Authorised Representative service supports engineering businesses exporting batteries to the EU

Hold Tech Files Ltd is extending its EU Authorised Representative
service for engineering businesses. This will be of interest to machine
builders, system integrators and panel builders who incorporate
batteries within products exported to the EU. These might be industrial
or portable batteries for general use, including button cells and
standard lower-capacity batteries. Appointing Hold Tech Files as an
Authorised Representative helps exporters comply with the new EU Battery
Regulation 2023/1542 that entered into force in August 2023 and has been
applied since February 2024.

For several years, Hold Tech Files has offered an EU Authorised
Representative (EUAR) service to aid compliance with Regulation
2019/1020 on market surveillance. The company is now extending its offer
to support engineering businesses that must comply with the Battery
Regulation. Based in the Republic of Ireland, Hold Tech Files can act as
an EUAR and perform certain tasks on behalf of non-EU businesses.

EU Battery Regulation 2023/1542 (EU BR) applies when batteries are
placed on the market or put into service in the EU, whether on their own
or incorporated within products. The scope encompasses all categories of
battery, with various requirements and deadlines for each. Nevertheless,
the EU BR is largely ‘technology agnostic’ and does not set out
different rules for each battery chemistry.

Engineering firms will mainly be concerned about the clauses relating to
industrial and portable batteries, including general use types such as
button cells, D, C, AA, AAA and PP3 batteries. If a firm incorporates
any of these within a product, then the EU BR considers the firm to be a
‘producer’.

Other categories of battery in the EU BR are EV (electric vehicle)
batteries, vehicle SLI (starting, light and ignition) batteries, and LMT
(light means of transport) batteries. However, Hold Tech Files is not
currently offering an EUAR services for these.

Note that if another type of battery has been repurposed for industrial
usage, it becomes an ‘industrial battery’. Also, the EU BR excludes
batteries for defence and space applications.

Under the EU BR, producer obligations relate to, for example, labelling,
instructions, documentation, take-back of waste batteries, annual
reporting, and registration with national authorities. Battery
manufacturers and firms repurposing used batteries have additional
obligations, but these are irrelevant for most engineering businesses
exporting products that incorporate batteries.

In line with the EU’s New Legislative Framework (NLF), the EU BR covers
the roles and responsibilities of economic operators. EU authorised
representatives can be mandated to perform certain tasks on behalf of
the producer. As a minimum, the mandate must cover the following:
retention of the Declaration of Conformity, technical documentation,
verification report, approval decision and audit reports for at least
ten years; provision of information and documentation requested by
national authorities; and co-operation with national authorities on
action taken to eliminate risks. Where batteries present a risk, EUARs
must notify the market surveillance authorities.

Hold Tech Files Ltd is based in the Republic of Ireland and acts as an
EUAR for non-EU businesses. The company operates a self-service online
portal where customers can sign a mandate, pay a fee and upload relevant
files to a secure server. Hold Tech Files then reviews the documentation
and, if acceptable, sends the customer a report stating that the company
is prepared to act as an EUAR. This entitles the customer to name Hold
Tech Files on the DoC. Customers can choose to pay for ten years or
annually.

For more information, go to www.holdtechfiles.eu [1] or email
derek@holdtechfiles.eu

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