Authorised representative
Put a name in the Union behind every battery you ship there.
A manufacturer outside the EU can appoint one person inside it to hold the mandate, keep the file and face the authorities. Battery Pass EU takes that role for battery makers, and can register the passports under the same relationship, so the party that answers for your batteries in Europe is the party that holds their data. EU Digital Passport Processor remains the passport platform either way.
- Why you appoint one
- A manufacturer established outside the Union may appoint, by written mandate, a person established in the Union to act on its behalf on specified tasks under the Battery Regulation (Art 3(63)). The mandate takes effect once Battery Pass EU accepts it in writing (Art 40(1)). From that point an authority in any member state has one address to write to, and you have one party to call.
- What Battery Pass EU does for you
- Keeps the EU declaration of conformity, technical documentation, verification reports, approval decisions and audit reports at the disposal of national authorities for 10 years after each battery is placed on the market; provides the information that demonstrates conformity on reasoned request; cooperates with authorities on any action to eliminate risk; and informs market surveillance where a battery presents one (Art 40(3) and (4)). You hear from Battery Pass EU before you hear from them.
- What is checked before it ships
- Where Battery Pass EU is also the economic operator under Article 4 of Regulation (EU) 2019/1020, it verifies that the declaration of conformity and technical documentation exist before a model goes on the market, and sees corrective action through when an authority requires it or a battery presents a risk (Art 4(3)).
- What stays yours
- Design, manufacture, marking and labelling, technical documentation, conformity assessment, the declaration of conformity and due diligence cannot be mandated to a representative (Art 38; Art 40(2)). You remain the manufacturer. Battery Pass EU makes sure the Union can see that you have done it.
- Names on the product
- Yours stays on the battery as manufacturer (Art 38(7)). Battery Pass EU's goes on the battery, its packaging, the parcel or an accompanying document (Reg 2019/1020 Art 4(4)). It does not place batteries on the market, take title to them, or appear as the brand.
- The liability the representative carries with you
- For products placed on the market from 9 December 2026, the authorised representative of a manufacturer outside the Union is liable for damage caused by a defective product, jointly and severally with the manufacturer and any importer, without contractual limit, for 10 years from placing on the market and 25 years for latent personal injury (Directive (EU) 2024/2853 Arts 8, 12, 15 and 17). That is why the mandate below asks for what it asks for.
- What the mandate contains
- The Article 40(3) tasks and the Article 40(2) exclusions; the models covered; your obligation to supply the file, keep it current, and notify Battery Pass EU of any incident, complaint, test failure or recall in any market; an indemnity supported by security and by your product liability insurance naming Battery Pass EU; termination rights; and the obligations that continue for batteries placed on the market during the mandate.
- One relationship, both authorisations
- Registering and maintaining battery passports under Article 77(4) is a separate written authorisation from the Article 40 mandate. Battery Pass EU can hold both. The file an authority asks for and the passport a customs officer scans are then kept by the same party, from the same records, and stay consistent with each other. If you keep registration with EU Digital Passport Processor instead, the two parties work from the same passport data.
- What Battery Pass EU needs to scope it
- For each model intended for the EU market: type, capacity and chemistry; expected EU volume per year; destination member states and their share; and whose brand appears on the product.
Who provides this service
Authorised representation is provided by Battery Pass EU, a separate entity working alongside EU Digital Passport Processor. Battery Pass EU holds the Article 40 mandate; its legal name and registered address go into the mandate itself. It is the party to contact for this service. EU Digital Passport Processor remains your passport platform and registry service provider, whether or not you also appoint a representative.
batterypasseu.com/authorised-representative