The most common mistake with the QR code for the battery passport is that companies think about it too late. The code is only created after the batteries have already been purchased, imported or even packed, while the link between a physical battery and its passport is actually established from the start of the process. The result: labels that are stuck on afterwards, codes that accidentally refer to the wrong batch or wrong model, or a generic code that leads to a product page instead of the passport of that specific item.
This may seem like a detail, but it strikes at the heart of what the data carrier is for: one-to-one traceability between the battery someone is holding and the data recorded about it. Regulation (EU) 2023/1542 describes in article 77 that the information must be accessible via a data carrier; how that link is technically and organisationally arranged in practice is up to the provider to set up.
Why the timing so often goes wrong
Among importers and dealers of e-bikes, scooters and industrial batteries, the order often follows a different route than the documentation. The batteries arrive, the technical data and certificates follow separately, sometimes via a different department or even a different supplier within the same group. If no one has agreed in advance who creates the QR code and at what point it ends up on the battery, a gap emerges between the physical product and the passport that goes with it.
That gap becomes visible as soon as a battery changes hands, is repaired or is returned at the end of its life. Precisely at those moments the code must work and lead to the correct, up-to-date data. Anyone who only then discovers that the link is not correct must solve the problem anyway, but then under time pressure and often for an entire inventory at once.
One code, one battery, no confusion with marketing
A second recurring mistake is using a QR code for marketing or service and the code that serves as a data carrier for the passport interchangeably. Both can work perfectly alongside each other, but then it must be clear to everyone — the user, the repairer, the regulator — which code is for what. Two similar codes on one battery without distinction lead to confusion and, during an inspection, to questions that could easily have been avoided.
Whether a company can work with one code per model for its own product line or per batch or even needs a unique code for each individual battery depends on how uniform the composition and origin of those batteries are. That is a question that differs per situation and for which it is advisable to lay your own product information alongside the official text, for example via the knowledge base in which topics are worked out per situation.
The code must continue to work, even after years
A third mistake that is less often mentioned but just as persistent: the code is applied on time, but the underlying page no longer exists a few years later. A supplier stops, a website is renewed without taking the old links with it, or an internal system is replaced. The battery itself often lasts for years; the data carrier must continue to work just as long.
If you have any doubts about this in your own product catalogue, you can quickly get an indication of where the points of attention lie with a few questions via a quick scan that shows in a few questions where you stand. This is not a legal assessment of your situation, but an initial direction to start the conversation internally or with a supplier.
How to prevent this in practice
The core of the solution is not complicated: establish who within the company is responsible for creating the code, at what point in the procurement or import process this happens, and where the underlying data comes from. Ensure that this step is as firmly established in the procedure as applying a CE marking or a nameplate, rather than a task that is completed afterwards.
Because the link between code and data must remain intact for ten years, it is also worthwhile to know in advance how a supplier has technically arranged that hosting. You can read more about this on the page explaining where the information comes from. For individual questions that come up daily at companies starting with this, there is also an overview of frequently asked questions.
This text describes a common bottleneck, not an assessment of your own situation. For a concrete assessment of your products and processes, it is advisable to consult the official text or contact a lawyer or the competent supervisory authority. If you would first like to get an idea of where your company stands, you can do the free quick-scan without obligation or browse through the topics at your own pace.