Battery Passport Labeling: QR Codes, Labels and Symbols

Why Battery Passport Labeling Must Be Physical

Battery passport labeling is more than a digital data sheet. The battery passport itself is a purely digital document, but access to this document must be provided through a QR code physically applied to the battery. This is unambiguously mandated by the EU Battery Regulation (EU 2023/1542).

How labeling works for compact batteries is shown on the battery passport for e-bike and LMT batteries page.

The logic is straightforward: a battery passport is useless if it only exists in a database. Inspectors, recyclers, market surveillance authorities and end users must be able to find the passport directly on the physical product, without knowledge of internal systems, without serial number lookups, without registration. A smartphone scan must suffice.

Article 77(3) of the Regulation specifies: the QR code must be placed directly on the battery or, where this is technically not feasible, on the packaging or in the accompanying documents. The battery itself takes priority.

This makes battery passport labeling the bridge between the physical world and the digital data record. The following sections cover what requirements the QR code must meet, which additional labels are mandatory, and how to implement labeling in practice.

QR Code: Requirements and Specifications

The QR code on the battery is not just any sticker. The EU Battery Regulation and DIN SPEC 99100 define concrete technical requirements that go beyond mere scannability.

Minimum Size and Placement

The Regulation does not prescribe an exact minimum size in millimeters, but the QR code must be reliably scannable under realistic conditions. In practice, this means:

• At least 15 × 15 mm for industrial applications
• At least 10 × 10 mm for batteries with limited space (e.g. cylindrical cells)
• A quiet zone (clear area around the QR code) of at least 4 module widths
• Placement in a clearly visible location that remains accessible when installed

Error Correction Level

QR codes support four error correction levels (L, M, Q, H). For battery applications, at least Level M (15% error correction) is recommended. Level Q (25%) is better. Batteries are exposed to mechanical stress, vibrations and abrasion. A higher error correction level ensures the code remains readable even after partial damage.

Contrast and Material Resistance

The QR code must remain readable throughout the entire expected lifetime of the battery. This places requirements on:

• Contrast ratio: Black on white or comparable contrast. Colored QR codes are risky.
• UV resistance: The code must not fade, especially in outdoor applications (solar systems, electric vehicles).
• Chemical resistance: No degradation from electrolytes, cleaning agents or moisture.
• Temperature resistance: Industrial batteries operate at temperatures from −20°C to +60°C.

Encoded Information

The QR code must link to the battery passport, not to a marketing page, not to a generic product page. The encoded URL should be a unique, permanent address through which the complete battery passport is accessible in machine-readable form. How this URL should be structured is covered in the section on GS1 Digital Link.

Labeling Requirements from August 2026: The Dress Rehearsal

The complete battery passport becomes mandatory on 18 February 2027. But expanded labeling requirements already take effect from 18 August 2026, a dress rehearsal for manufacturers and importers.

The table shows which markings apply, from when, and on which legal basis. Three of them are already mandatory today, only the QR code follows in February 2027:

The complete EU Battery Regulation timeline shows: the labels due from August 2026 cover most of what you need for the battery passport anyway. Collection symbol, chemical symbols and CE marking already apply today: the separate collection symbol under Article 13(4) has been mandatory since 18 August 2025, and the QR code follows later, on 18 February 2027. The general labeling under Article 13(1) to (3) applies from 18 August 2026 or 18 months after the implementing act under paragraph 10 enters into force, whichever is later, so the labeling processes should be up and running rather than just planned.

Battery Passport Labeling: Mandatory Labels and Symbols

Physical battery passport labeling encompasses far more than the QR code. Article 13 of the EU Battery Regulation defines a range of mandatory labels that must be applied to every covered battery.

QR Code Linking to Battery Passport

The QR code is the digital key to the battery passport. It must encode a URL that links directly to the complete battery passport. All mandatory information must be accessible through this link, from material data to the carbon footprint to recycling instructions. When you create a battery passport with DPP Hero, you automatically receive a permanent URL and a print-ready QR code.

CE Marking

The CE mark confirms that the battery meets applicable EU harmonization legislation. It must be applied to the battery in a visible, legible and permanent manner. The minimum height is 5 mm. For batteries too small for direct application, the CE marking may appear on the packaging or accompanying documents.

