A market-access timing term for the first use of a product or battery for its intended purpose in the Union.
Putting into service matters because some obligations attach when a product begins intended use, not only when it is supplied or first made available. It helps distinguish market-entry timing from commissioning, installation, configuration, or operational deployment.
ESPR and the EU Battery Regulation both use putting-into-service language around first use for the product or battery’s intended purpose in the Union. Read it with placing on the market and making available on the market: those terms concern supply and first market availability, while putting into service concerns first intended use.
Regulation (EU) 2024/1781 establishing a framework for the setting of ecodesign requirements for sustainable products
the first use, for its intended purpose, in the Union, of a product;
Reference: Article 2, point 41
Regulation (EU) 2023/1542 concerning batteries and waste batteries
the first use, for its intended purpose, in the Union, of a battery, without having been previously placed on the market;
Reference: Article 3, point 18
Putting into service is the first use of a product or battery for its intended purpose in the Union under the relevant source rule. It is a market-access timing trigger tied to operational deployment, not the same event as placing on the market or making a product available for supply.
Implementation records should capture the first-use event, intended-purpose record, installation or commissioning evidence, operational date, Union-use context, responsible actor, and readiness of passport, conformity, or operating records before first intended use.
Putting into service is a first-use timing control: the evidence consequence is that legal milestones can be aligned with deployment records rather than treated as identical to supply, sale, placing on the market, or making available.
EU product regulation uses a layered actor model: manufacturer → authorised representative → importer → distributor → economic operator (umbrella). Each actor in this chain has different obligations, and the applicable obligations depend on which regulation is in play. A company should determine its actor status independently under each applicable regulation, as the same entity can be a manufacturer under one regulation and a distributor under another.