In the context of the rapid development of the global battery industry, the European Union, with its vast consumer market, has become a crucial strategic destination for battery exporters. However, with the continuous update of regulations and policies, companies exporting pure batteries to the EU are facing increasingly stringent requirements. Especially in 2025, the gradual implementation of the EU Battery Regulation and the official introduction of new Amazon platform rules have set new standards for battery exports. This article will closely focus on key elements such as “EU new regulations”, “UN38.3 certification”, and “Amazon compliance”, and deeply analyze the key factors for exporting pure batteries to the EU and selling them on the Amazon platform.

I. Core Points of EU New Regulations in 2025

(I) Key Contents of the EU Battery Regulation

1. Definition of the Regulation’s Scope of Application

The EU Battery Regulation has a wide coverage, encompassing various types of pure batteries used in portable electronic devices, electric vehicles, etc. Whether it is the common lithium – ion batteries or emerging solid – state batteries, as long as their target market is the EU, they must comply with this regulation. For example, small button batteries used in small devices like watches, and large – scale power batteries used in electric vehicles, all fall within the strict regulatory scope of the regulation. Different uses and specifications of batteries have differences in the application of specific clauses. Small portable batteries place more emphasis on safety and recycling requirements, while power batteries have more stringent regulations in terms of performance and durability.

2. Environmental and Safety Requirements

This regulation sets clear quantitative indicators for battery recycling. Companies must ensure that a certain proportion of batteries can be effectively recycled. They can achieve this by building their own recycling systems or collaborating with professional recycling agencies to recycle various metals and other materials in the batteries. In terms of safety, from the selection of raw materials in battery production, to the strict control of the production process, and then to the safety guarantee during the battery’s use, there are detailed regulations. For example, in response to the prevention and control of the battery’s thermal runaway risk, companies are required to take necessary measures during the battery design and manufacturing process to avoid safety accidents caused by overheating.

3. Market Access Conditions

For pure batteries to enter the EU market, they must meet a series of strict basic conditions. First and foremost, the products must comply with relevant safety, environmental protection, and other technical standards. On this basis, the responsibilities of importers and manufacturers have been re – clearly defined. Manufacturers are responsible for the entire process from product design to production, ensuring that products meet regulatory requirements and assuming the primary responsibility for product quality. Importers, on the other hand, need to conduct strict reviews of imported batteries to ensure their compliance and actively cooperate with regulatory authorities in supervision and inspection after the products enter the EU market.

(II) Key Points of Amazon’s New Rule 1 in July 2025

1. Platform Sales Qualification Requirements

Amazon has adjusted its qualification review direction for sellers of pure battery products. For large – scale sellers, it may require a more complete supply chain management system, covering aspects such as raw material procurement traceability and production process monitoring. Small – scale sellers, however, need to fully prove that their product sources are legal and their product quality is controllable. For example, large – scale sellers may need to provide detailed production process documents, raw material supplier qualification certificates, etc., while small – scale sellers need to provide purchase contracts, product conformity certificates, etc. Different qualification standards apply to sellers of different scales, aiming to comprehensively ensure the quality and compliance of pure battery products sold on the platform.

2. Product Labeling and Information Disclosure

For pure battery products sold on the Amazon platform, the labeling specifications are more stringent. Product labels must clearly mark key information such as battery type, capacity, and voltage, and there are clear requirements for details such as font size and color contrast. At the same time, sellers need to fully disclose to consumers information such as battery usage precautions, safety tips, and recycling information. For example, for batteries that may have a high – temperature risk, consumers must be clearly reminded to avoid using them in high – temperature environments.

II. Comprehensive Analysis of UN38.3 Certification

(I) Basic Understanding of UN38.3 Certification

1. Definition and Role of the Certification

UN38.3 certification is a safety certification specifically for lithium – based and other pure battery products during transportation. Its core purpose is to ensure through a series of rigorous tests that batteries will not cause safety problems due to factors such as vibration, impact, and temperature changes during air, sea, or other transportation. This certification plays a crucial role in ensuring the global safety of pure battery transportation and is a widely recognized battery transportation safety standard in many countries and regions.

2. Scope of Applicable Products

Almost all types of pure batteries need to pass the UN38.3 certification, including common lithium – ion batteries, lithium – metal batteries, and relatively rare lithium – polymer batteries, etc. Whether it is a small battery used in mobile phones, laptops, or a large – scale battery used in energy storage systems, it must obtain this certification before transportation.

