This EU Battery Regulation checklist for car vacuum importers explains what European importers, distributors, ecommerce sellers and private-label brands need to review before ordering cordless car vacuums for sale in the European Union. A detachable battery is a good starting point, but it is only one part of the work. Buyers need to check battery removal, replacement compatibility, spare battery supply, labels, QR codes, technical documents, producer registration, instructions and post-market records.
Article 11 of Regulation (EU) 2023/1542 applies from 18 February 2027. It requires portable batteries incorporated into products to be readily removable and replaceable by the end user during the product’s service life. The European Commission’s updated guidance, published on 14 July 2026, explains that removal and replacement should avoid damage to the battery and appliance. The replacement battery should let the appliance continue operating without affecting function, performance or safety.
This article is a practical sourcing and project-management guide. It is not legal advice. Importers should confirm national registration, language, waste collection and extended producer responsibility procedures in every EU Member State where the product will be sold.
Quick EU Battery Regulation 2027 Checklist
Use this table during supplier selection, sample approval and pre-shipment inspection.
| Checkpoint | What to Verify | Evidence to Request |
|---|---|---|
| Legal role | Importer, distributor, battery producer or private-label manufacturer | Written responsibility table |
| Battery category | Rechargeable portable battery incorporated into an appliance | Battery specification sheet |
| Removability | The complete battery pack can be removed safely | Physical sample and removal video |
| Replaceability | A compatible pack restores normal operation | Replacement test record |
| Removal tools | No proprietary tool, heat or solvent is required | Removal instructions |
| Spare battery supply | Replacement packs remain available for at least five years | Supply agreement |
| Online instructions | Battery removal and safety information remains publicly accessible | Live web page or approved draft |
| Battery marking | Model, batch code, contacts and required symbols | Final battery artwork |
| QR code | QR content is accurate and accessible | Working QR code test |
| Conformity documents | Technical file, EU declaration and CE marking | Document package |
| Importer details | Importer name and contact information appear in the correct location | Approved artwork |
| Producer registration | Registration completed in each applicable Member State | Registration numbers |
| EPR arrangements | Collection, reporting and waste-battery financing are assigned | PRO or representative agreement |
| Traceability | Supplier, buyer, model and quantity records can be retrieved | Traceability procedure |
| Post-market plan | Complaints, corrective actions and recalls are documented | Written procedure |
A downloadable version can add columns for Pass, Needs Action, Responsible Party, Deadline and Evidence File.
1. Identify Your Legal Role Before Placing an Order
The first step is to identify which company carries each duty. A factory outside the EU, an EU importer, a private-label brand, an online seller and a local distributor may hold different roles under the same product program.
Car Vacuum Importer
An importer bringing a battery or an appliance containing a battery from outside the EU must verify that the required conformity assessment has been completed, the technical documentation and EU declaration of conformity have been prepared, the battery carries CE marking, and the required labels and instructions are present.
The importer must place its name, registered trade name or trademark, postal address and available electronic contact details on the battery. When direct marking is not practical, this information may appear on the packaging or an accompanying document.
The importer must keep a copy of the EU declaration of conformity for ten years after the battery has been placed on the market. It must make the technical documentation available to national authorities when requested.
Distributor
A distributor must check that the producer is registered, the battery carries CE marking and required labels, and the package includes the necessary documents and instructions in an accepted language.
A distributor that finds a suspected non-conformity should stop the battery or battery-powered product from reaching the market until the issue has been corrected.
Private-Label Brand
Private-label buyers need to examine Article 44 closely.
An importer or distributor is treated as the battery manufacturer under the regulation when the battery is placed on the market under that company’s name or trademark. The same rule applies when the importer or distributor modifies the battery in a way that may affect conformity or changes its intended purpose.
A private-label agreement should state who prepares the battery technical file, who signs the EU declaration, who approves the battery label and who manages later component changes.
