Labelling, Marking and QR Code: What the EU Battery Regulation Requires, for Which Batteries and From When

Six elements make up the full label set.

The labelling rules sit in Regulation (EU) 2023/1542 concerning batteries and waste batteries (OJ L 191, 28.7.2023). The Regulation is directly applicable, so Article 13 binds manufacturers without national law. Chapter III, "Labelling, marking and information requirements", of the EU Battery Regulation holds Articles 13 and 14.

The implementing act that fixes the label format had not been adopted as of 13 November 2026, so the general information, capacity and duration labels are not yet mandatory. The sections below take the elements in turn, then placement, the draft act, the operators and the proof.

What Does Article 13 Require on a Battery?

Article 13 sets six labelling and marking elements: a general information label, a capacity label, a minimum average duration label, the separate collection symbol, the Cd or Pb chemical symbol where a threshold is exceeded, and a QR code.

Which of them apply depends on the battery category and on the date; no battery carries both the capacity and the duration label.

Labelling is a condition for market access: Article 5 requires batteries placed on the market or put into service to meet Articles 6 to 10, 12, 13 and 14 (consolidated text on EUR-Lex). Labelling therefore sits beside substances, carbon footprint, performance and safety among the EU Battery Regulation requirements.

The Six Labelling Elements at a Glance

The table sets out each element with its paragraph of Article 13, the battery categories it covers and the date from which it applies. Two elements run on fixed dates, three share one conditional date, and the chemical symbols depend on the cadmium or lead content of the battery.

Table 1: The six Article 13 elements; each of the five battery categories (portable, LMT, SLI, industrial, electric vehicle) follows its own rows (Article 1(3)).

Each category follows its own rows because the strictest-category rule does not reach labelling. Article 1(3), second subparagraph, sets that rule for the purposes of Chapter II only, while Article 13 sits in Chapter III. A battery is therefore labelled for the one category it belongs to.

When Do the Labelling Obligations Apply?

Article 13 runs on two kinds of date: fixed dates for the separate collection symbol (18 August 2025) and the QR code (18 February 2027), and a conditional date for the general, capacity and duration labels. The conditional date depends on a Commission act, so it cannot be read from a calendar.

The Regulation itself entered into force on 17 August 2023 (Article 96(1)) and has applied since 18 February 2024 (Article 96(2)), while Article 13 sets its own later dates element by element. Every other date of the act is set out in the EU Battery Regulation timeline.

Each date applies battery by battery: from that date, the element is required for every battery placed on the market or put into service, because Article 5 makes Article 13 a condition of market access. The table shows each labelling date with its provision and its status as of 13 November 2026.

Why the General Label Is Not Yet Mandatory

The general information, capacity and duration labels of Article 13(1) to (3) apply from 18 August 2026 or 18 months after the entry into force of the implementing act under Article 13(10), whichever is the latest, and that act had not been adopted as of 13 November 2026. Without the act, the later date does not yet exist.

The 18-month period starts only once the implementing act enters into force. No calendar date can be computed for these three labels until the act is published in the Official Journal, so a statement that they have been "mandatory since 18 August 2026" is wrong.

The delay stems from a missed deadline. Article 13(10) required the Commission to adopt the implementing act by 18 August 2025, the day the separate collection symbol became mandatory. That deadline passed without adoption, so 18 August 2026 cannot serve as the application date on its own.

The old regime overlapped for a period. Article 95 of the Regulation repealed Directive 2006/66/EC with effect from 18 August 2025 but kept its capacity labelling rule in Article 21(2) applicable until 18 August 2026. The transition rules of the Batteries Directive 2006/66/EC are explained separately.

What Goes on the General Information Label?

The general information label lists ten items set out in Annex VI, Part A: the manufacturer, the battery category and identification, the place and date of manufacture, the weight, the capacity, the chemistry, hazardous substances other than mercury, cadmium and lead, the usable extinguishing agent and critical raw materials above 0.1 % weight by weight. The table numbers the items as Annex VI does.

Two items point to manufacturer duties elsewhere in the Regulation. Point 1 refers to the contact details of Article 38(7): name, registered trade name or trade mark, a postal address with a single contact point, and web and email addresses where available. Point 2 refers to the identification of Article 38(6).

The same data travels into the battery passport. Annex XIII, point 1(a), lists the Annex VI, Part A, label information among the publicly accessible passport data, so a manufacturer of a passport battery prepares one data set for both.

Capacity and Minimum Average Duration Labels by Category

Rechargeable portable, LMT and SLI batteries carry a capacity label under Article 13(2), and non-rechargeable portable batteries carry a label on their minimum average duration in specific applications plus the words "non-rechargeable" under Article 13(3). The table matches each of the five categories to its labels and to what its QR code opens.

Industrial and electric vehicle batteries carry neither label under Article 13. Their data reaches users through the QR code, which opens the battery passport for every electric vehicle battery and each industrial battery with a capacity greater than 2 kWh.

