Can I apply the QR code to my batteries myself?
Yes, physically applying a QR code to a battery can in most cases be done by yourself. Printing and sticking a label, or having a code engraved in the casing, requires no specialist knowledge and no expensive equipment. The question that entrepreneurs more often stumble over is not the sticking itself, but what should be behind that code: a working link to the correct digital passport that remains accessible for years and stays up to date with every change in the data.
The distinction between doing it yourself and outsourcing therefore does not run along the physical action, but along the question of who ensures the connection between that code and the underlying data, and who guarantees that connection will work for ten years. For a small, manageable assortment, this can be done with your own system. With a broader or changing assortment, or with batteries from multiple suppliers, that connection quickly becomes the part that takes the most time.
What the regulation requires of the QR code
The Battery Regulation (EU) 2023/1542 requires that the digital passport of a battery be accessed via a data carrier, and the QR code is the standard form for this. The regulation says little about how exactly you apply that code, what material you use or what printer you buy. Where the text does say something, it concerns the content and accessibility of the passport to which the code points. This distinction is the core of this article: applying is a practical choice, the connection and accessibility are an obligation. For those who wish to check the exact requirements, there is an overview by topic in the knowledge base with the source in the official text.
What you can arrange without help
Printing and applying a label, choosing a location on the battery where the code remains clearly readable, and choosing a material that is resistant to moisture, heat or wear, are all things that can be organised within a regular business. The same applies to the internal arrangement of who is responsible for applying the code when a battery leaves the warehouse. This is work comparable to applying a nameplate or a CE marking: practical, repeatable, and can be carried out by your own staff with a bit of instruction.
Where it becomes more complicated
It becomes more difficult once the code must point to a passport that is unique to that one battery or that specific production batch, and must remain accessible and up to date throughout its lifetime. This requires a system that connects the code to the correct dataset, that allows changes in that data to take effect without the code itself changing, and that continues to work even if the original supplier of that system ceases operations or changes name. How that connection is technically established and why traceability takes precedence, is explained on the page about how the data behind the code is recorded. It is precisely this component where businesses more often choose to work with an external party, not because applying is too difficult, but because the continuity of the connection requires a different expertise than the daily work of an importer or installation company.
The practical consideration
For a company with a small, stable assortment of one or two battery types, an in-house maintained overview with codes and data may be sufficiently clear. With a larger or changing range, with batteries from different manufacturers and regularly new models, the risk of errors increases: a code pointing to an outdated dataset, or a label that is no longer legible after a few years of use. Which situation applies to your company depends on the number of batteries, the range of types, and your internal capacity to maintain such an overview.
What in any case remains with you
Regardless of who prints the label or technically manages the code, the responsibility for the accuracy of the underlying data remains with the party acting as the supplier. Outsourcing the execution does not change that responsibility. Supervisory authorities in the EU Member States monitor compliance with the regulation, and for questions about your own situation, the competent supervisory authority or a lawyer is the appropriate contact. Practical questions about the data carrier itself, such as readability and placement, can be found in the answers to frequently asked questions about the QR code.
Do you want to know how this consideration works out for your own range? With the free product scan of a few minutes you will see where you stand, without any obligation attached.