Battery Producer for EPR Purposes
The battery producer role is separate from the manufacturer and importer roles. The regulation’s producer definition can cover a manufacturer, importer, distributor or distance seller that first makes a battery available in a Member State, including a battery incorporated into an appliance.
One company may hold several roles. A private-label importer may be the importer, battery manufacturer and EPR producer at the same time.
2. Confirm That the Car Vacuum Uses a Portable Battery
A rechargeable battery pack used in a handheld cordless car vacuum will normally fall within the portable battery category. Article 11 applies to products incorporating portable batteries and covers the complete battery, not each lithium-ion cell inside the pack.
For a battery containing three 18650 cells, for example, the end user is expected to remove and replace the assembled battery module. The user is not expected to open that pack, separate welded cells or rebuild the cell group.
The Commission guidance describes the intended end user as an adult with no special battery-repair experience or related qualification. The removal process, instructions and user testing should reflect that profile.
Most ordinary cordless car vacuums should be planned around the general end-user removability rule. Product-specific legal advice may still be needed where a buyer believes a stated derogation applies.
3. Check Whether the Battery Is Readily Removable
A battery is considered readily removable when the end user can take it out with commercially available tools. A specialized tool can be used when it is supplied free with the product. Proprietary tools, solvents, and thermal energy should not be required.
Ask the supplier to demonstrate the following steps:
- Switch off the car vacuum.
- Release the battery lock or open the battery cover.
- Remove the complete battery pack.
- Inspect the connector and battery interface.
- Insert a compatible replacement pack.
- Lock the pack into place.
- Restart the vacuum and test every operating mode.
Questions to Ask During Sample Inspection
- Can the pack be removed by hand?
- Is a screwdriver or other common tool required?
- Is any special tool included in the retail package?
- Does the housing need to be cut, heated or broken?
- Are adhesives holding the pack inside the appliance?
- Can the battery be removed without pulling internal wires?
- Can the user touch exposed live contacts?
- Does removal damage the latch, seal or connector?
- Can the same process be repeated many times?
A hand-release pack provides a simple user experience, but a common-tool design may still meet the rule. The full design and removal method need to be assessed, rather than the marketing name used for the battery.
4. Confirm That the Battery Is Readily Replaceable
Removability and replaceability are separate tests.
A pack may come out easily but fail the replacement test when:
- The connector has changed
- The replacement pack does not fit
- Voltage or current output is wrong
- The battery management system is incompatible
- Charging no longer works
- Suction or motor speed changes
- The replacement creates a safety risk
- Firmware rejects the new pack
The 2026 Commission guidance states that a compatible battery should let the device operate as intended without creating a safety risk. Product and battery design should support both original batteries and compatible replacement batteries.
Software cannot block replacement with another compatible battery. Serial pairing that rejects a valid replacement or removes product functions can conflict with Article 11.
Test the spare battery in several finished units from the pilot batch. Do not rely on one engineering sample.
5. Set Up a Five-Year Spare Battery Plan
Article 11 requires compatible batteries to remain available as spare parts for at least five years after the last unit of the equipment model is placed on the market. Spare batteries must be offered to end users and independent professionals at a reasonable and non-discriminatory price.
This period starts after the last unit of the model is placed on the market, not after the first production order.
The supply plan should cover:
- Battery model number
- Battery housing and dimensions
- Connector drawing
- Cell configuration
- Nominal voltage
- Rated capacity
- Watt-hours
- Battery management system version
- Charging compatibility
- Spare battery package
- MOQ for later battery orders
- Expected storage quantities
- Warranty replacement stock
- Final product placement date
- Spare supply end date
The buyer and supplier should agree that battery connectors, locking points and pack dimensions cannot be changed without written approval.
Suggested Contract Wording
The supplier will maintain the approved battery interface, connector, housing and replacement-pack specification during the agreed service period. Any proposed component or structure change requires written approval from the buyer before production.
A legal adviser should review the final contract language.
