The QR code on the battery

From 18 Feb 2027, every battery must carry a QR code, not only those that need a passport (Art. 13(6)). The Regulation defines it as a machine-readable matrix code that links to the required information (Art. 3(1), point 24). What the code must lead to depends on the battery category.

Where the code must lead

• LMT batteries (e-bike, e-scooter), industrial batteries above 2 kWh and electric vehicle batteries: to the battery passport under Art. 77 (Art. 13(6)(a)).
• All other batteries: to the labelling information under Art. 13(1) to (5), the EU declaration of conformity, the due diligence report under Art. 52(3) and the information on waste prevention and take-back under Art. 74(1)(a) to (f) (point (b)).
• SLI batteries: in addition, to the amount of cobalt, lead, lithium or nickel recovered from waste and present in the active materials (point (c)).

The information behind the code must be complete, up to date and accurate (Art. 13(6), last sentence). A code that leads to a dead page or a general home page does not meet the obligation.

Where the code goes

The QR code is printed or engraved visibly, legibly and indelibly on the battery (Art. 13(7)). Only where this is not possible or not warranted because of the nature and size of the battery does it go on the packaging and on the accompanying documents, meaning both. The obligation attaches to the battery, not to the device: on an e-bike, the code belongs on the battery pack, not only on the frame or the bike's box.

One code per battery

Batteries subject to the passport obligation each need their own passport (Art. 77(1)). The QR code links to a unique identifier assigned by the economic operator placing the battery on the market (Art. 77(3)). Code and identifier must comply with ISO/IEC 15459-1 to -6 or equivalent standards. A single model code on all batteries is therefore not enough. The simplest approach is to print the code together with the serial number on the same label.

The EU registry for product passports also works only at the level of the individual battery and expects the identifier as an HTTPS address. The address behind the code should therefore never change.

Print quality and durability

Annex VI Part C requires high contrast to the background and a size that a commonly available reader, such as a smartphone, can read easily. The Regulation sets no fixed minimum size in millimetres. "Indelibly" means the code must survive the battery's lifetime, with heat, abrasion, moisture and cleaning. Proven practices:

• a dark code on a light, matte background and a clear quiet zone around the code
• a short address, because fewer characters mean fewer and therefore larger modules in the same area
• a medium or higher error correction level, so that small scratches do not make the code unreadable
• label material and adhesive rated for the temperature and surface of the battery housing, or laser engraving
• no placement across edges, seams or strongly curved surfaces
• a test with several smartphones on the finished battery, also after a simple abrasion test

What else goes on the battery

The QR code rarely stands alone. Since 18 Aug 2025, the separate collection symbol applies (Art. 13(4)), plus Cd or Pb above 0.002 % cadmium or 0.004 % lead (Art. 13(5)). Add to that the model identifier and serial or batch number (Art. 38(6)), the manufacturer's name and address (Art. 38(7)) and, for imported goods, the importer's as well (Art. 41(3)), and the CE marking. The general label under Annex VI Part A becomes mandatory only 18 months after the implementing act on labelling, which had not been adopted as of October 2026. Batteries that have been repurposed or remanufactured get a new label, and their change of status must be accessible through the QR code (Art. 13(9)).

Labels with Batterypass Online

For each battery you generate a print-ready PDF with QR code, model, serial number, category and collection symbol, in A7 or 50 × 30 mm. The code leads to the public passport page of that individual battery. Before releasing series production, make a test print on the real material and scan it on the finished battery.