Both labels share the conditional date of the general label: 18 August 2026 or 18 months after the entry into force of the implementing act under Article 13(10), whichever is the latest. Neither label applied as of 13 November 2026.

The Separate Collection Symbol: Size and Placement

Every battery placed on the EU market has had to carry the separate collection symbol, the crossed-out wheeled bin shown in Annex VI, Part B, since 18 August 2025 under Article 13(4). The symbol marks the battery for separate collection once it becomes waste, and it applies to all five categories.

The size scales with the battery. The symbol covers at least 3 % of the area of the largest side of the battery, and at least 1.5 % of the surface area for cylindrical cells. In both cases the symbol may not exceed 5 x 5 cm, whatever the size of the battery.

Very small batteries move the symbol to the packaging. A battery whose symbol would be smaller than 0.47 x 0.47 cm is not marked on the battery itself; the symbol goes on the packaging instead, at a size of at least 1 x 1 cm. The table collects the five size cases.

Cadmium and Lead Chemical Symbols Below the Bin

A battery containing more than 0.002 % cadmium or more than 0.004 % lead must show the chemical symbol "Cd" or "Pb" printed beneath the separate collection symbol, at least one quarter of its size (Article 13(5)). The thresholds are measured by weight, and a battery below both carries the collection symbol alone.

No "Hg" symbol exists under Regulation (EU) 2023/1542; only cadmium and lead carry a chemical mark. The marking thresholds are separate from the limits on mercury, cadmium and lead content in Annex I, which govern whether a battery may be placed on the market at all and are covered under restricted substances.

What the QR Code Must Link To, by Category

From 18 February 2027 every battery must carry a QR code under Article 13(6), defined in Article 3(1), point (24), as a machine-readable matrix code that links to information required by the Regulation. The QR code applies to all five categories, not only to batteries with a passport.

What the QR code opens depends on the category. Batteries without a passport link to their labelling information and documents; SLI batteries add data on recovered materials. The table sets out the three cases.

For LMT batteries, industrial batteries with a capacity greater than 2 kWh and electric vehicle batteries, the QR code is the entry point to the battery passport of Article 77, required from the same date of 18 February 2027. The passport's scope, contents and access rules are explained on the EU battery passport page.

Annex VI, Part C, requires high contrast to the background and a size readable by a commonly available QR reader, such as one in a hand-held device.

Recital 44 points to the guidelines of ISO/IEC 18004:2015. For passport batteries, Article 77(3) requires compliance with ISO/IEC 15459, parts 1 to 6 (2014 and 2015 editions), "or their equivalent".

Where the Marks Go: Battery, Packaging or Accompanying Documents

Article 13(7) requires the labels and the QR code to be printed or engraved visibly, legibly and indelibly on the battery, and only where that is not possible or not warranted on account of the battery's nature and size are they affixed to the packaging and to the accompanying documents. The battery itself is the default carrier.

The identification and contact details follow the same order. The manufacturer's identification (Article 38(6)) and the importer's contact details (Article 41(3)) go on the battery, or else on the packaging or in an accompanying document, and the collection symbol has its own size fallback set out above. Labels on the packaging itself follow the separate EU packaging rules.

The Labelling Implementing Act: Draft Status as of 13 November 2026

As of 13 November 2026 the Commission has not adopted the implementing act under Article 13(10) that sets harmonised specifications for the labelling requirements; a draft (Ares(2025)11169592) was published on 15 December 2025 and is in inter-service consultation.

The draft is titled "Commission Implementing Regulation laying down rules for the application of Regulation (EU) 2023/1542 as regards format and harmonised specifications for certain labelling requirements".

Besides the statutory deadline, the Commission's own planning foresaw adoption in the second quarter of 2025, a date that also passed without adoption. The Have Your Say initiative 14456 tracks the act, and the status of all battery regulation implementing acts is collected in one place.

The feedback period on the draft closed on 26 January 2026 with 91 responses. A draft binds no manufacturer: its proposed label format, sizes and layout have no legal effect until the Commission adopts the act and it enters into force.

The same initiative also covers the format of the carbon footprint label under Article 7(2). Once the act is adopted, its entry into force starts the 18-month period that fixes the application date of the general information, capacity and duration labels of Article 13(1) to (3).

Who Applies the Label and Who Checks It

The manufacturer applies the label: Article 38(1)(b) requires it to ensure that each battery it places on the market or puts into service is marked and labelled in accordance with Article 13. The full set of battery manufacturer obligations goes beyond labelling.

Four further roles check or take over the label, as listed below.