6. Prepare Battery Removal Instructions and a Public Web Page
Products incorporating portable batteries must include instructions and safety information for battery use, removal and replacement. The information must remain permanently available online through a publicly accessible website and must be easy for end users to follow.
The page should contain:
- Car vacuum model
- Battery model
- Clear product and battery images
- Removal steps
- Replacement steps
- Required tools
- Connector inspection
- Charging instructions
- Compatible replacement specifications
- Safety warnings
- Storage guidance
- Waste battery handling
- Separate collection information
- Spare battery ordering method
Use the same battery model number on the pack, vacuum, retail box, user manual and website.
The Commission guidance recommends including the technical specifications that a compatible battery must meet. These details can cover chemistry, voltage, capacity, connector, physical size and safety requirements.
7. Review Battery Labels and Markings
Battery artwork should be reviewed before the retail box enters bulk printing.
CE Marking
Regulation (EU) 2023/1542 requires CE marking on batteries. Where direct marking is not possible or is not warranted from the battery’s nature, CE marking may be placed on the packaging and accompanying documents. Check the CE Certification Requirements for Wireless Car Vacuum Cleaners in the European Market.
Model and Traceability Information
The manufacturer must provide a model identifier plus a batch number, serial number, product number or another element that supports identification. Manufacturer contact information must appear on the battery or, where direct marking is not practical, on the packaging or accompanying document.
Separate Collection Symbol
All batteries have been required to have the separate collection symbol since 18 August 2025. When a battery is too small for the stated symbol size, the symbol may be printed on the packaging under the conditions set by Article 13.
General Battery and Capacity Labels
Article 13 states that general battery information labels and rechargeable portable battery capacity labels apply from the later of:
- 18 August 2026
- 18 months after the relevant implementing act enters into force
Buyers should keep the “whichever is later” wording in internal compliance schedules and check the latest implementing measure before printing final artwork.
QR Code from 18 February 2027
From 18 February 2027, all batteries must carry a QR code. For portable batteries outside the passport categories, the QR code must provide access to the applicable Article 13 information, the EU declaration of conformity and stated waste-battery information.
Where direct battery marking is not practical from the battery’s size or nature, the QR code may be placed on the packaging and accompanying documents.
Does a Car Vacuum Battery Need a Battery Passport?
A typical portable battery used in a handheld car vacuum does not need the formal battery passport. Battery passports apply to:
- LMT batteries
- Electric vehicle batteries
- Industrial batteries above 2 kWh
The car vacuum battery still needs the Article 13 QR code from 18 February 2027.
8. Check Restricted Substance Limits
Annex I sets limits for mercury, cadmium and lead in batteries:
| Substance | Maximum Content |
|---|---|
| Mercury | 0.0005% by weight |
| Cadmium in portable batteries | 0.002% by weight |
| Lead in portable batteries | 0.01% by weight |
The lead limit has applied to portable batteries since 18 August 2024, apart from the stated temporary exception for portable zinc-air button cells.
Ask the battery supplier for relevant test data, material declarations and component records. The battery regulation test package should be reviewed separately from finished-product RoHS reports.
9. Request the Correct Supplier Document Package
Importers should request a structured document set before approving mass production.
Battery Regulation Documents
- Battery technical documentation
- Battery specification sheet
- Applicable conformity assessment records
- EU declaration of conformity
- CE marking artwork
- Model and batch identification
- Manufacturer details
- Importer details
- Battery label artwork
- Capacity information
- QR code content
- Removal and replacement instructions
- Safety information
- Restricted substance test data
- Cell and battery-module supporting documents
Manufacturers must prepare technical documentation, complete the applicable conformity assessment, draw up the EU declaration of conformity and apply CE marking. They must retain the technical documentation and declaration for ten years.
Product and Transport Documents
A car vacuum project may require:
- Finished-product electrical safety report
- EMC report
- RoHS report
- Battery safety report
- UN 38.3 test summary
- Safety data sheet
- Transport classification
- Packing instructions
- Inspection report
- Bill of materials
- Component list
- Packaging vibration and drop records
A UN 38.3 report supports lithium battery transport. It does not replace the EU declaration, technical file, battery labels, producer registration or Article 11 design review.
