From 18 February 2027 every battery needs a QR code, not only the ones with a passport. Printed or engraved, and an NFC tag does not replace it

From 18 February 2027 all batteries placed on the EU market must be marked with a QR code, under Article 13(6) of Regulation (EU) 2023/1542. Not only the electric vehicle, LMT and large industrial batteries that need a passport: all of them. Article 13(7) says the code is printed or engraved on the battery, visibly, legibly and indelibly, and moves to the packaging and the accompanying documents only where the nature and size of the battery do not allow it. The regulation names one carrier, the QR code. An NFC tag or an RFID chip can be added, but it cannot replace the code until the Commission adopts a delegated act for it, and we found no sign of one being prepared.

Every battery, not only passport batteries

This is the part most people miss, because the QR code and the battery passport start on the same day. The passport is for three categories. The QR code is for every battery, and what it has to open depends on the category:

• LMT batteries, industrial batteries above 2 kWh and electric vehicle batteries: the battery passport under Article 77.
• All other batteries, including portable batteries in consumer products: the label information from Article 13(1) to (5), the EU declaration of conformity, the due diligence report referred to in Article 52(3), and the information on prevention and management of waste batteries from Article 74(1)(a) to (f).
• SLI batteries, the starter batteries in cars, in addition: the share of cobalt, lead, lithium or nickel recovered from waste and present in the active materials.

The regulation adds that this information must be complete, up to date and accurate. So a producer of AA cells or of a battery pack for a power tool needs a QR code and a page behind it, even though they do not need a passport.

What the law says about the code itself

Less than most suppliers suggest. These are all the requirements:

• Placement and durability, Article 13(7): printed or engraved on the battery, visibly, legibly and indelibly. Where this is not possible or not warranted on account of the nature and size of the battery, on the packaging and on the documents accompanying the battery. Both, not one of them.
• Readability, Annex VI Part C: high contrast to the background colour, and a size easily readable by a commonly available QR reader, such as the one in a phone. There is no size in millimetres.
• Symbology, recital 44: the code should respect the guidelines of ISO/IEC 18004:2015, the standard for QR codes. Any ordinary QR generator follows it.
• Identifier, Article 77(3), for passport batteries: the QR code links to a unique identifier attributed by the operator placing the battery on the market, and both comply with the ISO/IEC 15459 series or an equivalent. GS1 is one of the issuing agencies registered under that series, so a GTIN in a GS1 Digital Link address is one way to meet it. A draft delegated act opened for feedback on 29 September 2026 (initiative 14460, window until 27 October) would replace this reference: the QR code would have to comply with EN 18220:2026 and the unique identifier with EN 18219:2026, or their equivalent. These are two of the harmonised passport standards cited in July. Until the act is adopted, the current wording applies.
• Accessibility, recital 44: labels and QR codes should be accessible to persons with disabilities, in line with the European Accessibility Act.

Sticker, engraving, sublimation: what counts

The regulation names two methods, printing and engraving, and one result, a mark that is visible, legible and indelible on the battery. It does not name a technology.

• Engraving or laser marking on the housing is the reading nobody can argue with: the code is part of the battery and survives as long as the housing does.
• Printing on the housing, whether pad printing, screen printing, inkjet or sublimation, is printing. It counts if the print stays legible for the life of the battery, through heat, abrasion and whatever chemicals the battery meets in use.
• A printed adhesive label is the common industry practice, and the regulation does not mention it. Whether a label stuck on the housing is "printed on the battery" is an interpretation. If you use one, choose a material rated for the conditions the battery will see, and write down in your technical documentation why it meets "indelibly".
• Packaging and documents only are allowed when the battery is too small or its nature does not allow a mark, and then the code goes on both. That is a decision you have to be able to justify, not a default.

NFC, RFID and Data Matrix

Article 13(8) lets the Commission adopt delegated acts that provide for alternative types of smart labels, to be used instead of or in addition to the QR code. Until such an act exists, the QR code is the only carrier that satisfies the law. A search of the Commission register of initiatives for battery labelling on 1 October 2026 returned the labelling act described below and the act on carbon footprint label classes, and nothing on smart labels.

So an NFC tag can sit next to the QR code, for example so that a recycler's reader picks up the identifier without a camera. It cannot be the only mark. The same goes for Data Matrix, which is common in the automotive industry; the Battery Pass consortium names exactly this tension between the regulation's QR code and the Data Matrix codes already used on vehicle batteries.

What the draft labelling act adds

Article 13(10) required the Commission to adopt, by 18 August 2025, an implementing act with harmonised specifications for the battery labels. The draft was published on 15 December 2025 as initiative 14456 and drew 91 responses before the window closed on 26 January 2026. On 1 October 2026 it had not been adopted. It is a draft, and the final text can change, but it shows where the Commission is going:

• The QR code comes first. When the surface of a battery cannot hold all the required markings, the draft sets an order of priority, and the QR code is number one, ahead of the crossed-out bin symbol.
• The QR code can sit on the label instead of elsewhere on the surface of the battery.
• Batteries inside products. Where batteries are built into products or vehicles and are not immediately visible, the draft puts the QR code on the battery and in the documentation, and allows it on the product as well, with a battery icon next to it. For portable batteries that only a professional can remove, and for products that must stay sterile, the code goes in the documentation and may also appear on the battery or the product.
• Battery packs. The label goes on the external housing of the assembly, and each module may carry its own QR code giving access to the label.
• Durability. The label is placed for visibility and durability and designed to remain readable until the end of the battery's service life.

The draft also matters for timing. The labels under Article 13(1) to (3) apply from 18 August 2026 or 18 months after this implementing act enters into force, whichever is later, so they move with it. The QR code does not: Article 13(6) has a fixed date, 18 February 2027, independent of the labelling act.

What to tell your printer or your line engineer

• Decide per battery model where the code goes: on the housing, or on packaging and documents because the battery is too small. Write the reason down.
• Encode an address you control. A printed or engraved code cannot be changed, so it should point to a stable address that you can redirect, not to a page of a provider you may leave. The Battery Pass technical guidance recommends exactly this kind of stable link for a static QR code.
• Test it with ordinary phones on the real surface, in the real colour, at the real size. That is the legal test in Annex VI.
• Test durability the way the battery lives: heat, abrasion, cleaning agents, years.
• Treat NFC as an addition, never as the only mark.
• For packs and products, plan the code on the outer housing and in the instructions, and consider the module codes the draft allows.

For what it is worth, a passport or information page on dppera.com gives you the address and a QR code to download as a vector EPS file, which a print shop or a laser marking station can use directly. The marking itself is your process, not ours.

What this is not

This is not the passport obligation. A battery outside the three passport categories needs a QR code and the information behind it, not a battery passport.

This is not a ban on stickers. The regulation neither allows nor forbids them by name; it sets a result.

This is not legal advice for your product. A battery that is built into a device, sold sterile or exposed to unusual conditions may need a reading that only your conformity assessment can give.

FAQ

Łukasz Głuch

Builds DPPera, a digital product passport tool for small and medium-sized companies. Reads the delegated acts so you do not have to. Writes about what he checked in the registry, not about what vendors promise.

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