Implementation guide for Chinese companies

01Strategy definition and responsibility mapping

Goal: Clarify product classification and the company’s legal identity in the supply chain, and determine the applicable compliance path.

Determine the battery category and capacity threshold

• Calculate industrial battery energy under IEC 61960 (rated capacity Ah × nominal voltage V), not merely from the nominal value on the label, to determine whether the 2 kWh threshold is exceeded.
• Confirm whether the product is a “stationary battery energy storage system” (stationary BESS). Portable units (e.g. power banks that also provide propulsion) do not fall into this category and may be exempt from some BMS reset requirements.

Prerequisites	Detailed electrical specification sheets for the product
Expected result	Clear identification of which SKUs need a carbon footprint and battery passport (>2 kWh industrial / EV / LMT) and which need only baseline compliance
Potential risk	If the regulator does not accept the IEC 61960 calculation, borderline products (e.g. 1.9 kWh) may be forced into the high-compliance-cost zone

Determine “producer” status (EPR responsible party)

• Apply the EUROBAT scenario analysis tool to determine the registration responsible party by trade term (DDP/FOB) and customer type (OEM/distributor/end user).
• Cross-border e-commerce (direct sales to end users): immediately start the process of appointing an EPR authorised representative in the country of sale.

Prerequisites	Clear sales contracts and a logistics route map
Expected result	Clarity on whether to register for EPR and pay yourself, or leave it to the EU customer; avoid double payment or compliance gaps
Potential risk	Member States apply different definitions of “first placing on the market”, which may result in conflicting registration requirements across countries

02Building the supply-chain data architecture

Goal: Build a supply-chain traceability system that can pass third-party verification, in preparation for carbon footprint and due diligence.

Implement an OECD due diligence system

• Establish a management system based on the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
• Limit the traceability scope to the battery cell level; exclude non-chemical components such as casings and screws for now.
• Require Tier 1 suppliers to disclose the names and countries of origin of their direct suppliers of upstream raw materials (cobalt, lithium, nickel, graphite).

Prerequisites	Supply-chain transparency agreements signed
Expected result	Annual due diligence report produced (can be integrated into the ESG report), ready for notified body audit
Potential risk	Upstream miners falsify data or refuse transparency, making third-party verification impossible and the product barred from the market

Carbon footprint data modelling and accounting

• Build an LCA model based on the PEF (Product Environmental Footprint) methodology.
• Collect primary data for specific factories and specific models; use of averaged data across different factories is strictly prohibited.
• Exclude “carbon offset” data and count only actual emissions.

Prerequisites	Factory-level energy consumption and bill of materials (BOM) data complete
Expected result	Carbon footprint declaration (kg CO₂e/kWh) generated and filed in the technical documentation
Potential risk	Delegated acts are delayed or detailed rules change abruptly, invalidating earlier models and compressing the compliance window

03Product engineering and testing

Goal: Adjust product design to meet physical performance, safety and data access requirements.

Develop open BMS data interfaces

• Design BMS firmware that can record and output state of health (SOH) and expected lifetime data in read-only form.
• Develop a software reset function for EV and LMT batteries.
• Confirm that non-smart industrial batteries (e.g. lead-acid) are exempt from the BMS installation obligation.

Prerequisites	BMS hardware supports data storage and communication
Expected result	BMS data meets Annex VII requirements and supports repurposing assessment
Potential risk	Inaccurate BMS algorithms cast doubt on SOH data, leading to disputes in second-hand sales or hindering repurposing

Removability and safety design

• Verify the “easy removability” of portable batteries under EN 45554:2020 (using commercially available tools).
• Carry out the safety tests specified in Annex V (thermal shock, short circuit, thermal propagation, etc.).
• Conduct a risk assessment using FMEA (failure mode and effects analysis) and include it in the technical documentation.

Prerequisites	R&D team familiar with EN standards and EU safety parameters
Expected result	Product passes safety tests and the design meets right-to-repair requirements
Potential risk	Over-integration (CTP/CTC) makes “removable by independent professionals” impossible to meet, requiring new tooling

04Conformity assessment and digitalisation

Goal: Complete the legal paperwork, obtain the CE marking and deploy digital tools.

Choose the conformity assessment module

• General safety requirements use Module A (internal production control), self-declared by the manufacturer.
• For carbon footprint, recycled content and similar indicators, a notified body must perform Module D1 (quality assurance of the production process) or Module G (unit verification).
• Screen qualified notified bodies in the NANDO database.

Prerequisites	ISO 9001 quality system in place (the basis for Module D1)
Expected result	Notified body certificate obtained and EU declaration of conformity (DoC) signed
Potential risk	Insufficient notified body capacity causes backlogs, preventing the necessary certificates from being obtained before shipment

Deploy the battery passport and QR code

• Choose a decentralised data solution and generate a unique identifier compliant with ISO/IEC 15459.
• Generate a QR code, ensure it contains some offline data (stored locally), and affix it in a prominent position on the battery.

Prerequisites	IT systems have collected all compliance data (carbon footprint, material composition, etc.)
Expected result	Every battery has a unique digital identity, with data accessible to different permission levels
Potential risk	The chosen third-party passport platform is incompatible with EU data standards (e.g. Catena-X), requiring costly migration later

05Logistics and after-sales

Goal: Ensure compliant physical delivery and a closed loop for waste battery management.

Digital documentation accompanying shipments

• Keep paper documents accompanying shipments only for safety information.
• Provide non-safety documents such as carbon footprint declarations and instructions via digital links/QR codes to reduce packaging costs.

Prerequisites	Stable hosting servers for digital documentation
Expected result	Compliant with the Blue Guide, reducing logistics material costs
Potential risk	Customs in some conservative Member States insist on a full set of paper documents, causing goods to be held

Repurposing and waste management

• If repurposing (e.g. from traction to storage), re-assess conformity under Module A and issue a new DoC.
• When exporting second-life batteries, provide SOH test reports (capacity/impedance tests) and sales contracts to prove they are not “e-waste”.

Prerequisites	In-house battery condition testing capability or a partner
Expected result	Lawful cross-border transport of second-life batteries, avoiding allegations of illegal waste shipments
Potential risk	Re-certification costs are too high, the repurposing business model fails, and batteries are forced into direct recycling

Reporting obligationsWhat to report and who reports Risk management analysisTen key assumptions Frequently asked questionsSix question-and-answer groups

Basis: Regulation (EU) 2023/1542; harmonised and international standards including EN 45554:2020, IEC 61960 and ISO/IEC 15459; industry practice references the EUROBAT and EUROMOT guidance. This page is a compliance guide; the official text and the competent authority's interpretation prevail. Entries marked "under consideration" or "draft" may change.