Battery Labelling: QR Code, Symbols and CE Marking

The battery passport is digital, but its door is physical: the QR code on the battery. Article 13 and Annex VI of the EU Battery Regulation (EU) 2023/1542 govern that door and the label elements around it; these duties arrive in stages and start before the passport itself; CE marking sits separately in Articles 19 and 20.

This article puts every element, battery type and date into one table and explains what the QR opens outside passport scope. Print quality and code size are covered in DPP QR code: size, placement and print.

Label elements and dates

The general information label carries: manufacturer details, battery category, place and date of manufacture, weight, capacity, chemistry, hazardous substances other than mercury, cadmium and lead, the usable extinguishing agent, and critical raw materials above 0.1% by weight. The harmonised format of the label is set by an implementing act; track its publication status.

What the 2027 QR code opens

The QR code is mandatory on all batteries, but its target depends on the category:

• LMT, industrial above 2 kWh and EV batteries: the battery passport. For scope see which batteries, who is responsible.
• Other batteries: the label information, the EU declaration of conformity, the due diligence report and information on the prevention and management of waste batteries.
• SLI batteries: additionally the recycled content information under Article 8.

Annex VI Part C requires the code to be 100% black and of a size easily read by the readers built into common phones. Article 13 requires labels and the QR code to be printed or engraved on the battery visibly, legibly and indelibly; where the nature and size of the battery do not allow it, the label goes on the packaging and the accompanying documents.

Unlike ESPR, which allows QR, Data Matrix or NFC, the Battery Regulation specifically asks for a QR code. A laser-engraved metal housing must therefore carry a QR; the durability rules in Data Matrix and direct part marking still apply to the engraving. Encode a GS1 Digital Link URI, keep the code static and manage change in the resolver layer. The access principles (free, app-free, phone-readable) are those of EN 18220.

CE marking and the declaration of conformity

A battery undergoes conformity assessment before it is placed on the market and the manufacturer draws up an EU declaration of conformity. CE marking follows Articles 19 and 20: it is affixed to the battery visibly, legibly and indelibly; where that is not possible, to the packaging and documents. Where a notified body was involved in the production control phase, the CE marking is followed by that body's identification number. Annex VIII sets the assessment module; carbon footprint and recycled content requirements involve a notified body.

Market surveillance checks all three together: is the label present, does the QR resolve, does the declaration of conformity identifier match the passport. For enforcement practice see market surveillance and DPP enforcement.

Common label design mistakes

1. A small code on LMT packs: shrinking the module because the surface is narrow kills readability; see passports for LMT batteries.
2. Low contrast on a black housing: a light label area or white fill is essential.
3. The code on a removable cover: replace the cover and the passport is lost; put the code on the body.
4. Competing QR codes: a marketing QR next to the passport QR means consumers scan the wrong one. The single-carrier, multiple-link-type approach is explained in CLP digital labelling.
5. No durability test: scan the code after heat, vibration and electrolyte contact.

For the full timetable see the battery passport guide.

Frequently asked questions