Separate Collection Symbol (Crossed-Out Wheelie Bin)

The crossed-out wheelie bin symbol indicates that the battery must not be disposed of in household waste but must be collected separately. This symbol has been familiar since the old Battery Directive (2006/66/EC) and remains mandatory under the new Regulation. Under Art. 13(4) it must cover at least 3 percent of the area of the largest side of the battery, up to a maximum size of 5 × 5 cm; for cylindrical cells the minimum is 1.5 percent of the surface area. Where the symbol would come out smaller than 0.47 × 0.47 cm, the battery is not marked at all and a symbol of at least 1 × 1 cm is printed on the packaging instead.

Chemical Symbols for Hazardous Substances

If the battery contains more than 0.002% cadmium (Cd) or more than 0.004% lead (Pb), the corresponding chemical symbols must be placed below the wheelie bin symbol. Each symbol must cover an area of at least one quarter of the wheelie bin symbol.

Capacity Rating

The rated capacity of the battery must be stated in watt-hours (Wh) and, for certain battery types, additionally in ampere-hours (Ah). This information must be clearly visible and permanent.

Battery Type and Chemistry

The labeling must indicate the battery type (e.g. lithium-ion, nickel-metal hydride) and the specific cell chemistry (e.g. NMC, LFP, NCA). This information is critical for proper handling, transport and recycling.

Manufacturer Information

The name and postal address of the manufacturer or authorized representative must appear on the battery. This includes company name, street, postal code, city and country. These details correspond to the economic operator information stored in the digital battery passport.

Date of Manufacture and Weight

The date of manufacture (month and year) and the weight of the battery in kilograms must be stated on the product. Weight refers to the total weight including the housing.

What exactly has to be on the label

Annex VI Part A lists the general information that belongs on every battery: details identifying the producer, the battery category and the identification of the battery, the place of manufacture, the date of manufacture with month and year, weight, capacity, chemical composition, hazardous substances present other than mercury, cadmium or lead, the extinguishing agent to be used, and critical raw materials present above 0.1 percent by mass. The identification of the battery under Article 38(6) is where the model, batch or serial number goes.

On top come entries by battery type. Rechargeable portable batteries, LMT batteries and starter batteries carry their capacity under Article 13(2). Non-rechargeable portable batteries carry, under paragraph 3, the minimum average duration when used in specific applications and expressly the wording “non-rechargeable”.

For the separate collection symbol, paragraph 4 gives hard dimensions: at least 3 percent of the largest side surface, no more than 5 × 5 cm. For cylindrical cells it is at least 1.5 percent of the surface. If the symbol would fall below 0.47 × 0.47 cm, it is omitted from the battery and printed on the packaging at no less than 1 × 1 cm instead. Where a battery contains more than 0.002 percent cadmium or more than 0.004 percent lead, paragraph 5 adds the chemical symbol Cd or Pb underneath, at least a quarter the size of the collection symbol.

Paragraph 7 covers how it is applied: visibly, legibly and indelibly printed or engraved. Only where the nature and size of the battery do not allow or justify that may the marking and the QR code move to the packaging and accompanying documents.

Two points that planning often misses. First, time: producers keep the technical documentation and the EU declaration of conformity available for ten years from placing on the market under Article 38(4), and importers likewise under Article 41(7). Whatever the QR code makes reachable therefore has to stay reachable across that span. Second, collection information: which take-back points are named depends on the member state and its producer responsibility organisations. Ship into several countries and you coordinate that per country.

What the Regulation does not require, incidentally, is polarity marking or a do-not-charge symbol. Both come from product standards for primary batteries, not from the Battery Regulation. Applying them is a safety or standards decision, not an Article 13 duty.

Label Durability

All labels must survive the expected lifetime of the battery. This sounds obvious, but in practice it is one of the biggest challenges. A traction battery in an electric vehicle has an expected lifetime of 10 to 15 years. A QR code sticker that peels off after three years does not meet the requirements.

The Regulation requires that labels:

• Remain visible and legible throughout the entire lifetime
• Are not easily removable (no simple paper stickers)
• Are resistant to UV radiation, moisture, chemicals, temperature changes and mechanical abrasion

Proven Materials

Choosing the right labeling material belongs on the battery passport checklist that every manufacturer should complete before the deadline.

GS1 Digital Link as the QR Standard

A QR code can encode any URL. But DIN SPEC 99100 recommends a specific standard for the URL encoded in the QR code: the GS1 Digital Link.

