Economic Operator Roles — Which One Are You?

Why this matters

The EU Battery Regulation places different obligations on different actors in the supply chain. The role you select in DPP Cloud determines how the responsible party is identified on the public DPP viewer, what information customs and market surveillance authorities see, and your legal obligations under the regulation.

The four roles

Manufacturer

You designed or manufactured the battery and are placing it on the EU market under your own name or trademark.

You are a manufacturer if:

• You make the battery in the EU
• You make the battery outside the EU and sell it under your own brand in the EU
• You have the battery made to your specifications and sell it under your brand

DPP obligation: You must create and maintain the Digital Product Passport.

Importer

You are bringing a battery into the EU from outside the EU and placing it on the market.

You are an importer if:

• You buy batteries from a manufacturer in China, Korea, Japan, the US, or any non-EU country
• You sell those batteries in the EU under the original manufacturer's brand or your own

DPP obligation: You become the responsible EU party. The public DPP viewer identifies your organisation as the EU Importer.

Authorised Representative

A non-EU manufacturer has formally appointed you to act on their behalf for EU regulatory compliance.

DPP obligation: You create DPPs on behalf of the manufacturer. The public viewer shows your firm as the EU Authorised Representative and identifies the manufacturer you represent.

Distributor

You make batteries available on the EU market but did not manufacture or import them.

DPP obligation: You must ensure the battery has a valid DPP before selling it. You do not create one.