Why am I legally considered a battery manufacturer if I'm an importer?

The Battery Act and the EU Battery Regulation tie manufacturer obligations not to production but to first placing a battery on the EU market. Whoever imports goods from a third country and makes them available for the first time automatically assumes the role of manufacturer — including responsibility for safety, take-back and recycling. This may feel unfamiliar to companies that see themselves purely as traders, but the logic is consistent: someone must take responsibility for product stewardship, and that is whoever first brings the goods to the European market. Early registration prepares you for exactly that.