The GS1 Digital Link combines the GTIN (Global Trade Item Number) of a product with the serial number of the individual unit in a standardized URL structure:

https://id.example.com/01/04012345678901/21/SN12345

This URL is globally unique, machine-readable and enables authorities and economic operators to find the battery passport without proprietary software. A regular QR code with an arbitrary URL (e.g. https://company.com/battery/12345) works technically, but it is not interpretable by third parties without knowledge of the manufacturer's URL structure.

The advantages of GS1 Digital Link for battery passport labeling:

• Interoperability: Every actor in the supply chain can read and understand the QR code
• Machine readability: Automatic assignment of GTIN and serial number without manual input
• Resolver function: Through content negotiation, the same URL can deliver different formats: HTML for humans, JSON-LD for machines
• Future-proofing: GS1 is the globally established standard for product identification

Detailed information on GS1 Digital Link and its role in the battery passport can be found in our article on GS1 Digital Link. What GS1 Germany does in detail is described on our page GS1 Germany.

Practical Implementation of Labeling

The requirements are clear, but how do you implement them in production? Here are proven approaches for practical battery passport labeling:

Plan the Placement

Define a labeling zone on the battery housing before production starts. This zone must:

• Be accessible when installed (not covered by cable ducts or mounting brackets)
• Provide sufficient space for the QR code, CE mark, wheelie bin symbol, capacity rating and manufacturer information
• Be reachable by service technicians without having to remove the battery

Consolidate Label Design

Rather than applying individual stickers for each mandatory element, a consolidated label design is recommended. A single nameplate or label zone can combine all mandatory information:

• QR code (top left or top right, prominent)
• CE mark and wheelie bin symbol (adjacent)
• Text block with manufacturer, type, chemistry, capacity, weight, date
• Hazardous substance symbols (if applicable) below the wheelie bin symbol

Synchronize Digital and Physical Data

The information on the physical label must match the data in the digital battery passport. A discrepancy between physical marking and digital record, such as a differing capacity rating, can lead to objections during market surveillance inspections.

In DPP Hero, you enter all product data once in a central location and export it both as a digital battery passport and as the basis for your nameplate. This prevents inconsistencies between physical and digital labeling.

Integrate into the Production Workflow

Integrate labeling into your existing production workflow:

• Data generation: Serial number and QR code URL are generated during production
• Print trigger: The label is printed inline (laser engraving or label printer)
• Quality check: Automatic scan after printing to verify readability
• Data upload: Simultaneous creation or update of the digital battery passport

The sooner you establish this process, the less effort will be needed by the deadline. The battery passport mandatory dates leave little room for last-minute changes.

From 2027 every battery needs a QR code

This is often shortened to the three passport categories. But Article 13(6) says: from 18 February 2027 all batteries carry a QR code. Only the destination differs.

• LMT batteries, industrial batteries above 2 kWh, electric vehicle batteries: to the battery passport under Article 77.
• All other batteries: to the EU declaration of conformity under Article 18, the due diligence report under Article 52(3) and the waste prevention information under Article 74(1)(a) to (f).
• Starter batteries in addition: to the amount of recovered cobalt, lead, lithium or nickel in the active materials, calculated under Article 8.

The text closes with a requirement that is easily missed: this information has to be complete, up to date and accurate. A QR code pointing at an outdated declaration of conformity does not discharge the obligation.

Why there is no mercury symbol

Anyone familiar with the old Batteries Directive looks for the Hg mark on the label. The new Regulation does not have it, and there is a logical reason. Article 13(5) requires the chemical symbol only for cadmium above 0.002 per cent and lead above 0.004 per cent. Mercury, by contrast, is restricted under Annex I to a mass fraction of 0.0005 per cent, well below any labeling threshold. A battery that stays within the limit cannot reach the threshold at all.

In practice: do not print an Hg symbol. It is not required and would be incorrect labeling.

The harmonised label format is still outstanding

Article 13(10) provides for an implementing act laying down harmonised specifications for labeling and the label format. Until it exists there is no official layout you could or would have to follow. Several labeling duties under Article 13 even hang on it: paragraph 3 applies only from 18 August 2026 or 18 months after that act enters into force, whichever is later.

You can still prepare: the space on the battery has to be sufficient, and the requirements in Annex VI Parts B and C are already fixed. The separate collection symbol must cover at least 3 per cent of the largest side, capped at 5 × 5 cm; for cylindrical cells at least 1.5 per cent of the surface. If you are reissuing labels now, plan for these areas already.

