Authorised representative
Put a name in the Union behind every battery you ship there.
A manufacturer outside the EU can appoint one person inside it to hold the mandate, keep the file and face the authorities. We take that role for battery makers, and register the passports under the same relationship, so the party that answers for your batteries in Europe is the party that holds their data.
- Why you appoint one
- A manufacturer established outside the Union may appoint, by written mandate, a person established in the Union to act on its behalf on specified tasks under the Battery Regulation (Art 3(63)). The mandate takes effect once we accept it in writing (Art 40(1)). From that point an authority in any member state has one address to write to, and you have one party to call.
- What we do for you
- Keep the EU declaration of conformity, technical documentation, verification reports, approval decisions and audit reports at the disposal of national authorities for 10 years after each battery is placed on the market; provide the information that demonstrates conformity on reasoned request; cooperate with authorities on any action to eliminate risk; and inform market surveillance where a battery presents one (Art 40(3) and (4)). You hear from us before you hear from them.
- What we check before it ships
- Where we are also the economic operator under Article 4 of Regulation (EU) 2019/1020, we verify that the declaration of conformity and technical documentation exist before a model goes on the market, and we see corrective action through when an authority requires it or a battery presents a risk (Art 4(3)).
- What stays yours
- Design, manufacture, marking and labelling, technical documentation, conformity assessment, the declaration of conformity and due diligence cannot be mandated to a representative (Art 38; Art 40(2)). You remain the manufacturer. We make sure the Union can see that you have done it.
- Names on the product
- Yours stays on the battery as manufacturer (Art 38(7)). Ours goes on the battery, its packaging, the parcel or an accompanying document (Reg 2019/1020 Art 4(4)). We do not place batteries on the market, take title to them, or appear as the brand.
- The liability we carry with you
- For products placed on the market from 9 December 2026, the authorised representative of a manufacturer outside the Union is liable for damage caused by a defective product, jointly and severally with the manufacturer and any importer, without contractual limit, for 10 years from placing on the market and 25 years for latent personal injury (Directive (EU) 2024/2853 Arts 8, 12, 15 and 17). That is why the mandate below asks for what it asks for.
- What the mandate contains
- The Article 40(3) tasks and the Article 40(2) exclusions; the models covered; your obligation to supply the file, keep it current, and notify us of any incident, complaint, test failure or recall in any market; an indemnity supported by security and by your product liability insurance naming us; termination rights; and the obligations that continue for batteries placed on the market during the mandate.
- One relationship, both authorisations
- Registering and maintaining battery passports under Article 77(4) is a separate written authorisation from the Article 40 mandate. We hold both. The file an authority asks for and the passport a customs officer scans are then kept by the same party, from the same records, and stay consistent with each other.
- What we need to scope it
- For each model intended for the EU market: type, capacity and chemistry; expected EU volume per year; destination member states and their share; and whose brand appears on the product.
- Who holds the mandate
- An Irish-established entity, now being formed. Its legal name and registered address go into the mandate itself.