what should I do if the QR code on a battery is no longer readable

A damaged QR code does not need to make the passport inaccessible

A QR code that is no longer readable does not automatically mean that the battery passport is lost. The QR code is a reference to the passport, not part of the passport itself: the data are stored online, not on the label. If the code is damaged, soiled or worn, the passport simply continues to exist at the place where it is hosted — only access via that specific battery becomes more difficult. Anyone in that situation can usually still access the passport via the identification data of the battery itself, such as the serial number or the other markings that are on the battery.

For whom this applies, and what it does not cover

This concerns the physical QR code on the label or housing of the battery: scratches, wear, soiling, a torn or detached label. It does not concern a passport that no longer exists online — that is a different problem, with its own answer about how long a battery digital product passport must remain available. It also does not concern the question of who must apply the code to the battery and according to which technical standard; that is described at how the QR code for the battery passport gets onto the battery. And it does not concern a battery that has not received a QR code at all — that is a matter of labelling that was not in order beforehand, not of later damage.

The distinction is relevant because the solution differs: with a damaged code, the question is how to access existing data, with a missing passport, the question is whether the data ever existed.

No separate deadline for this specific case

There is no separate date specified on which rules concerning damaged QR codes come into force; this falls under the general obligations regarding labelling and the battery passport, which apply from 18 February 2027. Until that date, there is no legal obligation to maintain a passport or a QR code. From that date, the obligation applies to new batteries placed on the market; no separate rule has been found that specifically describes what must happen if a code is damaged after sale. This does not mean there is nothing to say about it — it means that the basis lies in the requirements for the label and the passport as they apply to placing on the market, and that damage afterwards is a practical matter rather than a new legal regime.

How to approach this in practice

First: check whether the passport itself is still accessible, regardless of the code. Because the passport is hosted on a server and does not reside in the QR code itself, the data remain intact as long as hosting is in order — see where the data of the battery digital product passport is located online and who manages it. The passport can then still be found via the unique identification of the battery, such as a serial number, batch number or the model number that appears elsewhere on the battery or in the documentation.

Then: check whether there is a second marking on the battery. Article 13 of the Battery Regulation describes that in addition to the QR code, other information also appears on the label, such as capacity, composition and safety information. That text often remains readable even if the code itself is damaged, and can serve as a point of reference to identify the battery and find the passport via the serial number instead of by scanning.

Subsequently, if the battery still comes from the importer, dealer or manufacturer: check whether a copy of the label or product documentation is available there. Anyone responsible for applying labels — for example an importer who repackages or resells batteries — can in practice choose to apply a new, readable QR code as soon as an existing code becomes unusable, as long as that code refers to the same passport. How that link between code and passport works technically is described at what GS1 Digital Link is and whether it is necessary for the battery passport.

For anyone managing or providing passports themselves, it is practical to keep the link between serial number and passport findable outside the QR code as well — for example in their own system. This makes a damaged code less of a problem, because the battery can then be traced in another way. See about this linking the digital product passport to your own ERP or inventory system.

Where this follows from: Article 13 and Article 78

Article 13 of Regulation (EU) 2023/1542 (Battery Regulation) describes which labels and markings must appear on a battery, including the QR code that refers to the battery passport, and which other information must be directly visible on the battery. Article 78 describes the technical design and operation of the battery passport, from which it follows that the passport data itself is stored on a server and not in the code — the code is a reference, not a data carrier. From this design it follows that damage to the code is an access problem and not a loss of the underlying data.

What to do now

If you encounter a damaged QR code on a battery, first look for the serial number or model number elsewhere on the battery and contact the supplier, importer or the platform where the passport is hosted. If the data is still present there, it is practical to have a new code applied that refers to the same passport page, so that the battery can be scanned again for the remainder of its service life.