10. Add Manufacturer and Importer Details to the Artwork
The battery manufacturer’s name, registered trade name or trademark, postal address and available web or email contact must appear on the battery. Packaging or an accompanying document may carry this information when direct battery marking is not practical.
The EU importer must provide its corresponding identification and contact details.
Use an artwork matrix before approval:
| Information | Battery | Vacuum | Retail Box | Manual |
|---|---|---|---|---|
| Battery model | Yes | Recommended | Yes | Yes |
| Battery capacity | Yes | Optional | Yes | Yes |
| Manufacturer details | Yes or alternate location | Optional | Yes | Yes |
| Importer details | Yes or alternate location | Recommended | Yes | Yes |
| Batch or serial code | Yes | Yes | Optional | Optional |
| CE marking | Yes or alternate location | Product rules apply separately | Yes | Yes |
| Separate collection symbol | Yes or packaging | Product symbols apply separately | Yes | Yes |
| QR code | Yes or permitted alternate location | Optional duplicate | Yes | Yes |
11. Complete Producer Registration and Battery EPR Planning
Each Member State must maintain a producer register. A producer must register in every Member State where it first makes a battery available on the market. This includes batteries incorporated into appliances.
The registration and EPR plan should identify:
- The legal battery producer
- Every target Member State
- Producer registration numbers
- Battery category and chemistry
- Producer responsibility organization
- EPR representative where required
- Battery weight reporting method
- Sales quantity reporting method
- Financial contributions
- Collection and recycling arrangements
- Marketplace registration checks
A producer selling batteries through distance contracts from another Member State or a third country must appoint an EPR representative in each Member State where it sells.
Battery EPR does not replace other possible duties. WEEE and packaging EPR may apply separately to the car vacuum and retail packaging.
12. Test the Car Vacuum and Replacement Battery Before Approval
A photo of a detached battery is not enough. The physical sample needs to pass functional, mechanical and packaging checks.
Battery Removal and Replacement
Test:
- Release force
- Removal time
- Number of steps
- Battery insertion direction
- Latch retention
- Repeated insertion and extraction
- Contact wear
- Incorrect insertion prevention
- Movement during operation
- Replacement pack compatibility
Electrical and Cleaning Performance
Record:
- Charging time
- Runtime at every operating mode
- Suction at every mode
- Motor startup
- Battery temperature
- Low-charge behavior
- Protection functions
- Performance with the spare battery
Packaging and Transport
Check:
- Product drop resistance
- Battery drop resistance
- Transport vibration
- Movement inside the retail box
- Protection of the battery release button
- Separation of accessories
- Label adhesion
- QR code scanning
- Carton markings
Article 41 permits importers to carry out sample testing based on battery risk. It requires importers to investigate non-conforming batteries and recalls where needed.
Kinzir’s OEM car vacuum manufacturing service includes sample production, insertion and extraction testing, button-life testing, transport vibration testing, final inspection and custom packaging. Kinzir states that its factory runs five production lines with a ten-person QC team and performs eight-hour endurance and insulation testing.
13. Add Battery Requirements to the Purchase Specification
The purchase order should refer to an approved specification containing:
- Battery model
- Cell model or approved equivalent
- Chemistry
- Cell configuration
- Nominal voltage
- Rated capacity
- Watt-hours
- Battery management system
- Connector drawing
- Battery housing drawing
- Release structure
- Runtime at each mode
- Charging input
- Label revision
- QR code revision
- Spare battery SKU
- Required documents
- Inspection limits
- Change-notification procedure
Add a rule that no cell, connector, battery management component or housing part may be substituted without written buyer approval.
A signed specification protects both sides when component availability, cell pricing or production schedules change.
14. Complete a Pre-Shipment Review
Run one final review before the balance payment and shipment release.
