circular economy,  compliance e AEO,  free trade agreement

AEO and obligations of importer of batteries

Luglio 23, 2023 /

According to the European batteries framework, the importers has to place on the market a battery which is compliant with Articles 6 to 10 and Articles 12, 13 and 14 of the regulation.

In particular, before placing a battery on the market, importers shall verify that:

  • the EU declaration of conformity and technical documentation referred to in Annex VIII (Conformity assessment procedures) have been drawn up and that the relevant conformity assessment procedure has been carried out by the manufacturer
  • the battery bears the CE marking referred and is marked and labelled in accordance with Article 13;
  • the battery is accompanied by the documents required pursuant to Articles 6 to 10 and Articles 12, 13 and 14 and by instructions and safety information in a language or languages which can be easily understood by end-users, as determined by the Member State in which the battery is to be made available on the market;
  • the manufacturer has complied with the following requirements: mark CE and clear, understandable and readable instructions and safety information in a language or languages which can be easily understood by end-users.

Furthermore, where the battery presents a risk, the importer shall inform the manufacturer and the market surveillance authorities giving details of the non-compliance and of any corrective action taken.

Importers has to indicate on the battery their name, registered trade name or registered trade mark, their postal address, indicating a single contact point, and, if available, web and e-mail address. Where that is not possible, the required information shall be provided on the packaging or in a document accompanying the battery. The contact details shall be in a language or languages which can be easily understood by end-users, as determined by the Member State in which the battery is to be made available on the market, and shall be clear, understandable and legible.

Importers shall, for 10 years after the battery has been placed on the market, keep a copy of the EU declaration of conformity at the disposal of the national authorities.

Finally, , the AEO approach based on high knowledge of free trade agreements, rules of origine, preferential origin, monitoring of the internal processes and ongoing risks analysis, is the main way to manage the coming obligations of this new legal framework.