From 18 February 2027, the EU Batteries Regulation (EU) 2023/1542 requires a QR code on every battery placed on the EU market. Most of the attention has gone to the battery passport for electric vehicle batteries, LMT batteries and industrial batteries above 2 kWh. But the Regulation also creates digital information obligations for batteries that need no battery passport at all:
- SLI batteries (starting, lighting and ignition, for example car starter batteries);
- portable batteries;
- industrial batteries with a capacity of 2 kWh or less.
These batteries are outside the battery passport of Article 77, which applies only to LMT batteries, industrial batteries above 2 kWh and electric vehicle batteries. Yet under Article 13(6), their QR code must still lead to a defined set of regulatory information, and part of that information belongs to the production batch, not to the battery model.
What must the QR code provide access to?
Article 13(6) states: "From 18 February 2027, all batteries shall be marked with a QR code". For batteries other than LMT, electric vehicle and industrial batteries above 2 kWh, point (b) requires the QR code to provide access to:
- the applicable information referred to in Article 13(1) to (5);
- the EU declaration of conformity under Article 18;
- the battery due diligence report under Article 52(3), where applicable;
- the information on prevention and management of waste batteries under Article 74(1)(a) to (f).
For SLI batteries, point (c) adds the amount of cobalt, lead, lithium or nickel recovered from waste and present in the battery, calculated in accordance with Article 8. The Regulation also requires that "this information shall be complete, up-to-date and accurate".
The general battery information: Annex VI, Part A
The most important cross-reference is Article 13(1), which refers to Part A of Annex VI. It lists the general information on batteries:
| Required information | Legal source |
|---|---|
| Information identifying the manufacturer | Annex VI Part A (1), Article 38(7) |
| Battery category and information identifying the battery | Annex VI Part A (2), Article 38(6) |
| Place of manufacture (geographical location of the manufacturing plant) | Annex VI Part A (3) |
| Date of manufacture (month and year) | Annex VI Part A (4) |
| Weight | Annex VI Part A (5) |
| Capacity | Annex VI Part A (6) |
| Chemistry | Annex VI Part A (7) |
| Hazardous substances present, other than mercury, cadmium or lead | Annex VI Part A (8) |
| Usable extinguishing agent | Annex VI Part A (9) |
| Critical raw materials above 0.1% weight by weight | Annex VI Part A (10) |
Two of these fields are not model attributes: the place of manufacture and the month and year of manufacture.
A note on timing. The QR code date is fixed: 18 February 2027. The label with the Annex VI information applies "from 18 August 2026 or 18 months after the date of entry into force of the implementing act referred to in paragraph 10, whichever is the latest" (Article 13(1)). That implementing act, which sets harmonised label specifications, had been published as a draft but not adopted as of early October 2026. Because Article 13(6)(b) refers to the applicable information, check the status of the act before relying on a date, and prepare the data now either way.
Why this creates a batch-level data requirement
Annex VI does not just ask for a battery model. It asks for information identifying the battery in accordance with Article 38(6), which requires manufacturers to ensure that batteries "bear a model identification and batch or serial number, or product number or another element allowing their identification".
Put the requirements together:
- The QR code (Article 13(6)(b)) must give access to the applicable information of Article 13(1).
- Article 13(1) refers to Annex VI, Part A.
- Annex VI requires the battery identification, the manufacturing plant and the month and year of manufacture.
Consider one battery model, produced twice:
| First production run | Second production run | |
|---|---|---|
| Model | ABC-100 | ABC-100 |
| Chemistry | Lead-acid | Lead-acid |
| Capacity | 80 Ah | 80 Ah |
| Batch | 240901 | 241101 |
| Manufacturing plant | Poland | Germany |
| Date of manufacture | September 2026 | November 2026 |
A single static web page showing "ABC-100, lead-acid, 80 Ah" cannot show the right plant and date for both runs. The system behind the QR code has to connect the scanned battery to the right production data.
This does not necessarily mean one QR code per battery
The Regulation does not require an individually serialised QR code on SLI, portable or small industrial batteries. It requires the relevant information to be accessible, and it lets manufacturers identify the battery by a batch number, serial number, product number or another suitable element.
Depending on how a manufacturer produces and identifies its batteries, the digital record can therefore sit at:
- model level plus batch, for example model ABC-100 with batch 240901; or
- item level, with a serial number, where that is needed.
The critical requirement is not serialisation. It is being able to show the information that belongs to the battery in hand. Because the manufacturing plant and date usually change from batch to batch, batch-level records will be the practical minimum for many manufacturers. That is a different requirement from linking every battery of a model to one static product page.
Additional information by battery category
Article 13 adds category-specific information:
- Capacity. Rechargeable portable batteries, LMT batteries and SLI batteries must carry information on their capacity (Article 13(2)).