(II) Detailed Explanation of the Certification Process

1. Pre – certification Preparation

Companies first need to comprehensively collect various materials. For example, a detailed battery specification sheet should cover parameters such as the battery’s chemical system, dimensions, and weight; a technical parameter table should include information such as the battery’s charge – discharge characteristics and internal resistance. Choosing a qualified testing laboratory is of vital importance. Factors such as the laboratory’s qualifications, equipment advancement, and tester professionalism need to be comprehensively considered. For example, a laboratory with internationally recognized qualifications, such as ISO 17025 certification, can usually provide more reliable testing services.

2. Testing Items and Standards

The main testing items include vibration testing, which simulates the vibration environment the battery experiences during transportation to check the stability of the battery structure; impact testing, which examines the safety of the battery when subjected to accidental impacts; and temperature cycle testing, which detects the performance stability of the battery under different temperature conditions, etc. Each testing item is carried out in accordance with corresponding international standards. For example, the vibration test is based on relevant standards of the International Electrotechnical Commission (IEC). The pass – judgment criteria clearly stipulate the allowable performance change range of the battery during the test, such as the voltage fluctuation range and whether a slight deformation of the battery appearance is allowed.

3. Certification Application and Review

When submitting an application to the relevant institution, companies need to prepare materials such as test reports and product manuals. During the review process, common problems include incomplete test data and discrepancies between the product manual and the actual product. Companies should ensure that the submitted materials are true, accurate, and complete. For problems feedback during the review, timely rectification should be carried out, and relevant materials should be supplemented to ensure a smooth review process.

(III) Post – certification Maintenance

1. Certificate Validity Period and Renewal

The UN38.3 certification certificate usually has a certain validity period, generally 1 – 3 years. When renewing, companies need to make preparations in advance, submit a renewal application, and may need to conduct some tests again to prove that the product continues to meet the certification standards. The renewal process is similar to the initial application, but special attention should be paid to submitting the latest product information and test data.

2. Responding to Regulatory Changes and Product Upgrades

When the UN38.3 standard is updated, companies should pay timely attention to the changes and comprehensively assess the impact on their products. It may be necessary to retest and re – evaluate the products to ensure compliance with the new standard requirements. After product upgrades, such as an increase in battery capacity or material improvement, it is also necessary to re – examine whether the certification requirements are still met, and re – apply for certification if necessary.

III. In – depth Interpretation of Amazon’s Compliance Requirements

(I) Account Registration and Maintenance Compliance

1. Truth and Completeness of Registration Information

When registering an Amazon account, the information related to the pure battery business provided by sellers must be true, accurate, and complete, including company information, product information, contact information, etc. Providing false information may lead to the suspension or closure of the account, seriously affecting normal sales. For example, if false production addresses or product specification information is provided and detected by Amazon, severe penalties will be imposed.

2. Meeting Account Performance Indicators

There are many performance indicators related to the sale of pure batteries. The order defect rate needs to be strictly controlled within a certain range, such as not exceeding 1%, to ensure product quality and customer satisfaction. In terms of logistics performance, timely shipping and accurate delivery should be ensured, and the on – time delivery rate should reach over 95%. Sellers can improve their account performance by optimizing supply chain management and strengthening communication and cooperation with logistics partners.

(II) Product Listing Compliance

1. Product Listing Specifications

The title of pure battery products should accurately reflect the product characteristics, such as “High – capacity Lithium – ion Mobile Phone Battery”, and exaggerated or misleading words are strictly prohibited. The description should explain in detail the devices the battery is applicable to, performance parameters, usage precautions, etc. The pictures should clearly display the product appearance, logo, etc., and should not contain any illegal content. Common non – compliance cases include exaggerating the battery’s battery life in the title and not mentioning key safety information in the description. Sellers need to rectify these problems in a timely manner.

2. Submission of Compliance Certification Documents

To sell pure batteries on the Amazon platform, compliance documents such as the UN38.3 certification certificate and product safety inspection report need to be uploaded. The file format usually requires PDF, and it is necessary to ensure that the documents are within the validity period. Products with expired certificates or incorrect file formats will not be able to be listed for sale normally.

(III) After – sales Service Compliance

1. Return and Exchange Policy

Amazon has a clear policy orientation for the return and exchange of pure battery products. The return and exchange process formulated by sellers should meet the platform requirements and fully consider the special nature of battery products. For example, for returns and exchanges due to product quality problems, the seller should bear the corresponding shipping costs and ensure that the returned batteries are properly disposed of to avoid environmental pollution.

