The QR code on a battery is a mandatory data carrier under the Battery Regulation (EU) 2023/1542, Article 13. From 18 February 2027, all batteries must carry a QR code. On EV batteries, LMT batteries and industrial batteries over 2 kWh, it links directly to the battery's digital battery passport.

On other batteries, the QR code gives access to the labelling information, the EU declaration of conformity, the due diligence report and the information on the prevention and management of waste batteries. The code must be printed or engraved visibly and legibly and must be indelible.

What does the regulation require for physical labelling?

Article 13 states that all batteries must be labelled with a range of information, including the manufacturer's name, the battery category, the model identifier and the date of manufacture. If the size of the battery makes it impossible to apply all the information directly, the labelling must instead appear on the packaging and in the accompanying documents.

The QR code is a central new element:

  • For EV, LMT and industrial batteries over 2 kWh, it must link to the digital battery passport.
  • For other batteries, such as portable batteries, SLI batteries and industrial batteries under 2 kWh, it must give access to the labelling information, the EU declaration of conformity, the report on the due diligence policy and the information on the prevention and management of waste batteries. For SLI batteries also the recovered content of cobalt, lead, lithium or nickel.

The code must be printed or engraved visibly and legibly and must be indelible: this is a direct requirement in Article 13(7). If that is not possible because of the battery's nature and size, it is placed on the packaging and in the documents accompanying the battery.

A draft of the harmonised labelling specifications (an implementing act under Article 13(10)) was notified to the WTO in December 2025 and contains rules on:

  • Minimum size (at least 5% of the battery's largest printable surface, up to a maximum of 2.5 x 2.5 cm for icons)
  • Typeface (Noto Sans or equivalent to support all EU languages)
  • Contrast (high contrast for accessibility)

Where should the QR code be placed?

The QR code must be placed on the most visible side of the battery during normal use. For battery packs with several modules, it must be on the external battery housing, but manufacturers may also label the individual modules internally to make traceability easier during repair or recycling.

For integrated batteries (smartphones, e-scooters, medical devices), specific rules apply: if the battery is not visible without disassembly, the QR code must be placed on the surface of the product or appear in the digital user interface and the manual.

For button cells, where the surface area is extremely limited, the regulation allows the labelling to be placed on the packaging or in the accompanying documents, provided the QR code still gives access to all mandatory data.

The technical link to the battery passport

The QR code acts as the technical key to the battery passport. At its core is the unique identifier (UID) assigned to each individual battery, which follows it throughout its life cycle, even if it changes owner, is repaired or is converted for a second-life purpose.

The regulation requires the UID system to be based on open standards to ensure interoperability:

  • ISO/IEC 15459 for unique identification
  • GS1 Digital Link, which turns the QR code into a web address

GS1 Digital Link makes the code future-proof: if the underlying database is moved, the link can be updated centrally without changing the labelling on batteries already in use.

The battery passport system is decentralised (Article 78). The Commission is not building one central database. Instead, the manufacturer or importer is responsible for hosting the battery passport data, either on its own servers or via a certified provider.

The EU is establishing a central register of the unique identifiers, which acts as an indexing service: it contains the UID and a link to where the full battery passport can be found.

The decentralised model was chosen to protect confidential data and to handle the enormous volumes of data that millions of batteries generate over time. It does, however, place requirements on companies' IT readiness: the data must be available for at least 10 years, even if the company ceases to exist.

Three access levels: who sees what?

The battery passport contains more than 90 data points, from carbon footprint to detailed chemical compositions. To protect trade secrets, Article 77 works with three access levels.

Public access: Available to anyone who scans the QR code with a smartphone. Shows:

  • General information about the battery (type, chemistry, manufacturer)
  • The overall carbon footprint
  • Instructions for safe use and disposal
  • Information on collection schemes

Authority access: Reserved for market surveillance authorities, customs authorities and the Commission. Gives full access to:

The system is expected to be integrated with the EU customs systems, so batteries can be checked automatically at the EU's external borders.

