What labels and markings must be on a battery?
What must be on the label
A battery bears a physical marking with a fixed basic set of data: who the manufacturer is, what type and what batch or serial number it concerns, what the chemical composition is, and — where applicable — whether it contains substances such as mercury, cadmium or lead. In addition, many battery categories must have an indication of capacity. Also mandatory is the symbol for separate collection: the familiar crossed-out waste bin, which indicates that the battery does not belong in ordinary waste. In addition to this physical data, a QR code is placed on or with the battery: a data carrier that provides access to further information. This code is the same type of carrier that can also refer to the digital battery passport, but the marking obligation under Article 13 stands alone and applies more broadly than only to batteries for which a passport is mandatory.
Which batteries this applies to — and which it does not
The regulation distinguishes battery categories — portable batteries, batteries for light electric vehicles, industrial batteries, batteries for electric vehicles and starter, lighting and ignition batteries (SLI) — and the precise content of the label varies by category. Not every battery therefore needs to show the same information; for example, a capacity indication is relevant for different categories than those concerned purely with chemical composition. What the labelling obligation does not do: it does not replace any other obligation under the regulation. CE marking is a separate matter, and the obligation to maintain a digital product passport is separate from the marking obligation, even though the same QR code can be used for both purposes. For very small batteries where physical space for a complete label is lacking, the regulation sets out how to handle this per category — this is therefore not a generic exemption, but a category-specific arrangement.
Which date is fixed, and which is not yet
It is established that Regulation (EU) 2023/1542 as a whole has been adopted and entered into force, and that the obligations do not all come into effect at the same time: the regulation builds up the various obligations — including marking, the collection symbol, the QR code and the capacity indication — in stages, with separate implementation dates for each component and battery category. Which exact date applies to which part of labelling is something that is set out in the regulation itself for each obligation. To avoid naming a date that cannot be substantiated with certainty: for the precise implementation date of a specific part of the marking obligation, the official text of Article 13 is the appropriate source to consult. What is clear: the phased build-up means that a battery placed on the market today does not automatically have to comply with all future labelling requirements, but does have to comply with the requirements that already apply at that time.
What this means in practice
For importers, traders or installers of batteries, the first step is to determine which category a battery falls into — portable, light electric vehicle, industrial, EV or SLI — because that determines which data must appear on the label. Next comes checking which data is already available from the manufacturer: chemical composition, any presence of mercury, cadmium or lead, capacity, batch or serial number. If that data is missing, it should be requested from the manufacturer or supplier, because without that basic information a label cannot be completed. The physical label then goes on the battery together with the collection symbol, and the QR data carrier is added. In practice it is efficient to link the QR code directly to where the broader product information is located — including, where applicable, the digital battery passport — so that two separate codes are not needed for two separate obligations. Batpas.eu provides the QR data carrier and hosting of the underlying data, and compiles it on the basis of information supplied by the manufacturer or importer.
Where this comes from: Article 13
The labelling and marking requirements for batteries are laid down in Article 13 of Regulation (EU) 2023/1542 (Battery Regulation). That article governs which data must physically appear on or with the battery, which collection symbol is mandatory, and that a QR code must be added as a data carrier. For the complete and up-to-date text, including the precise implementation per battery category and the associated implementation dates, the official publication of the regulation is the appropriate source.
What to do now
Those now facing this obligation should start by determining the battery category and collecting the data the manufacturer already has — chemistry, capacity, any hazardous substances, batch number — and consult the official text of Article 13 for the exact, up-to-date implementation and implementation dates. Those wishing to combine the physical marking with the digital side of the story, with a single QR code pointing to both the legally required information and the battery passport, can contact batpas.eu for this.
What this is based on
The Regulation itself is on EUR-Lex. We refer for each statement; you need not believe us.
What you need to do concretely
What is expected of you
Labelling with general information about the battery
Article 13 of Regulation (EU) 2023/1542 (batteries regulation) requires that a battery is fitted with a label containing a fixed set of data: including the name or trademark of the manufacturer, the type of battery and the place where the battery was produced. For a company with 10 to 100 employees, this is primarily a matter of data management: those data must be established upon receipt of the battery (upon import or assembly), as they must also be included in the digital product passport. Companies that purchase batteries from different manufacturers will quickly notice that the label differs per supplier in form and completeness — this is precisely where internal controls should begin.
