The EU battery QR code: who needs it, what it must open, and what is still changing

1. Which batteries need what

The regulation sorts batteries into five categories. The category decides what the code opens. Art. 3(1) Art. 13(6)

Cells and modules made available for end use, with no further assembly, count as batteries, under the most similar category, or the strictest where several fit. Art. 1(4) The rules apply whatever the battery’s chemistry, shape, weight or use. Art. 1(3) Three kinds of equipment are left out of the labelling chapter: equipment connected with Member States’ essential security interests, arms, munitions and war material (not products that aren’t specifically military); equipment sent into space; and equipment specifically designed for the safety of nuclear installations. Art. 1(5), (6)

The 2 kWh line. The Commission’s FAQ says that units which are each a complete, independently functioning battery are assessed one by one, but where they form one integrated system with common components, the complete system is the battery, and its combined capacity is what counts. Commission FAQ, Q3.3

2. Who is responsible

A summary of each role; the articles have the full duties.

Batteries inside products

The regulation applies to batteries “incorporated into or added to products”. Art. 1(3) Its recitals are direct about imports: batteries from outside the EU must comply “whether imported on their own or incorporated into or added to products”, and importers are to make sure of it. Recital 71

So if you import a finished product with a battery in it, treat yourself as the importer of that battery. The Commission’s FAQ says the same for passport batteries: for a product imported with a finished, working battery installed, “the battery is normally placed on the EU market when the product is imported, and responsibility lies with the importer”. Commission FAQ, Q3.5 We have not found it saying so specifically for portable batteries, but the definitions are the same. The FAQ states that it reflects the views of its authors, and isn’t law.

The code goes on the battery, not on your product, and the text doesn’t ask a device maker to label the device itself. That doesn’t remove the importer’s duty: it is why many importers will have to ask their factory to print it.

Where the text leaves room

• An unbranded cell inside your own-brand device. Selling the battery “under its own name or trademark” is what makes you its manufacturer. Whether a brand on the device counts isn’t spelled out. If you import it, you are its importer either way.
• A battery bought from an EU supplier. It was placed on the market when that supplier first sold it, so on our reading you are not its importer. As you pass it on, the distributor’s check still applies.
• Cells and modules. Their suppliers must give a battery’s manufacturer the information it needs to comply, free of charge. Art. 39 The Commission’s FAQ adds, for passport batteries, that cells or modules imported to be assembled in the EU are normally not the finished battery, and that whoever completes it is the manufacturer, with an exception for do-it-yourself kits. Commission FAQ, Q3.4

3. What the code must open, and from when

For batteries without a passport, Article 13(6)(b) lists “the applicable information referred to in paragraphs 1 to 5”, the declaration of conformity, the due diligence report and the waste information. All of it must be “complete, up-to-date and accurate”. Art. 13(6) Most of it is already required some other way. The dates below say when each applies, and when it has to be behind the code.

What “applicable” means

The reading we find most natural: “the applicable information” is what applies at the time, so the label details wouldn’t be required behind the code until the label rules themselves apply. It can also be read as what applies to that category of battery, which would put every field behind the code from 18 February 2027, and some guides list them all from day one. No text settles it. The Council’s mandate would, by deferring all of paragraphs 1 to 5, including the symbol and Cd or Pb, until 18 months after the labelling act (section 7), but it isn’t law. Publishing the details you already have costs little, and covers both readings.

The code doesn’t replace the other duties

Producers, or their producer responsibility organisations, must also make the waste information available “as a minimum at the point of sale in a visible manner and through online platforms”, and distributors must provide it in their retail premises. Art. 74(1), (4)

Languages and accessibility

The waste information must be in a language or languages easily understood by end-users, as each Member State determines. Art. 74(1) The declaration of conformity must be translated into the languages the Member State requires. Art. 18(2) The recitals add that labels and QR codes should be accessible to persons with disabilities. Recital 44

4. The code itself

What it must be. A machine-readable matrix code that links to the required information, in high contrast to its background, and big enough for a commonly available reader, such as a phone. That is all Annex VI asks. Art. 3(1)(24) Annex VI, Part C The recitals add that it should respect ISO/IEC 18004:2015, the QR code standard. Recital 44 For help with the size, see how big to print a QR code.

No special identifier without a passport. The unique identifier and the ISO/IEC 15459 standards are in Article 77(3), which is about passports. We found nothing that asks batteries without a passport for GS1 codes or a unique identifier per battery. Art. 77(3)

Where it goes. “Printed or engraved visibly, legibly and indelibly on the battery.” Where that is “not possible or not warranted on account of the nature and size of the battery”, it is affixed to the packaging and to the documents accompanying the battery. Art. 13(7)

One code per model, or per lot? Nothing asks for one per battery. The catch is that the label details include the place and month of manufacture, which differ between lots. Where putting the date on the label causes disproportionate costs, the draft labelling act would let it stay elsewhere on the battery, with the label saying where. Draft act, Art. 1(8) One page per model can then work, as long as the model comes from one plant and your declaration covers every batch the page serves: the declaration’s model asks for “batch or serial number”. Annex IX, point 1 Otherwise, make one page per plant or per declaration.

How long it must work. No period is set. The recitals say the code is there “to ensure the availability of information over time” (Recital 44), and the declaration must be kept for authorities for 10 years (Art. 38(4)). A battery can be discarded long after it is sold, so plan for its whole life, and make sure a printed code doesn’t depend on a subscription someone might stop paying.

