Before the request
Identify the model, variant, pack manufacturer and cell supplier.
- Define who supplies each field and in which format.
- Specify the expected document, version and response date.
Control for the European operator
DPP software for EU importers: from supplier data to the passport.
NexusDpp assigns suppliers the fields within their competence while keeping checks, corrections, approval, publication and registration under the EU importer’s control.
Non-EU suppliersCountersignaturePublication gateEU Registry
Batteries from China and other non-EU countries
Battery importers: prepare a data request you can verify.
Start by agreeing a precise list of information, evidence and contacts with the pack manufacturer and other relevant suppliers.
During collection
Compare the technical records, test reports and serials received.
- Link evidence to the relevant model and units.
- Assign each follow-up request to a named owner.
Before publication
Plan an explicit review by the authorised person.
- Check completeness, consistency and data visibility.
- Agree how future deliveries and revised documents are handled.
Scope and responsibility depend on the product and the company’s actual role. Collecting data does not replace checking the applicable requirements.
The EU Registry is live
DPP registration can be integrated into the importer workflow.
Since 20 July 2026, the EU Registry has provided a secure user interface and API. Where product legislation requires a DPP, NexusDpp can coordinate data approval, identifiers, metadata submission, error handling and electronic proof of registration. A live Registry does not, however, make a DPP mandatory for every product; scope depends on the applicable legislation.
How the Registry worksDPP caseImported product · N24
EU importer- ✓Request sent to manufacturerAccess limited to relevant dataCompleted
- ✓Documents and data receivedSource, version and date recordedCompleted
- 3Importer reviewCorrections and additions in progressIn review
- 4Approval and countersignatureGate before publication and registrationWaiting
The importer’s challenge
Collecting information properly means being able to demonstrate compliance with confidence.
Technical sheets, composition, origin, certificates and conformity evidence are collected in one process, with coordinated versions and systematic checks.
- Repeated requests and long lead times with distant suppliers.
- Missing fields discovered only at the end of the process.
- Difficulty linking each document to the correct model, batch or component.
- Regulatory pressure and commercial risk concentrated on the EU operator.
Legal responsibility
The importer plays a direct role in product compliance.
For consumer products, Article 11 of Regulation (EU) 2023/988 sets out general obligations for importers. These are complemented by Regulation (EU) 2019/1020 on market surveillance and by the rules applying to the specific product category.
Checks before placing on the market
Verify that the manufacturer has fulfilled the applicable obligations, that the product is identifiable and that the required documentation, instructions, warnings and safety information are available.
Blocking non-compliant products
Where there are reasons to believe that a product is dangerous or non-compliant, the importer must suspend its placing on the market and initiate the required corrective measures.
Importer identification
The importer’s name or trade name, postal address and any electronic contact details must appear on the product, packaging or accompanying documents, in accordance with the applicable rules.
Storage and transport
Storage and transport conditions under the importer’s responsibility must preserve product safety, integrity and compliance.
Traceability and authorities
The importer must retain the necessary information, manage reports and complaints, cooperate with authorities and provide data and documents useful for market surveillance.
Products under the importer’s own brand
An operator marketing a product under its own name or trademark, or substantially modifying it, may assume the manufacturer’s obligations under Article 13 of Regulation (EU) 2023/988 and the applicable sector legislation.
Penalties and risks
Across Europe, infringements can have a significant economic and operational impact.
Regulation (EU) 2023/988 requires Member States to apply effective, proportionate and dissuasive penalties. Amounts and measures vary according to the country, product category and seriousness of the infringement.
Administrative and financial penalties
Penalties may apply to dangerous or non-compliant products, inadequate documentation, missing information, failure to meet traceability obligations or failure to cooperate with authorities.
Sales restrictions or suspension
Authorities may require corrective action, suspend marketing, prohibit making the product available, or order withdrawal or recall.
Operational and reputational costs
Relabelling, new testing, replacements, reverse logistics, contractual disputes and loss of trust can have a greater impact than the penalty itself.
Operational risks
Non-compliance can stop the product.
Beyond financial consequences, an authority’s measure can interrupt distribution and require rapid action on products already placed on the European market.
- Suspension of sales and distribution delays.
- Costs for verification, rework, relabelling, withdrawal or recall.
- Lost orders, contractual disputes and reputational damage.
- Greater exposure of the EU operator to authorities, distributors and customers.
NexusDpp method
Request → Collect → Validate → Approve → Publish.
The workflow distributes the work while maintaining control, accountability and visibility over the process. Each party sees only what it must complete, approve or verify.
Secure invitation
The supplier receives dedicated access and a precise request for a product or model.
Guided completion
Fields, units of measure, required attachments, deadlines and instructions in the project language.
Completeness checks
The platform flags omissions, invalid formats, expired documents and inconsistencies.
EU approval
The importer reviews, requests corrections and authorises progression to the next status.
QR or NFC
Unique identifier and data carrier associated with the product, batch or individual unit.
Updates over time
Versions, document changes, recalls, support and end-of-life events remain connected.
Legal references
Articles cited
- Regulation (EU) 2023/988, Article 11 — obligations of importers
- Regulation (EU) 2023/988, Article 13 — cases in which manufacturer obligations apply to other operators
- Regulation (EU) 2023/988, Article 44 — penalties set by Member States
- Regulation (EU) 2019/1020 — market surveillance and product compliance
Optional module
Explore the module
Trade Compliance for international supply chains and shipments
Document counterparty screening, final destination, end users, clauses and logistics documents in one audit trail.
Importing finished batteries into the EU?
Connect manufacturer documents, supplier corrections and approval to the individual battery. Explore Battery Passport software for EU importers, then scope a battery pilot with your supplier to test the information flow on a defined sample.