Two further markings: the carbon footprint label and safety information

Alongside the Annex VI label, the Regulation knows a second physical marking that is often confused with the passport. Article 7(2) requires electric vehicle batteries, rechargeable industrial batteries above 2 kWh and LMT batteries to carry a “clearly visible, legible and indelible” marking showing the carbon footprint of the battery and stating the performance class into which the model falls per manufacturing plant. That is print on the battery, not merely a field in the passport.

It does not apply yet. The carbon footprint obligations depend on legal acts on methodology and format that the Commission has not adopted, and the Commission guidance of 15 August 2026 expressly lists the carbon footprint declaration and label as not to be filled in as of February 2027. Plan the label area today by all means, but do not tell anyone the duty is already here.

The second addition concerns appliances with a built-in battery. Under Article 11(1) they must be accompanied by instructions and safety information for the use, removal and replacement of the battery. The same information must also be made available to end users online, on a publicly accessible website, permanently and in an easily understandable form. A QR code that dead-ends once the model leaves the range does not meet that.

The individual identifier: which standard it has to meet

The QR code is one half, the identifier behind it the other. Article 77(3) sets out what it must follow: “The QR code and the unique identifier shall comply with ISO/IEC standards 15459-1:2014, 15459-2:2015, 15459-3:2014, 15459-4:2014, 15459-5:2014 and 15459-6:2014 or equivalent standards.”

That series covers unique identifiers for transport units, registration procedures, common rules, individual items, returnable transport items and product groupings. What matters in practice is the consequence: the identifier applies per unit, not per model. A passport using the same identifier for every item of a type does not meet the requirement.

So when picking a numbering scheme, check two things. First, whether it meets one of the named standards or is equivalent. Second, whether it leaves room for the volumes of the coming years. An identifier issued twice is worse than none, because then two batteries show the same passport.

Warnings: what the Battery Regulation requires, and what it does not

Many packs carry warning symbols about fire, water or children. The Battery Regulation does not require them. What it does require is narrower and comes down to three points.

First, Annex VI Part A point 9 puts the extinguishing agent to be used on the label. That is the only fire-related mandatory entry.

Second, Article 19(4) expressly allows the CE marking and identification number to “be followed, where appropriate, by a pictogram or any other marking indicating a special risk, use or any hazard linked to the use, storage, treatment or transport of the battery”. Allowed, not required: applying warning pictograms is a product safety decision or follows from other rules.

Third, appliances with a built-in battery must under Article 11(1) be accompanied by instructions and safety information for use, removal and replacement, and the same information must be permanently available online. That is where temperature and storage guidance belongs, not necessarily on the label.

What the Regulation does not know: a duty to warn about child safety. The term fire hazard does not appear in it at all, and children appear only among the social risks covered by the due diligence rules. Such warnings come from product safety law; they are sensible, but they satisfy no requirement of the Battery Regulation.

FAQ

Must the QR code be on the battery itself, or is the packaging sufficient?

The EU Battery Regulation gives priority to direct application on the battery. Only if the battery's size makes this technically unfeasible may the QR code be placed on the packaging or in accompanying documents. For traction and industrial batteries, direct application is generally feasible and required.

What happens if the QR code becomes unreadable?

If the QR code becomes unreadable during the battery's lifetime, the economic operator is in breach of the Regulation's labeling obligations. This can lead to corrective measures during market surveillance inspections. This is why choosing a durable marking method (laser engraving, polyester labels) is critical.

Which QR code format is used for the battery passport?

The Regulation prescribes a QR code as the data carrier (Art. 77). The encoded content should follow the GS1 Digital Link standard, which encodes the GTIN and serial number in a URL structure. Technically, it is a standard QR code according to ISO/IEC 18004.

Do the labeling requirements also apply to batteries under 2 kWh?

The general labeling requirements (CE mark, wheelie bin symbol, capacity, manufacturer details) apply to all battery categories. The digital battery passport and thus the QR code linking to the passport is mandatory from February 2027 for industrial batteries above 2 kWh, traction batteries and LMT batteries. For e-bike and e-scooter batteries (LMT), the same deadlines apply.

Can I generate the QR code with DPP Hero?

DPP Hero automatically generates a QR code for every published product that links to the digital battery passport. You can download this QR code as a PNG or SVG file and integrate it into your label design. The step-by-step guide shows the entire process from data entry to print-ready QR code.