EU DPP Compliance for Importers and Distributors

Article 4 of EU Battery Regulation 2023/1542 places compliance obligations on every economic operator in the supply chain — including importers and distributors who place products on the EU market.

EU Battery Regulation 2023/1542, Article 4; ESPR 2024/1781, Article 4 · 348 days remaining

Your obligation in plain English

If you import batteries or other covered products into the EU market, or distribute them within the EU, you share responsibility for ensuring a compliant DPP accompanies each unit. You must verify that the manufacturer has created the passport, that it is accessible, and that the data is accurate. If the manufacturer is outside the EU and has not provided a passport, the importer becomes the responsible economic operator.

EU Battery Regulation 2023/1542, Article 4; ESPR 2024/1781, Article 4

What your product passport must contain

Verify manufacturer passport exists before import
Check passport completeness and accuracy
Ensure QR code is present and resolves correctly
Create passport if manufacturer has not (importer obligation)
Maintain records for market surveillance authorities
Report discrepancies to manufacturer and competent authority

How Traceable helps

Every field in the template is mapped directly to the regulatory requirement it satisfies. The compliance scoring engine shows your completion percentage per section — so you know exactly what is missing and what is complete.

  • AI document extraction from test reports and certificates
  • Real-time compliance scoring per regulatory section
  • GS1 Digital Link QR code on every published passport
  • Supplier portal for upstream data collection
Compliance Dashboard
Overall Score 94%
Fields Completed 105 / 111
QR Code Generated
Supply Chain 3 of 4 suppliers verified
EU Registry Ready

Your action timeline

Now
Audit your supply chain

Identify which products in your portfolio will require passports and when.

Q1 2026
Contact manufacturers

Confirm your manufacturers' DPP readiness. Identify gaps.

Feb 2027
Battery passport mandatory

All batteries in scope must have compliant passports at point of import.

Frequently asked questions

If the manufacturer has created a compliant passport, your obligation is to verify it exists and is accessible. If the manufacturer is outside the EU and has not created a passport, the importer becomes the responsible economic operator and must create one.

You cannot legally place a product without a compliant passport on the EU market after the mandatory date. If your manufacturer cannot or will not provide the required data, you must either create the passport yourself or find an alternative supplier.

Yes. The Verifier Portal allows you to check passport completeness and data accuracy for products in your portfolio. The compliance score shows exactly what is present and what is missing.

What happens if you miss the deadline

Importers and distributors who place non-compliant products on the EU market after mandatory deadlines face the same enforcement actions as manufacturers — market withdrawal, import blocks, and penalties.

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