2. Handling of Consumer Complaints

Common types of consumer complaints about pure battery products include insufficient battery life and abnormal charging. Sellers should establish a rapid response mechanism, communicate with consumers in a timely manner, and understand the details of the problems. For reasonable complaints, active solutions should be taken, such as providing replacement, refund, or technical support, to avoid account penalties due to improper complaint handling.

IV. Comprehensive Combing of Document Preparation

(I) EU Market Access Documents

1. Mandatory Documents

The CE certification certificate is a necessary document for pure batteries to enter the EU market. Companies need to conduct tests and certifications in accordance with relevant directives and harmonized standards. The EU authorized representative agreement is also of great importance. Companies need to appoint an authorized representative within the EU to be responsible for communication and coordination with regulatory authorities. When handling these documents, it is necessary to ensure the authenticity and timeliness of the documents. For example, the CE certification certificate must be issued by a qualified certification institution and be within the validity period.

2. Supplementary Documents

The battery safety data sheet should record in detail information such as the chemical properties and safety characteristics of the battery, providing guidance for transportation, storage, and use. The product manual should be written in the official languages of the EU, clearly explaining product performance, usage methods, safety precautions, etc. These documents play an important role in EU customs inspections, market supervision, etc., and can effectively prove the compliance and safety of the products.

(II) Amazon Platform Documents

1. Sales Qualification Certificates

Sellers need to obtain and submit to Amazon sales authorization documents for pure battery products, such as manufacturer’s authorization letters, brand authorization letters, etc. The qualification certificates corresponding to different battery categories may vary. For example, imported brand batteries may require authorization from the brand owner, while self – owned brand batteries need to provide production qualification certificates, etc.

2. Compliance Declaration Documents

The compliance statement required by Amazon should include a clear statement that the product complies with relevant regulations and standards, such as compliance with the EU Battery Regulation and UN38.3 certification requirements. The statement should be filled in according to the specified format, signed by the company’s responsible person, and ensure the authenticity and accuracy of the content.

V. Identification of Responsible Entities and Risk Avoidance

(I) Clear Definition of Responsible Entities

1. Manufacturer’s Responsibilities

Under the EU new regulations and Amazon’s compliance requirements, manufacturers bear primary responsibility for product quality. From the product design stage, regulatory requirements must be fully considered to ensure the safety and environmental friendliness of the battery. During the production process, strict quality control should be carried out, using qualified raw materials and following established production process standards. If safety accidents or other problems occur due to non – compliant products, manufacturers will face serious legal consequences, such as huge fines and product recalls.

2. Importer’s Responsibilities

Importers are responsible for the customs clearance process to ensure the legal entry of goods into the EU market. They need to conduct strict reviews of product compliance and require manufacturers to provide relevant certifications and documents. In terms of market supervision, importers should actively cooperate with regulatory authorities. If problems occur with the products, they may bear joint liability. Importers can effectively reduce their risks by signing detailed contracts, clarifying the division of responsibilities with manufacturers, and requiring manufacturers to provide quality guarantees.

3. Amazon Seller’s Responsibilities

During the platform sales process, sellers need to ensure the compliant operation of their accounts, the compliance of product listings, and the timely handling of consumer complaints. Compliant operation not only helps maintain the platform ecosystem but also effectively protects their own interests. For example, if an account is blocked due to non – compliant operations, it will bring huge economic losses to sellers.

(II) Risk Avoidance Strategies

1. Regulatory Tracking and Response

Companies should establish a sound regulatory tracking mechanism, closely monitor regulatory updates released by EU official websites, industry associations, etc. Regularly collect and deeply analyze regulatory changes, and promptly adjust internal management and product strategies. Once regulations change, companies should comprehensively evaluate the impact on their own businesses, such as whether re – certification is required, product design needs to be adjusted, etc., and formulate corresponding response plans.

2. Strengthening of Internal Management

Establish and improve a quality control system, conduct full – process quality control from raw material procurement, production process monitoring to finished product inspection. Strengthen employee training, regularly organize regulatory training, business skills training, etc., to effectively improve employees’ compliance awareness and operational capabilities. For example, train employees responsible for product certification on the UN38.3 certification standards and train sales staff on Amazon platform rules.

The changes in the EU new regulations and Amazon platform rules in 2025 undoubtedly bring challenges to battery – exporting companies, but at the same time, they also provide opportunities for companies to improve product quality and compliance levels. Only by deeply understanding the relevant requirements, carefully preparing documents, clarifying the responsible entities, and actively avoiding risks can companies develop steadily in the EU market and on the Amazon platform. It is hoped that this article can provide comprehensive and practical guidance for relevant companies and help them smoothly carry out their battery export business.