There is no fixed deadline in the regulation for applying the QR code itself. Regulation (EU) 2023/1542 requires in article 77 that a data carrier be present on or attached to the battery that leads to the digital product passport, but not within how many weeks or months you must arrange this internally. You determine that processing time in practice yourself, and it varies widely.
With a limited assortment of one or a few models, applying the code can often be arranged within a few weeks, especially if the data for the passport is already complete. With a running production line with many variants, or with imports of varying batches, this can quickly extend to several months. The main reason for this is not the application or etching of the code itself, but the coupling between that one, physical code and the correct passport per battery or serial number.
What determines the processing time
The first factor is whether the QR code has already been incorporated into the design or production, or whether it is added afterwards. A code that is etched or printed during production requires an adjustment to the production process itself; this takes time to set up, but is then repeatable for each subsequent batch. A sticker that is applied afterwards is quicker to set up per unit, but requires more time as the number of already produced or already imported batteries increases.
The second factor is the number of variants. Coupling one passport to one QR code is straightforward. Ten models, each with multiple capacities, suppliers or production years, requires a system: which code belongs to which passport, and how do you prevent the same code from accidentally ending up on two different batteries. If you do not yet have an overview of this, you can answer a few questions and get an initial indication of where the greatest time pressure lies in your own assortment.
Where it gets stuck in practice
The most common delay does not occur during the application itself, but before and after it. Before application, the data for the passport must be complete; if information is still missing from a supplier, the code is ready but the passport is not, and application makes no sense yet. After application, the code must remain readable under the conditions in which the battery is used: moisture, heat, vibration or wear can make a QR code unreadable, and this is usually only noticed when tested under practical conditions, not in the office.
A third delay is in the transition between systems. If you have the passport drawn up in one environment and the QR code generated in another, you run the risk that the two become out of sync as soon as something changes, for example a new supplier or an amended specification. This is also the moment when a conversation with a software supplier becomes relevant: not about the code itself, but about how changes to the passport automatically flow through to what is behind the code.
The coupling between application and keeping it current for ten years
Applying the code is a one-time action, but the passport behind it must remain accessible and correct throughout the entire life of the battery. This changes the way you should look at the processing time of application: not as an endpoint, but as the starting point of a trajectory that continues for years afterwards. How that hosting and updating work in practice is described on the page about how the data is compiled and hosted.
What shortens the processing time in practice
Companies that start testing early, separately from the full production line, prevent a readability or coupling issue from coming to light only shortly before the obligation takes effect. The same applies to establishing early a fixed systematic approach for linking codes to battery passports, so that this systematic approach can grow along with new models instead of having to be corrected afterwards. An overview of the individual steps, from determining role to keeping the passport current, is set out in the knowledge base with the topics worked out per situation.
For your own situation, with the specific assortment size, production method and suppliers, an assessment will always be custom-made. If you would first like to get an impression of where you stand in this process, then the free quick-scan can provide a first direction; for questions not answered there, you can contact frequently asked questions or a lawyer or the competent supervisory authority for your specific situation.