The passport requirement under the EU Batteries Regulation applies to light means of transport batteries, industrial batteries above the capacity threshold set by the Regulation and electric vehicle batteries, when placed on the EU market or put into service from February 2027. Portable batteries in consumer devices generally do not need a passport, though they face other requirements such as labelling and, in time, removability. If you export battery packs for electric bicycles, scooters, energy storage or vehicles, a passport is likely to be needed. We review your products against the definitions to confirm the position.

The economic operator that places the battery on the EU market or puts it into service is responsible for the passport. That is usually the manufacturer or, for products made outside the EU, the importer or another party established in the EU. A Bangladeshi exporter will not normally hold the legal duty itself unless it places products on the market directly through an EU entity, but it will almost certainly be asked to provide data. We clarify the roles in each sales channel and draft contracts setting out exactly what information the Bangladeshi party must supply.

A battery passport holds general information about the manufacturer and the battery model, material composition including hazardous substances and critical raw materials, carbon footprint information, recycled content, performance and durability data, information on supply-chain due diligence, and details relevant to repair, repurposing and recycling. Some information is public, while some is restricted to authorities or to persons with a legitimate interest. The exact content is being refined through implementing measures and standards. We help clients map each data field to its source and set up processes to collect, verify and update it throughout the product's life.

The legal obligations fall on economic operators placing batteries on the EU market above a turnover threshold, not directly on Bangladeshi suppliers. However, those operators must assess risks throughout their supply chains and will require information and commitments from suppliers, including Bangladeshi assemblers, pack makers and component manufacturers. The obligations were postponed and are now expected to apply from 2027. We help Bangladeshi suppliers prepare credible responses, policies and records, and negotiate contract terms that reflect the information they can realistically provide from their own upstream suppliers in China, India and other countries.

Yes, in several ways. Lead-acid batteries sold in the EU must meet the Regulation's requirements on substances, labelling, collection and producer responsibility, and industrial or vehicle batteries above the relevant thresholds may also need a battery passport depending on their category and use. Domestically, lead-acid battery manufacturing and recycling are subject to environmental clearance and hazardous waste controls, and improper informal recycling has caused serious pollution and public health concerns. We advise lead-acid battery manufacturers and recyclers on both export requirements and domestic compliance, including the records needed to demonstrate responsible end-of-life handling.

The Regulation separates information that must be publicly accessible from information available only to authorities or persons with a legitimate interest. Even so, many suppliers worry, with some justification, that composition, sourcing and performance data could reveal trade secrets or allow customers to bypass them. Contracts with buyers and passport platform providers should define access rights, permitted use, security standards, retention and what happens to data when the relationship ends. We draft these provisions and advise on balancing regulatory transparency with legitimate confidentiality, so that suppliers can participate without losing their competitive position.

There is currently no Bangladeshi battery passport requirement equivalent to the EU rules. Domestic regulation of batteries focuses on environmental clearance, hazardous waste and e-waste management, imports, product standards and workplace safety. However, Bangladeshi exporters must comply with the rules of their export markets, and other countries are considering digital product passports and battery due diligence. Building a robust record system now prepares businesses for future domestic or foreign rules and strengthens their position with existing buyers. We monitor battery passport developments and advise clients when new requirements are likely to affect their products or markets.

Inaccurate data can lead EU authorities to take action against the economic operator, including requiring corrective measures, withdrawal or recall of products and penalties under national law. The operator will usually seek to recover its losses from the supplier that provided the faulty data. Bangladeshi suppliers should therefore make sure their contracts define data responsibilities clearly, include verification procedures and set reasonable limits on liability. We help draft these terms, investigate data errors, notify buyers where required and resolve claims, so that a battery passport error does not escalate into a costly dispute.