Making chemical composition visible
A second obligation under Article 13 concerns the indication of the chemical composition of the battery on the label. This is relevant for recycling, transport and hazard identification, and it is also information that is included in the digital product passport. In practical terms, this requires cooperation with the cell supplier or cell manufacturer: an importer of e-bikes or scooters usually has not measured this data themselves, but receives it via a data sheet or declaration of conformity from the manufacturer. It is that documentation that forms the basis for what appears on the label and in the passport.
Indication of hazardous substances
Where applicable, the label indicates the presence of certain substances such as mercury, cadmium or lead, insofar as the regulation requires it. For companies that assemble batteries from cells and modules of different origin, this means that the presence of these substances must be checked per component, not only at the level of the final product. An assembly company that assembles a battery pack from cells of an external supplier bears its own responsibility in this regard, even when the cells themselves already have a label.
Capacity and other technical characteristics
Article 13 also requires the inclusion of technical characteristics such as capacity on the label itself or via the accompanying documentation. For machinery manufacturers applying industrial batteries above 2 kWh in their own equipment, this is often the point where the distinction between 'label on the battery' and 'information in the passport' becomes somewhat blurred — both must be correct and consistent with each other. A mismatch between what appears on the label and what is entered in the passport is one of the first things that stands out during an inspection.
The QR code as access to the digital product passport
In addition to physical labelling, Article 13 requires a QR code on the battery that provides access to the battery passport. This is a different obligation from the label with textual data: the QR code is the bridge to the digital layer. How this code is to be applied to the battery, where it is to be affixed to the product and what technical requirements apply, is set out in how the QR code for the battery passport gets onto the battery. For companies that have this code created themselves, it is also worth knowing what GS1 Digital Link is and whether it is necessary for the battery passport, as this is a widely used standard for establishing the link between physical product and digital passport.
Legibility and durability of marking
The label and QR code must remain legible throughout the battery's life. This is an obligation that goes beyond applying the marking at the production stage — it is also about material selection and placement, so that wear, moisture or heat do not impair legibility in a short time. For an importer of light means of transport, this means that the choice of a sticker, engraving or burned-in marking is not only a cost matter, but also a compliance matter.
Where things go wrong in practice
A first common situation: an importer receives batteries with a label in a language or format that does not comply with what Article 13 requires, and does not modify this because the battery "already has a label". The presence of a label is not the same as meeting the content that the regulation requires.
A second situation arises with battery packs composed of multiple cells or modules: the label on the end product states data about the casing, but not about the underlying cells, while the chemical composition of those cells is relevant to the passport.
A third recurring situation is the QR code that is technically present, but does not link to a valid or current passport — for example because the code was created before the final data were known. This also touches on the question how each battery obtains a unique identification: without a conclusive link between a unique identification and the correct passport data, there is a risk that a code points to the wrong page or an empty page.
A fourth situation: the QR code is affixed to a sticker that is not resistant to the battery's operating environment, making it unreadable within a few months. What needs to be done then is linked to the question what to do if the QR code on a battery is no longer readable — a situation that could have been prevented by making a better material choice beforehand.
A fifth situation occurs with companies that use batteries in a larger device, such as a machine or an e-bike: the battery label becomes unintentionally hidden behind a casing, while the question whether the battery passport applies to their situation has long been answered with "yes". The labelling obligation does not disappear because the battery has been built in.
What you can record
- An overview per battery type of the data that must appear on the label, linked to the source (manufacturer, cell supplier, own assembly)
- Specification sheets and declarations of conformity from cell suppliers, containing the chemical composition and any hazardous substances
- An established procedure for affixing the QR code, including material selection and placement on the product
- A checkpoint where label data and passport data are compared against each other, before the battery leaves the company
- Agreements with suppliers on labelling for batteries that are purchased as a component (cell, module) rather than as an end product
- An established link between the unique identification of the battery and the corresponding passport, also relevant when passport data are managed via linking to an own ERP or inventory system
This is not legal advice. This page provides general information about the legislation that this platform covers. We do not know your situation. If in doubt about your own case, consult a lawyer or the competent supervisory authority.
Written with AI based on the sources above, checked by a human on 2026-08-22. Is something wrong? Let us know — corrections take priority.