Product and Battery Check
- Correct removable battery structure
- Approved battery model
- Correct cell configuration
- Secure battery lock
- Working replacement pack
- Charging test passed
- Runtime test passed
- All suction modes passed
- Serial and batch records completed
Label and Packaging Check
- CE marking
- Battery model
- Capacity information
- Separate collection symbol
- QR code
- Manufacturer details
- Importer details
- Required languages
- Correct retail SKU
- Correct carton markings
Document Check
- EU declaration of conformity
- Technical documentation access
- Battery test records
- Product test records
- Removal instructions
- Public online information page
- Transport documents
- Producer registration numbers
- Inspection report
15. Keep Post-Market and Traceability Records
Importers must take corrective action where a battery is non-conforming. Depending on the case, this may involve correction, withdrawal or recall. Importers must inform the relevant market surveillance authority when the battery creates a risk.
Economic operators must be able to identify who supplied a battery and which business customers received it, including exact models and quantities. These records must remain available for ten years.
Keep the following records:
- Supplier and cell records
- Production batch records
- Customer shipment records
- Complaints
- Battery failure reports
- Corrective actions
- Product withdrawals
- Recall decisions
- Spare battery orders
- Label revisions
- Manual revisions
- Archived online instructions
Kinzir Removable Battery Solutions for EU Car Vacuum Projects
Kinzir offers several user-removable battery platforms for European importers, distributors and private-label brands. The range includes compact car vacuums, multifunctional vacuum and air-duster products, and a turbo jet fan that can form part of a wider automotive cleaning collection.
These products provide practical hardware platforms for EU 2027 planning. Final conformity depends on the approved battery, finished branded SKU, technical documentation, labels, instructions, importer information, EPR registration and target market.
Kinzir VC16R Swappable Battery Car Vacuum and Air Duster
The Kinzir VC16R cordless car vacuum cleaner with swappable battery pack is a compact 2-in-1 cleaner for vacuuming and dust blowing.
Its battery pack releases from the bottom of the handle without opening the motor housing. The complete module can be replaced by the user, creating a clear route for spare battery sales and battery-only warranty service.
A 45 mm BLDC motor provides three operating modes:
| Mode | Rated Output | Motor Speed | Suction | Runtime |
|---|---|---|---|---|
| Eco | 50 W | 50,000 RPM | 8 kPa | Up to 40 minutes |
| Standard | 70 W | 60,000 RPM | 12 kPa | Up to 25 minutes |
| Max | 90 W | 70,000 RPM | 20 kPa | Up to 15 minutes |
The VC16R has three 2,000 mAh cells, a 300 ml transparent dust cup and an estimated 2.5-hour charging time. OEM options include product color, logo, attachments, replacement filters, spare battery packs, manuals and retail packaging.
Suggested image placement: Show the complete VC16R beside the detached battery pack and nozzle set.
Kinzir VC26R Removable Battery Cordless Car Vacuum
The Kinzir VC26R removable battery cordless car vacuum cleaner combines car vacuuming and electric air-duster functions in one handheld unit.
A quick-release mechanism at the base of the handle lets the user detach the complete battery module by hand. The appliance does not need to be opened for routine battery replacement.
The VC26R provides 8 kPa, 12 kPa and 20 kPa suction settings through its 45 mm BLDC motor. Runtime ranges from approximately 15 to 40 minutes based on the selected mode. Its three-cell removable battery, 300 ml dust cup, USB-C connection and multiple cleaning nozzles make it suitable for car seats, floor mats, consoles, vents, keyboards and narrow gaps.
For private-label buyers, the VC26R supports:
- Branded product housing
- Custom color combinations
- Battery label artwork
- Spare battery sets
- Custom nozzle kits
- Multilingual instructions
- Ecommerce and retail packaging
- Batch and barcode customization
Suggested image placement: Use an image showing the VC26R in vacuum mode with the battery removed from the handle.
