Hello together,

From my perspective working in the field of the EU Battery Regulation and the practical implementation of the Battery Passport, it may help to bring some clarity to this question — because “who is responsible?” is one of the most common uncertainties we see across industry.

Article 77(4) is clear:

“The economic operator placing the battery on the market shall ensure that the information in the battery passport is accurate, complete and up to date. It may give written authorisation to any other operator to act on its behalf.”

This means that the manufacturer (or importer) whose trade name or mark appears on the product label is ultimately responsible.

Other actors may support or provide data, but the legal responsibility stays with the economic operator placing the battery on the market.
I’m looking forward to your thoughts and further exchange on this topic.