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.

In principle, the responsible economic operator in the EU is responsible. However, this may change depending on the life cycle stage of the product. For batteries, for example, it is initially the importer and later, if applicable, the reprocessor. Since the DPP is designed for different legislations, there is no general answer to this question.

Hi Philip, I guess that is still one of the key open questions around the DPP. In principle, the economic operator placing the product on the EU market will be responsible for creating the Digital Product Passport. But in practice, that requires input from across the value chain: suppliers provide data, manufacturers compile and validate it, and updates may be needed at different life cycle stages (e.g. repair, reuse, recycling). Would be great to hear some thoughts from the community, what do you think?