- Non-rechargeable portable batteries must state their minimum average duration in specific applications and be labelled "non-rechargeable" (Article 13(3)).
- Separate collection symbol. All batteries must carry the crossed-out wheeled bin symbol since 18 August 2025 (Article 13(4)).
- Cd and Pb marking. Batteries containing more than 0.002% cadmium or more than 0.004% lead must carry the chemical symbol Cd or Pb (Article 13(5)).
Articles 13(2) and 13(3) follow the same timing as Article 13(1).
SLI batteries: recycled content behind the QR code
For SLI batteries, Article 13(6)(c) adds information on the cobalt, lead, lithium or nickel recovered from waste and present in the battery, calculated according to Article 8. Article 8(1) makes the underlying documentation mandatory "from 18 August 2028 or 24 months after the date of entry into force of the delegated act", whichever is later, and it is kept "for each battery model per year and per manufacturing plant". Not every field has to be filled on 18 February 2027, but each must be assessed against the date of its own provision.
The EU declaration of conformity
The QR code must also give access to the EU declaration of conformity under Article 18. It follows the model structure in Annex IX, must be kept up to date and is drawn up in electronic format. This makes the QR destination an access point to regulatory documentation, not a marketing page.
Waste prevention and end-of-life information
Article 74(1)(a) to (f) requires producers to inform end-users and distributors about:
- good practices that extend the use phase of batteries, and the options for re-use, repurposing and remanufacturing;
- their role in the separate collection of waste batteries;
- the separate collection, take-back and collection points available;
- safety instructions for handling waste batteries, including lithium batteries;
- the meaning of the labels and symbols on batteries and their packaging;
- the impact of hazardous substances on the environment, human health and safety, including from inappropriate disposal.
Article 13(6)(b) puts this information behind the QR code.
The battery due diligence report, where applicable
The QR code must also lead to the public due diligence report under Article 52(3), where one is required. Not every company needs one: the due diligence chapter does not apply to economic operators with a net turnover below EUR 40 million that are not part of a group exceeding that threshold (Article 47). Regulation (EU) 2025/1561 postponed the due diligence obligations to 18 August 2027.
QR battery information versus battery passport
| Battery category | QR code from 18 February 2027 | Battery passport (Article 77) |
|---|---|---|
| Portable battery | Yes | No |
| SLI battery | Yes | No |
| Industrial battery up to 2 kWh | Yes | No |
| Industrial battery above 2 kWh | Yes | Yes |
| LMT battery | Yes | Yes |
| Electric vehicle battery | Yes | Yes |
The first three categories need no battery passport, but they still need a structured digital information solution behind their QR codes.
A static QR page will often not be enough
The required information combines model-level and production-level data:
- Model data: battery model, chemistry, capacity, weight, hazardous substances, extinguishing agent, critical raw materials, waste and recycling information, declaration of conformity.
- Production or batch data: batch, serial or product number, manufacturing plant, month and year of manufacture.
Manufacturers therefore need more than a QR code generator. They need a system that identifies the battery, finds the matching production record, shows the right regulatory information and keeps it available and up to date. The Regulation does not call this a battery passport for SLI, portable or small industrial batteries, but technically it looks very much like a lightweight one.
How GoodsTag supports these requirements
GoodsTag provides the digital infrastructure for this, so manufacturers do not have to build a regulatory platform themselves. A manufacturer creates a digital record for each battery model, with its general regulatory data, declaration of conformity, waste and recycling information and documentation, and extends it with batch or item data: the batch identifier, manufacturing plant and date.
The physical battery is connected to the right record through its QR code, at model, batch or item level, for example with a GTIN combined with a batch or lot number via GS1 Digital Link where that fits. GoodsTag connects to ERP, MES, PIM and production systems, so production site, date and batch number do not have to be maintained by hand.
The same platform covers both regimes: QR-linked battery information for SLI, portable and small industrial batteries, and the full battery passport for industrial batteries above 2 kWh, LMT and electric vehicle batteries. Read more about our Battery DPP or talk to our team.
The key takeaway
The Batteries Regulation should not be read as "only batteries with a battery passport need digital information". From 18 February 2027, every battery needs a QR-based access point. For SLI, portable and industrial batteries up to 2 kWh, that QR code must lead to the applicable regulatory information, even without an Article 77 battery passport. Because that information includes the battery identification, the manufacturing plant and the month and year of manufacture, manufacturers need to manage data below model level, in many cases per batch.
Sources
- Regulation (EU) 2023/1542 on batteries and waste batteries, Articles 8, 13, 18, 38, 47, 52, 74 and 77, Annex VI
- Regulation (EU) 2025/1561 postponing the battery due diligence obligations
- Batteries at the European Commission
This article reflects the legal situation as of 8 October 2026 and is not legal advice.
