Lithium batteries
Import batteries into the EU in 2027 without risking seizure or penalty!
Customs compliance, battery passport, supply chain due diligence, dangerous goods class 9, CE marking. One firm, five regulatory layers, zero blind spots.
EU Battery Regulation 2023/1542 changes everything. Most importers don't know it yet.
From 18 February 2027, every battery placed on the European market must have a digital passport accessible via QR code. Labelling obligations already entered into force in 2026. The supply chain due diligence duty for lithium, cobalt, nickel and natural graphite has been postponed to 18 August 2027 by Regulation 2025/1561 — a postponement, not an exemption.
In parallel, the reform of the Union Customs Code, on which political agreement was reached on 26 March 2026, deeply transforms declaration obligations, and the UN codes UN 3556, UN 3557 and UN 3558 have replaced UN 3171 for lithium-ion, lithium metal and sodium-ion battery vehicles since 1 January 2026.
Direct consequence: Belgian importers of e-bikes, e-scooters, scooters, replacement batteries, stationary storage and consumer electronics face five regulatory layers that do not communicate with each other — and none of them gives you a second chance under inspection.
One offer. Five expertises. No blind spots.
01
EU Battery Regulation 2023/1542
Labelling 2026, QR code 2027, battery passport, performance and durability.
02
Supply chain due diligence
Mapping of cobalt, lithium, nickel, graphite. Due diligence policy compliant with Regulation 2025/1561.
03
Dangerous goods transport class 9
UN 3480, UN 3481, UN 3090, UN 3091, UN 3536, UN 3551, UN 3552, UN 3556, UN 3557, UN 3558. IATA-DGR, ADR and IMDG compliance, UN 38.3 packaging.
Dangerous goods transport is not only about batteries. See our ADR, IMDG and IATA DGR page.
04
General customs
HS tariff classification, preferential origin, customs value, duties, CBAM, e-commerce handling fee.
05
Product conformity & CE marking
EU Declaration of Conformity, market surveillance, complete documentary traceability.
Today, your freight forwarders cover layer 4. Your engineering office covers layer 5. No one covers layers 1, 2 and 3. That is your importer responsibility — we make it our profession.
Who it is for
For importers who cannot afford a seizure at Liège or Antwerp.
1
Light electric mobility importers
E-bikes, scooters, mopeds, e-motorcycles, replacement batteries. Sourcing from China, Vietnam and Poland. From the independent distributor to the industrial group.
2
Stationary storage operators
Residential and industrial batteries, BESS for solar panels. Integrators and installers, from the engineering firm to the national group.
3
Electronics e-commerce
Marketplaces and pure players reselling electronics with embedded batteries: drones, cordless tools, vaping, audio, toys.
The 3 levels
Three entry points. One logic.
Level 1 — Ready-to-Import Battery Assessment
Who it’s for: You’re learning about your 2027 compliance requirements or have just undergone an inspection.
- Mapping of up to 10 SKUs
- Gap analysis across the 5 layers
- Prioritized risk matrix
- Costed 90-day action plan
- 1.5-hour oral presentation
- 30-day hotline included
Duration: 10 working days Price: Quote on request
Level 2 — Battery Compliance Package
Who it’s for: You want to be fully compliant across your entire catalog by February 2027.
- Full compliance for up to 50 SKUs
- Battery passport files ready to upload
- Due diligence policy + initial report
- Labeling and CE marking compliance
- Turnkey internal procedures (SOPs)
- Carrier briefing and internal training
- 6-month post-delivery hotline
Duration: 4 to 6 months Price: Quote on request
Level 3 — Battery Watch Retainer
For whom: you want to maintain compliance without hiring in-house staff.
- Monthly battery regulatory monitoring
- Unlimited hotline support
- Battery passport updates
- Annual compliance audit
- Quarterly governance review
- 48-hour alert on significant regulatory changes
Duration: minimum 12-month commitment Price: Quote on request
Why CTB Group
A Belgian firm founded by a customs specialist trained at the University of Liège, rooted where your batteries enter Europe.
University training in customs University certificate – Customs specialisation, University of Liège (Tax Institute). The six courses taken are the customs courses of the specialised master's in tax law – Customs Compliance, a programme recognised by the European Commission (EU Customs Certificate of Recognition).
