Determining Importer Liability under European Union Battery Regulations
EU Regulation 2023/1542 holds the first European entity taking title to imported batteries legally liable for all safety, carbon footprint, and passport duties.
Module a Internal Control
Meaning
Conformity assessment pathways that allow manufacturers to self-declare that their products meet all applicable safety and environmental standards provide a simplified route to market access. The use of module a internal control means that the manufacturer itself verifies and declares compliance without mandatory third-party audits. This pathway is restricted to specific battery classes that do not require independent certification.
It does not apply to batteries that use reclaimed materials or have complex chemistry configurations.
Compliance Procedure
Quality assurance activities must be integrated directly into the assembly line to maintain the validity of this self-declaration. Under a module a internal control regime, the factory must test finished packs to ensure they match the approved design specifications. This ensures that every shipped unit meets the safety criteria.
The process remains entirely under the control of the producing company.
Technical File
Technical documentation must be compiled and kept for ten years after the battery has been placed on the market. Sourcing teams must review these dossiers during their quality audits to ensure the manufacturer has performed all necessary thermal and electrical safety tests. This dossier must be presented to market authorities upon request.
Sourcing Choice
Sourcing departments use this simplified compliance route to reduce the lead times and costs of bringing standard battery packs to market. This approach is highly effective for low-risk applications.