• Importers verify the CE marking, the Article 13 labels and the required documents before placing a battery on the market (Article 41(1) and (2)), and add their own contact details on the battery, or else on the packaging or an accompanying document (Article 41(3)).
• Distributors verify before making a battery available (Article 42(2)) the battery producer registration under Article 55, the CE marking and Article 13 labelling, the documents in the right language, and the Article 38(6), 38(7) and 41(3) identification.
• Own-brand sellers: an importer or distributor that places a battery on the market under its own name or trade mark, or modifies it, becomes the manufacturer (Article 44).
• Remanufacturers, repurposers and operators preparing batteries for re-use are manufacturers under Article 38(11).

These operator duties belong to Chapter VI of the Regulation and have applied since 18 August 2024 under Article 96(2), point (b). Since that date the label check has been part of every import and every sale through the supply chain.

Stock is protected. Recital 11 states that batteries placed in stock in the Union by distributors before the date of application of a requirement do not need to meet that requirement.

The recital covers distributor stock only; it gives no relief to a manufacturer or importer for batteries it places on the market after that date.

The CE marking is a separate mark beside the Article 13 labels, affixed visibly, legibly and indelibly before the battery is placed on the market (Article 20(1) and (2)). The notified body number follows it where Module D1 or G applies (Article 20(3)), as explained under CE marking for batteries.

How to Meet the Labelling Requirements

Label compliance is proven through the conformity assessment of Article 17, so build each label into the technical documentation before the first battery leaves the line. The six steps below follow the order in which a manufacturer meets the labelling requirements.

1. Confirm which battery category applies; it decides the capacity, duration and QR code rows.
2. List the elements that apply on the date of placing on the market, using the six-elements table.
3. Prepare the Annex VI, Part A, data and a label specimen for the technical documentation (Annex VIII, Part A, point 2).
4. Choose Module A or D1 for series production under Article 17(1) in the battery conformity assessment.
5. Cover Article 13 in the EU declaration of conformity (Article 18(1)) and keep it for 10 years (Article 38(4)).
6. Plan the QR code content for 18 February 2027 and check the Article 38(7) and 41(3) contact details, a formal requirement in battery regulation enforcement.

Missing paperwork is formal non-compliance. Article 83(1) lists a wrong or missing CE marking or notified body number, an EU declaration of conformity missing or not drawn up correctly, incomplete technical documentation and absent, false or incomplete Article 38(7) or 41(3) information.

If the non-compliance persists, the member state restricts or prohibits making the battery available, or has it withdrawn or recalled (Article 83(2)).

Need help with battery labelling? The full sequence by role and category is set out under the battery regulation compliance programme.

Relabelling, Smart Labels and Proposed Changes to the Label

A battery that is prepared for re-use, repurposed or remanufactured is labelled anew: Article 13(9) requires new labels or markings with change-of-status information accessible through the QR code. The new label tells the next user that the battery has changed status, as set out for second-life batteries.

Article 13(8) empowers the Commission to allow alternative smart labels by delegated act. No such delegated act had been adopted as of 13 November 2026, so the QR code of Article 13(6) is the only digital carrier a manufacturer plans for.

The proposal COM(2025) 981 of 10 December 2025 (procedure 2025/0397(COD)) is pending at the stage "Awaiting committee decision", indicative plenary 14 December 2026 (OEIL, as of 13 November 2026).

It would replace Annex VI, Part A, point 8 with substances of very high concern, other than mercury, cadmium and lead, at 0.1 % weight by weight or more.

The proposal COM(2025) 504 (procedure 2025/0134(COD)) is also pending: the agreed text was approved in committee on 14 July 2026, indicative plenary 23 November 2026 (OEIL, as of 13 November 2026). It would add a digital contact to the Article 38(7) and 41(3) details on the battery. Both proposals are tracked under battery regulation amendments.

Labelling Questions

Five questions recur about battery labels under the Regulation.

Is the QR code mandatory on batteries now?

No: the QR code of Article 13(6) is required on all batteries from 18 February 2027, not before. The battery passport that the QR code opens for LMT, electric vehicle and larger industrial batteries follows the same date.

Must batteries already in stock be relabelled?

No: recital 11 states that batteries placed in stock in the Union by distributors before the date of application of a requirement do not need to meet that requirement. Batteries placed on the market from that date must meet it.

Is a mercury (Hg) symbol still required?

No: the Regulation provides chemical symbols only for cadmium and lead (Article 13(5)); an Hg symbol is not a current obligation. The mercury content limit of Annex I is a separate rule.

What must a lithium-ion battery label show?

A lithium-ion battery follows the same Article 13 rules as any battery of its category: the chemistry is one of the general label items (Annex VI, Part A, point 7), and rechargeable portable, LMT and SLI lithium-ion batteries also carry a capacity label. Chemistry-specific rules are covered under lithium-ion batteries under the EU Battery Regulation.

What does the crossed-out wheeled bin on a battery mean?

It is the separate collection symbol of Article 13(4) and Annex VI, Part B, required on every battery since 18 August 2025 to mark it for separate collection. Above the cadmium or lead threshold, "Cd" or "Pb" sits beneath it.