Kinzir VC80 3-in-1 Removable Battery Car Vacuum
The Kinzir VC80 removable battery 3-in-1 car vacuum combines three functions:
- Cordless car vacuum
- Electric air duster
- Mini turbo jet fan
Its 130,000 RPM BLDC motor provides eight adjustable settings. Vacuum pressure ranges from 2.5 to 7.5 kPa. In blowing mode, the VC80 produces concentrated airflow up to 65 m/s with approximately 190 gf of blowing force.
The removable battery contains two 4,000 mAh 21700 lithium-ion cells. The complete 8,000 mAh module can be released by hand. Runtime ranges from approximately 15 to 60 minutes, and the pack supports 5V/3A USB-C charging.
The VC80 suits brands seeking a premium car-cleaning product that can collect debris, blow dust from narrow areas and remove loose water droplets after vehicle washing. It can be sold with one battery, a spare-battery bundle or a larger accessory set.
Suggested image placement: Show the VC80 with its removable 21700 battery pack and separate vacuum and blower attachments.
Kinzir AD80 Removable Battery Turbo Jet Fan
The Kinzir AD80 removable battery turbo jet fan is not a car vacuum. It is a related removable-battery platform for brands building a broader automotive cleaning range.
The AD80 uses a 130,000 RPM BLDC motor with eight airflow settings, up to 65 m/s wind speed and approximately 190 gf of blowing force. Applications include car drying, dashboard and vent cleaning, keyboard cleaning, workshop dust removal and light outdoor work.
Its user-removable battery pack contains two 4,000 mAh 21700 cells. The complete 8,000 mAh module releases by hand, supports 5V/3A USB-C charging and provides approximately 15 to 70 minutes of operation according to the selected setting.
The AD80 can share visual branding, packaging themes and replacement-battery planning with a Kinzir car vacuum collection.
Suggested image placement: Use an image showing the AD80 with the battery separated from the handle and several airflow nozzles beside it.
Kinzir Removable Battery Product Comparison
| Model | Product Type | Motor | Main Performance | Battery | Runtime |
|---|---|---|---|---|---|
| VC16R | Car vacuum and air duster | Up to 70,000 RPM | Up to 20 kPa suction | 3 × 2,000 mAh cells | 15 to 40 minutes |
| VC26R | Car vacuum and air duster | Up to 70,000 RPM | Up to 20 kPa suction | 3 × 2,000 mAh cells | 15 to 40 minutes |
| VC80 | Vacuum, air duster and turbo jet fan | 130,000 RPM | Up to 7.5 kPa suction and 65 m/s airflow | 2 × 4,000 mAh 21700 cells | 15 to 60 minutes |
| AD80 | Air duster and turbo jet fan | 130,000 RPM | Up to 65 m/s airflow | 2 × 4,000 mAh 21700 cells | 15 to 70 minutes |
Final specifications should be confirmed against the approved sample and signed purchase specification.
How Kinzir Supports EU-Bound Private-Label Projects
Kinzir can support the hardware and production side of an EU car vacuum program through:
- User-removable battery structures
- Compatible spare battery packs
- Battery model and batch identification
- OEM battery label artwork
- QR code placement
- Custom housing colors
- Logo engraving and printing
- Multilingual manuals
- Battery removal instructions
- Retail and ecommerce packaging
- Sample and production testing
- Replacement battery supply planning
Read the EU Battery Regulation 2027 guide for car vacuums, air dusters and turbo jet fans for broader regulatory background.
For the meaning of end-user battery access, see the readily removable and replaceable battery guide.
For symbols, capacity labels and QR codes, read the EU battery labeling requirements guide.
Buyers planning logos, colors, motors, attachments and packages can review Kinzir’s custom OEM car vacuum cleaner options and OEM manufacturing service.
Common Mistakes Made by Car Vacuum Importers
Treating a Detachable Pack as Complete Compliance
Battery access is one requirement. Labels, instructions, technical documents, CE marking, spare supply, registration and traceability need separate review.
