers the transport file. The compliance file and the transport file are related, but they are not the same folder.
If you are preparing a first order or a tender and need the document set mapped to a market, send us the project details or browse the Storage Wall series and the full product range. We will tell you what exists, what needs to be requested, and what we cannot confirm yet.