--- title: "A marketplace asks for battery information on the listing" description: "Marketplaces under the Digital Services Act's trader rules must obtain from producers that offer batteries, or products with batteries inside, to EU consumers: the registration number in the national register of producers and a self-certification on extended producer responsibility (Battery Regulation (EU) 2023/1542, Article 62(6)). Register in each country you sell to, check the battery's CE marking and labels, and put the safety and take-back information in the listing." type: "problem" url: "https://www.conphora.com/solutions/problem/marketplace-battery-info/" markdown: "https://www.conphora.com/solutions/problem/marketplace-battery-info.md" locale: "en" language: "en" updated: "2026-10-05" author: "Conphora compliance team" publisher: "Conphora" source: "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1542-20260813" tags: ["BattR", "GPSR", "marketplace-retailer"] license: "Free to quote with attribution and a link to the page" --- # A marketplace asks for battery information on the listing Marketplaces under the Digital Services Act's trader rules must obtain from producers that offer batteries, or products with batteries inside, to EU consumers: the registration number in the national register of producers and a self-certification on extended producer responsibility (Battery Regulation (EU) 2023/1542, Article 62(6)). Register in each country you sell to, check the battery's CE marking and labels, and put the safety and take-back information in the listing. ## Why this happens The battery fields in a listing form come from the waste chapter of the Battery Regulation (EU) 2023/1542. For the purposes of the trader traceability rules in the Digital Services Act, providers of online platforms within the scope of those rules (which exclude platforms that are micro or small enterprises, unless designated as very large) that allow consumers to conclude distance contracts with producers must obtain two things from producers offering batteries to consumers in the Union: details of the register of producers and the producer's registration number or numbers, and a self-certification committing the producer to offer only batteries for which the extended producer responsibility requirements are met (Article 62(6)). The rule expressly covers batteries incorporated in appliances, light means of transport or other vehicles. [1] The producer is defined widely. It is the manufacturer, importer, distributor or other person that, irrespective of the selling technique, manufactures batteries or has them made and first supplies them under its own name in a Member State, resells under its own brand there, first supplies batteries from another country there on a professional basis, or sells them by distance contracts directly to end-users in a Member State while established in another Member State or a third country. Producers register in each Member State where they make a battery available for the first time, and may only make batteries available there if registered (Article 55(2)). [1] A marketplace seller is also a distributor or an importer of the battery as a product. A distributor verifies before making a battery available that the producer is registered, that the battery bears the CE marking and is marked and labelled in accordance with Article 13, that it comes with the required documents and with instructions and safety information in a language end-users easily understand, and that the manufacturer and importer have put their details on it (Article 42(2)). An importer verifies in addition that the declaration of conformity and the technical documentation have been drawn up (Article 41(2)). The marks arrive in stages: the separate collection symbol since 18 August 2025, the general information label from 18 August 2026 or 18 months after the implementing act, whichever is the latest, and the QR code from 18 February 2027 (Article 13(1), (4) and (6)). The implementing act on the label specifications was due by 18 August 2025 (Article 13(10)); because the 18 months run from its entry into force, check whether it has been published before treating the general label as due. [1] Information duties reach the listing too. Producers make information on waste prevention, collection points, safety instructions and the meaning of the labels available to end-users, as a minimum at the point of sale and through online platforms (Article 74(1)), and distributors provide it also when they sell through online platforms (Article 74(4)). In sales with delivery, the end-user is informed when ordering of the take-back arrangements (Article 62(5)). Under the General Product Safety Regulation (EU) 2023/988, every online offer shows the manufacturer, the responsible person where the manufacturer is outside the Union, the product identification and the warnings and safety information (Article 19). The Battery Regulation is one of the acts for which Regulation (EU) 2019/1020 requires such a responsible economic operator in the Union (Article 4(5)). [1] [2] [3] ## How to solve it 1. **Find out whether you are the producer, country by country** You are the producer where you first supply the battery in a Member State, sell it there under your own brand, or sell it from another country directly to end-users by distance contract. A battery built into an appliance, an e-bike or a toy counts. List the countries you ship to and your position in each. 2. **Register and get the number** Apply to the register of producers in each Member State where you make batteries available for the first time. Where you sell directly to end-users in a country where you are not established, you must appoint an authorised representative for extended producer responsibility there by written mandate. Keep the registration numbers per country and battery category. 3. **Check the battery and its papers** Before listing, verify the CE marking, the separate collection symbol, the labels due at the date of sale, the manufacturer's and importer's details, and the instructions and safety information in the buyer's language. As importer, also verify that the declaration of conformity and technical documentation exist. 4. **Put the battery information in the offer** Show the warnings and safety information that go on the battery or its packaging, the manufacturer and, for a non-EU manufacturer, the responsible person. Tell the buyer when ordering how a waste battery can be returned free of charge. 5. **Give the marketplace the number and the self-certification** Enter the registration number for each country where the platform offers your product, and confirm that you only offer batteries for which the producer responsibility requirements are met. Update both when you add a country or a battery category. ## What you need to show - **Producer registration number for each Member State of sale** — The national register of producers (Battery Regulation Articles 55(2) and 62(6)(a)) - **Self-certification on extended producer responsibility** — You as producer (Battery Regulation Article 62(6)(b)) - **EU declaration of conformity for the battery** — The battery manufacturer (Battery Regulation Articles 18 and 41(2)(a)) - **Photos or artwork showing the CE marking, the collection symbol and the labels** — The battery and its packaging (Battery Regulation Articles 13 and 42(2)(b)) - **Information to end-users on waste batteries and take-back** — The producer or its producer responsibility organisation (Battery Regulation Articles 62(5) and 74(1) and (4)) ## If you do nothing - **No registration, no sale in that country** — Producers may only make batteries available on the market of a Member State, including batteries incorporated in appliances, light means of transport or other vehicles, if they or their authorised representative are registered there (Article 55(2)). - **A distributor must hold back a non-conforming battery** — A distributor that considers or has reason to believe that a battery does not conform to the labelling and other product requirements must not make it available until it has been brought into conformity (Article 42(3)). - **The listing itself is checked** — An online offer must show the warnings and safety information required by the applicable harmonisation legislation (GPSR Article 19(d)). Authorities can require operators to end a non-compliance and can restrict the making available of a product (Regulation (EU) 2019/1020, Article 14(4)(g) and (h)). ## Questions ### We sell a gadget with a built-in battery, not batteries. Does this apply? Yes. The platform's duty covers producers offering batteries including those incorporated in appliances, light means of transport or other vehicles (Article 62(6)), and the definition of producer covers the same. ### Do we need a registration in every country we ship to? A producer applies for registration in each Member State where it makes a battery available on the market for the first time (Article 55(2)). A seller established in one country that sells directly to end-users in another is the producer in that other country and must appoint an authorised representative for extended producer responsibility there (Article 56(3)). ### We buy from an EU wholesaler. Who is the producer? For sales in the same Member State, usually whoever first supplied the battery there, which can be the wholesaler. Once you sell by distance contract directly to end-users in another Member State, you are the producer there. ### Is the QR code on the battery required yet? Not yet. All batteries must carry a QR code from 18 February 2027 (Article 13(6)). The separate collection symbol has been required since 18 August 2025 (Article 13(4)). ### Does a battery product need an EU responsible person? Yes. The Battery Regulation is among the acts for which a product may only be placed on the market if an economic operator established in the Union is responsible for it, with its name and contact details on the product, packaging, parcel or an accompanying document (Regulation (EU) 2019/1020, Article 4(1), (4) and (5)). ## Regulations involved BattR, GPSR ## Sources 1. [Regulation (EU) 2023/1542 concerning batteries and waste batteries (consolidated text of 13 August 2026)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1542-20260813) — EUR-Lex, 2026-10-05 2. [Regulation (EU) 2019/1020 on market surveillance and compliance of products (consolidated text of 12 August 2026)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02019R1020-20260812) — EUR-Lex, 2026-10-05 3. [Regulation (EU) 2023/988 on general product safety (consolidated text of 29 May 2026)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R0988-20260529) — EUR-Lex, 2026-10-05