Failing to Define Legal Roles
A private-label importer may carry manufacturer, importer and EPR producer duties under the same program.
Confusing a QR Code with a Battery Passport
A portable car vacuum battery needs the Article 13 QR code from 18 February 2027. It will not normally fall within the formal battery passport categories.
Printing Packaging Too Early
A battery model, capacity, manufacturer address or QR content change can make printed boxes and manuals inaccurate.
Forgetting the Spare Battery SKU
A replacement battery needs its own model, price, package, label, stock plan and ordering channel.
Accepting Cell Substitution Without Review
A new cell can change capacity, runtime, heat behavior, label data, transport records and the technical file.
Ignoring National Producer Registration
EU product rules do not replace Member State producer registration and EPR procedures.
Keeping No Post-Market Records
Complaint, shipment, batch and corrective-action records may be needed years after the first sale.
Frequently Asked Questions
Does every cordless car vacuum need a removable battery from 2027?
Article 11 sets a general rule that portable batteries incorporated into products must be readily removable and replaceable by the end user from 18 February 2027. Limited derogations exist. Most normal handheld car vacuums should be planned under the general rule.
Must the battery come out without any tool?
No. Commercially available tools may be used. A specialized tool may be used when supplied free with the product. Proprietary tools, heat and solvents should not be required.
Can the end user replace individual cells?
The Article 11 end-user requirement applies to the complete portable battery, not the individual cells inside the pack.
Does a removable battery automatically make a car vacuum compliant?
No. The complete project must cover battery compatibility, spare supply, instructions, labels, technical documentation, conformity assessment, registration and the duties of the responsible economic operators.
How long must replacement batteries remain available?
At least five years after the last unit of the equipment model is placed on the market.
Does a cordless car vacuum battery need a QR code?
Yes. All batteries must carry a QR code from 18 February 2027. The regulation permits placement on packaging and accompanying documents when direct marking is not practical from the battery’s size or nature.
Does the battery need a battery passport?
A typical portable car vacuum battery does not fall within the battery passport categories. The formal passport applies to LMT batteries, electric vehicle batteries and industrial batteries above 2 kWh.
Does a private-label brand become the battery manufacturer?
It can. Article 44 treats an importer or distributor as the manufacturer when the battery is placed on the market under that company’s name or trademark, or when it makes a change that may affect conformity.
Is CE documentation from the supplier enough?
The importer must verify the declaration, technical documentation, conformity assessment, CE marking, labels, instructions and manufacturer details. The importer retains its own obligations after receiving the supplier’s files.
Does one EPR registration cover the whole EU?
No. Producers register in each Member State where they first make a battery available on the market.
Prepare Your 2027 Car Vacuum Program with Kinzir
Car vacuum buyers should begin the EU 2027 review before confirming molds, battery packs or retail artwork. Early planning reduces the risk of redesigns, unusable packaging, missing documents and unsupported spare battery promises.
Kinzir offers removable battery car vacuums, vacuum and air-duster combinations, turbo jet fans, custom branding, spare battery packs and private-label packaging. Browse the Kinzir cordless car vacuum range or contact Kinzir with your target countries, annual quantity, battery requirements, launch date and packaging brief.
References
- European Commission. (2026). Commission guidelines to facilitate the harmonised application of provisions on the removability and replaceability of portable and LMT batteries in Regulation (EU) 2023/1542 (Commission Notice C(2026) 5032 final). https://environment.ec.europa.eu/document/download/17491562-50cc-443a-897f-b50848ab0a8a_en?filename=C_2026_5032_1_EN_ACT_part1_v13.pdf
- European Parliament & Council of the European Union. (2023). Regulation (EU) 2023/1542 of the European Parliament and of the Council of 12 July 2023 concerning batteries and waste batteries, amending Directive 2008/98/EC and Regulation (EU) 2019/1020 and repealing Directive 2006/66/EC. Official Journal of the European Union, L 191, 1-117. https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng
