How does the QR code for the battery passport get on the battery?

The manufacturer or importer applies the QR code

The QR code is placed on the battery via a label or marking that the manufacturer, or in the case of imports from outside the EU the importer, affixes. This code — the "data carrier" as the regulation calls it — provides access to the digital battery passport that has been created for that specific battery. The passport itself is not on the battery; the code merely points to it. When someone scans the code with a phone or scanner, they arrive at a page containing information about the battery: composition, source of materials, performance, and information on repair and end of life.

For whoever has the passport compiled — often not the manufacturer itself, but a party specializing in this — it means that two separate things happen that must align with each other: the creation and online publication of the digital passport on the one hand, and the affixing of the physical code on the battery on the other hand. Both must continue to point to the same location, throughout the entire lifetime of the battery.

Which batteries this applies to and which it does not

This obligation applies to the battery categories that must be issued with a digital passport under the Battery Regulation: batteries for electric vehicles, batteries for light transport vehicles (such as e-bikes and scooters) and industrial batteries above 2 kWh. For these categories, Article 13 of Regulation (EU) 2023/1542 requires that the battery bears a label and a data carrier.

Batteries that do not fall within these categories — think of an AA battery or the battery in a headphone — do not need to have a battery passport and therefore also do not need a QR code pointing to it. For those batteries, other labelling requirements from the same regulation apply, but not the passport requirement.

There is also a distinction between the code itself and the passport behind it. Article 13 governs the physical aspect: that a label and a data carrier are affixed to the battery. Article 78 governs the technical aspect of the passport that the code points to: how the passport functions and what requirements apply to access. Anyone looking for how the code is placed on the battery will therefore find the answer mainly in the labelling requirement, not in the provisions on the content of the passport itself.

The obligation applies from 18 February 2027

The obligation to provide batteries with a battery passport — and thus with the QR code that points to it — takes effect on 18 February 2027. Until that date, there is no legal obligation to affix the code, although an importer or manufacturer may choose to begin doing so earlier, for example to put production and labelling processes in place in time. Batteries that have already been placed on the market before this date will not be provided with a passport and code retroactively on the basis of this rule.

How this is handled in practice

For an importer or manufacturer preparing for this, the sequence is usually as follows. First, it is determined whether the battery falls within one of the categories for which the passport is mandatory: EV battery, battery for a light transport vehicle, or industrial battery above 2 kWh. Next, the data that will be included in the passport is collected: technical specifications, source of materials, performance and information on repair and end of life. The passport is then created and published online, at a fixed location that remains accessible throughout the lifetime of the battery. Only once that passport exists can the corresponding QR code be generated and printed or engraved on the battery's label.

For the physical implementation, what matters most is that the code is clearly readable and durably affixed to the battery — resistant to wear over the product's lifetime — and positioned in a fixed, findable location so that a user, repairer, or recycler can locate and scan it later. If you do not manufacture the battery yourself but import it, it is advisable to coordinate with the manufacturer to determine which party is responsible for each part of this process: creating the battery passport, generating the code, and affixing it to the physical product.

Where this is stated: Article 13 and Article 78

The obligation to provide a battery with a label and a data carrier is set out in Article 13 of Regulation (EU) 2023/1542 (Battery Regulation), which governs the labelling and marking of batteries. The technical requirements for the battery passport to which that data carrier refers — its design and operation — are laid down in Article 78 of the same regulation. Together, these two articles determine both what must physically appear on the battery and what must be digitally available behind it.

Anyone wishing to review the precise requirements for the label and data carrier can find the full text of both articles in Regulation (EU) 2023/1542, accessible via EUR-Lex.

If you are already working on this subject, it is best to start by establishing whether the battery in question falls under one of the three categories mentioned, and from there determine what data is needed to complete the passport — this inventory usually takes more time than affixing the code itself.