Persons with a legitimate interest: Dedicated to professional actors in the battery's life cycle: repairers, second-life operators and recyclers. Gives access to:

  • Detailed chemical composition
  • Disassembly instructions
  • Real-time data on the battery's state of health (State of Health)

By August 2026, the Commission was to adopt an implementing act that defines precisely the criteria for "legitimate interest" and the technical requirements for verification.

Data carrier technologies other than QR

The regulation focuses on the QR code as the primary technology, but Article 13(8) allows for future alternatives via a delegated act.

  • RFID can be read from several metres away and allows fast scanning of whole pallets, but is more expensive per unit and requires special equipment.
  • NFC offers high security and can interact with smartphones, but has a very short range and requires a chip to be built in.

Industrial pilot projects from Catena-X and the Battery Pass consortium are experimenting with a combined approach: the QR code for the mandatory public access, and a built-in NFC chip for professional repairers, who can read deep technical data from the battery management system even if the battery is defective.

As long as no delegated act has been adopted approving other data carriers as a replacement for the QR code, manufacturers should plan with an optical QR code as the baseline.

What must labels contain besides the QR code?

The QR code is only part of the labelling requirements. Annex VI contains an extensive list of information that must appear physically on the battery or its packaging.

The general information (Part A) applies to all batteries and includes:

  • The manufacturer's contact details
  • Battery category, model number, place and date of manufacture
  • Weight and electrochemical composition
  • Information on hazardous substances and the correct extinguishing agent

Symbols and pictograms (Part B) include:

  • The separate collection symbol (the crossed-out wheeled bin, at least 3% of the battery's largest side)
  • Chemical symbols for heavy metals if the limit values are exceeded (mercury, cadmium, lead)
  • For non-rechargeable batteries: a marking that they must not be recharged

For EV, LMT and industrial batteries over 2 kWh, a carbon footprint label with a performance class (A-E) is added, in a format similar to the energy label on household appliances.

Timeline for labelling requirements

The labelling requirements are phased in step by step:

  • August 2024: CE marking mandatory for all batteries.

  • August 2025: Separate collection symbol mandatory for all batteries.

  • August 2026: General labelling requirements (capacity, chemistry, lifetime) from Annex VI, Part A. The deadline is linked to the adoption of the harmonised specifications: if the implementing act is delayed, the requirement applies 18 months after its final publication.

  • February 2027: QR code mandatory for all batteries. For EV, LMT and industrial batteries over 2 kWh, the QR code must link to the digital battery passport.

  • August 2028: Documentation of the recycled content of cobalt, lithium and nickel.

What does it mean for the production line?

For batteries with a battery passport, each individual battery must have its own unique identifier that the QR code links to. This has concrete consequences for production and logistics.

Many manufacturers are moving from traditional paper labels to laser engraving, which ensures the code is indelible. This requires close integration between the manufacturing execution system (MES) and the platform that hosts the battery passport: the moment a battery has been assembled and tested, data must be uploaded to the passport, and the laser station engraves the QR code that links to exactly that data set.

For companies importing batteries from countries outside the EU, responsibility for labelling and the battery passport lies with the European importer. The importer must require suppliers to provide the necessary data and apply QR codes in line with the EU specifications.

From 18 February 2027, a battery without correct labelling does not comply with the rules, and the same applies to EV, LMT and industrial batteries over 2 kWh without a battery passport. Market surveillance can then require the non-compliance to be corrected and ultimately prohibit sales or require the battery to be withdrawn (Market Surveillance Regulation, Article 16).

Summary

The QR code is more than a barcode: it is the physical key to the battery's digital identity. From 18 February 2027, it must be on all batteries and must be indelible. On EV, LMT and industrial batteries over 2 kWh, it links to the digital battery passport.

For manufacturers and importers, this requires investment in labelling technology, integration with battery passport systems and a clear data flow process from production to digital registration.

Until the harmonised labelling specifications are available, manufacturers should plan with a QR code as the baseline and open standards (GS1 Digital Link, ISO 15459) as the foundation.

Syntakk is built to generate and host digital battery passports with automatic QR code generation, so the labelling requirements are covered from production to market access.