Used batteries. Batteries prepared for re-use or repurposing, repurposed or remanufactured need new markings, with their change of status reachable through the code. Art. 13(9)

5. Stock and the date

The duty attaches when a battery is placed on the market, which means first made available in the EU, not when it was made, and not when its model first went on sale. Art. 3(1)(16) Art. 38(1) Art. 41(1) The recitals say it outright: batteries “placed in stock in the Union by distributors, including retailers, wholesalers and sales divisions of manufacturers, before the date of application of relevant requirements of this Regulation do not need to meet those requirements”. Recital 11

The Commission’s Blue Guide on EU product rules, which is general guidance rather than battery law, adds two points. The concept “refers to each individual product, not to a type of product”, and a product is not yet made available while it is “in the stocks of the manufacturer (or the authorised representative established in the Union) or the importer”, not being supplied. Blue Guide 2022, section 2

So shops can sell through what they already hold, and each battery is judged on its own date. Don’t stretch this to a container that lands on 19 February: the Blue Guide says that goods declared for release for free circulation can “generally be considered” as being placed on the market, and the Commission’s FAQ says a battery inside an imported product is “normally placed on the EU market when the product is imported”. Commission FAQ, Q3.5

6. If your battery needs a passport

E-bike, e-scooter, electric vehicle and industrial batteries above 2 kWh need much more than a page. olinqs doesn’t make battery passports, so this is only an outline of what differs.

• One for each battery, with data about the model and about the individual battery, including its use. Art. 77(1), (2)
• Three levels of access: the public; notified bodies, market surveillance authorities and the Commission; and people with a legitimate interest. Art. 77(2)
• A unique identifier under ISO/IEC 15459 or equivalent, uploaded to the EU’s registry, set up by Implementing Regulation (EU) 2026/1778. Art. 77(3), (10) Commission FAQ, Q1.4
• Open and interoperable: machine-readable, searchable, without vendor lock-in. Art. 77(5)
• It outlives you: it must remain available after the operator ceases to exist or leaves the EU. Art. 78(e)
• Not everything from day one: carbon footprint, recycled content and due diligence information are not yet required in February 2027. Commission FAQ, Q7.2 Data points, v3.2

Who issues it, according to the Commission’s FAQ: whoever completes the finished, working battery and places it on the market. If a finished battery is supplied and a vehicle maker merely installs it, the battery manufacturer is responsible; if the vehicle maker completes it, for example by adding the battery management system, the vehicle maker is. For a product imported with a finished battery installed, it is normally the importer. Authorising someone else to do the work doesn’t transfer the legal responsibility. Commission FAQ, Q2.1, Q2.3, Q2.5, Q3.5

7. What is still changing

The state of each text on the date at the top of this page, with the place to check it yourself. A draft or a mandate is not law.

8. Other duties on the same batteries

The code is one duty among several. Most of these already apply.

• CE marking, technical documentation and identification. The battery carries the CE marking, a model and batch, serial or product number, and the manufacturer’s name and address, with instructions and safety information in the right languages. The declaration of conformity covers the marking rules too. Art. 20 Art. 38(1), (2), (6), (7) Art. 18(1)
• Removal and replacement. From 18 February 2027, portable batteries in products must be readily removable and replaceable by the end-user, with exceptions. Instructions and safety information must be “available permanently online”. Art. 11(1)–(3) Art. 96(2) Guidelines C/2025/214
• Producer registration and collection. Producers register in each Member State where they first make a battery available, and organise collection. This has applied since 18 August 2025. Art. 55(2) Art. 59–61 Art. 96(2)
• Conformity assessment. It has applied since 18 August 2024 and comes before the declaration. Art. 17(1) Art. 96(2)
• Penalties are set by each Member State, and must be “effective, proportionate and dissuasive”. Art. 93

9. Common mistakes

• “The QR code is only for passport batteries.” “All batteries shall be marked.” Art. 13(6)
• “E-bike packs are portable batteries.” A sealed battery of up to 25 kg designed for the traction of wheeled vehicles is an LMT battery, which needs a passport. Art. 3(1)(11)
• “Every battery QR code needs GS1.” The identifier standards are in the passport article. Art. 77(3)
• “We’ll just put it on the box.” Only where the battery’s nature and size make marking it impossible or not warranted, and then on the documents too. Art. 13(7)
• “It’s our supplier’s problem.” An importer must check the marking and hold back batteries that don’t comply. Art. 41(2)
• “The code replaces the label.” Today the label rules are separate, with their own dates. Art. 13(1)–(5) Parliament’s rapporteur proposes a digital route, not voted (section 7).
• “We must relabel all our stock.” Not stock already placed on the market. Recital 11

10. Checklist

1. Work out each battery’s category (section 1). If it needs a passport, find a service that makes them.
2. Work out your role for each one: manufacturer, importer or distributor (section 2).
3. Ask your supplier for the declaration of conformity, and whether the battery will carry a code, and to what.
4. If nobody will provide the page, publish it yourself: it can be on your own website or a service.
5. Put on it the declaration, the waste and safety information in the right languages, the markings, and the label details you have.
6. Get the code printed on the battery; if its nature and size make that impossible or not warranted, on the packaging and the documents.
7. Scan the real print with an ordinary phone.
8. Keep the page up to date, for the battery’s whole life. Check section 7 before your next print run.