Strategic Belgian anchorage Brussels presence, expertise in Liège Airport and Antwerp flows, direct relations with the Belgian Customs Administration.
Reproducible methodology Standardized diagnostic, documented deliverables, reusable SOPs.
Multilingual service
Frequently Asked Questions.
The questions all importers ask us.
Your freight forwarder manages transportation logistics (Layer 4) and, in some cases, customs declarations (Layer 1). However, the Battery Passport, supply chain due diligence, and product compliance requirements fall outside their core responsibilities. These are legal obligations of the importer.
In the event of a customs inspection, product compliance audit, shipment detention, or market surveillance investigation, it is the importer—not the freight forwarder—who is held liable.
Yes.
Under EU Battery Regulation (EU) 2023/1542, the Battery Passport becomes mandatory from 18 February 2027 for:Light Means of Transport (LMT) batteries (e-bikes, e-scooters, electric mopeds);Industrial batteries above 2 kWh;Electric vehicle (EV) batteries.
Preparing a compliant Battery Passport typically requires 3 to 6 months of supplier data collection, validation, and documentation. If you start preparing in January 2027, you are already behind schedule.
The average financial impact ranges from €8,000 to €25,000, including:Customs duties and taxes;Administrative penalties and fines;Expert assessment costs;Storage and immobilization charges;Commercial losses due to delayed market access.
This estimate does not include the potential registration on customs monitoring lists, which may significantly increase future inspections and compliance controls.
Yes.
The EU Battery Regulation applies to any battery placed on the EU market, regardless of where it is manufactured.
In addition, the due diligence obligations apply to the sourcing of raw materials, which are almost always sourced outside the European Union—even when battery cells are manufactured in Germany, Poland, or other EU countries.
There is no standard amount: the cost depends on each case. It usually combines the duties and VAT to be regularised, storage and demurrage costs, a possible fine and the commercial loss. In Belgium, for an unintentional error where the customs debt does not exceed €10,000, the law provides for an administrative fine of €250 to €5,000; above that, or in case of intent, criminal penalties apply. Irregularities that are found also feed into customs risk analysis, which can increase the frequency of later inspections.
Sources: Regulation (EU) No 952/2013, Union Customs Code, Article 46 ; Belgian General Law on Customs and Excise, Article 266/3, inserted by the Law of 14 April 2024.
Step 1: Initial scoping meeting (1-hour video conference).
Step 2: You securely share your documentation through a protected workspace, including:Commercial invoices;Bills of lading;Technical datasheets;Product and label photographs.
Step 3: Our experts perform a detailed compliance assessment within 5 to 7 business days.
Step 4: We deliver a 90-minute debriefing session and provide a written compliance report.
Total turnaround time: Approximately 10 business days from start to finish.
No.
We are a customs compliance, battery regulation, and pre-conformity consulting firm.
For customs representation services in the strict legal sense, we coordinate with trusted Belgian customs brokers and freight forwarding partners.
You keep your existing freight forwarder; we provide the compliance expertise, regulatory framework, and risk management tools they typically do not offer.
You import batteries. You want to know where you stand.
Book a free 30-minute scoping call. No obligation. By the end, you’ll know exactly which regulatory requirements apply to you, and we’ll know if we can help.
What is included, and what is not
What is included
- The analysis of your flows against the requirements specific to your industry: classification, origin, customs value, documents and authorisations.
- A map of the regulatory obligations that genuinely apply to your products.
- Preparation of the files intended for your declarant and your partners.
- Reusable deliverables: matrices, procedures and action plans your teams keep.
What is not included
- Lodging customs declarations, handled by the representatives your company appoints.
- Laboratory analyses, testing and certification: we prepare the files, accredited bodies remain solely competent.
- Transport, warehousing and handling: we coordinate your providers, we do not replace them.
- Guaranteeing the accuracy of data supplied by your suppliers: we flag inconsistencies, we do not certify them.
Authorisations concerned
For this sector, these are the statuses and authorisations that come up most often. The applicant is always the company; we prepare the file.
- Binding tariff information (BTI) — to secure a contested classification
- EORI number — a prerequisite for any import or export operation