CE Marking and a Lithium Pack: Who Is Responsible in the EU?

TalkOctober 26, 2026Redway Tech Editorial TeamTopic: Certification, Quality & Factory
CE Marking and a Lithium Pack: Who Is Responsible in the EU – Redway Tech Talk
Buyer question / scenario

A company imports lithium forklift batteries into the EU. A customer asks who holds the CE documents for the battery, what the importer has to check, and what the truck maker is responsible for.

Main answer

In general, the manufacturer is responsible for designing and building the battery to meet the applicable EU requirements and for the supporting documents; the importer must check that those documents exist and that the product carries the required marking and identification before placing it on the EU market; and the truck maker is responsible for the truck as a whole. Which rules apply to your battery depends on its type and date, so confirm them with an EU adviser. Redway can discuss the documents available for your model with sales.

Who usually does what

  1. Manufacturer. Designs the pack, carries out the conformity steps that apply, prepares technical documentation and an EU declaration of conformity where required, and puts the required marking and identification on the product.
  2. Importer. Brings the product into the EU market. In general it checks that the manufacturer has done its part, holds a copy of the declaration and documents, and puts its name and address on the product or packaging.
  3. Truck maker or integrator. Is responsible for the truck as a finished machine, including how the battery is installed and how it interacts with the truck’s safety systems.

What to ask for

  1. The declaration of conformity and a list of the rules it refers to, matching your exact model.
  2. Labels and markings as they will appear on the product you receive.
  3. Transport test documents, covered in our UN 38.3 article.
  4. Instructions and safety information in the languages you need.

Redway holds relevant qualifications and certifications for its batteries; details are available from sales on request. The EU is phasing in its new Battery Regulation, so check which requirements apply to your product on the date you place it on the market. Redway’s compliance documentation page and the Germany case page give background.

Keeping records

Keep a file for every model with the declaration, labels, instructions and transport summary, and update it when the design changes. Agree with the supplier who informs whom about design changes. A short checklist at each order helps the importer to show it has checked the product.

Risk limits

This article is a general overview, not legal advice. Rules, dates and duties change, and they depend on the product type and the role you play. Take advice from a qualified EU compliance adviser before importing.

Additional perspectives

Importer perspective

Build a one-page file per model: declaration, label photo, instructions and transport summary. Ask the factory for these before the first order, and keep them for the period your adviser recommends.

Redway Tech Editorial Team – Importer perspective

Truck maker perspective

Do not assume a battery’s documents cover the truck. Check how the pack is mounted, how it connects to the truck’s safety circuits and whether the truck’s own documents mention it.

Redway Tech Editorial Team – Truck maker perspective

Compliance adviser perspective

Define your role first: manufacturer, importer or distributor. The duties differ, and many problems start from a company assuming someone else has done the checks.

Redway Tech Editorial Team – Compliance adviser perspective

Specifications are taken from Redway product pages as of October 2026. Where a figure isn’t published, this article says so. Confirm current specifications for your model with Redway before ordering. This article is general guidance, not a site-specific engineering assessment.

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