EU Batteries Regulation QR code and label timing

Article 13 sets several label clocks. The Cd or Pb marking rule has applied with the Regulation since 18 February 2024 when a battery exceeds 0.002% cadmium or 0.004% lead. The separate collection symbol applies from 18 August 2025. General battery labels, capacity labels for rechargeable portable, light means of transport (LMT) and starting, lighting and ignition (SLI) batteries, and non-rechargeable portable battery duration and non-rechargeable labels apply from 18 August 2026 or 18 months after the Article 13(10) implementing act enters into force, whichever is later.

The QR code clock is separate. From 18 February 2027, all batteries must be marked with a QR code described in Annex VI Part C. For LMT batteries, industrial batteries above 2 kWh, and electric vehicle batteries, that QR code must provide access to the battery passport under Article 77.

The general label content comes from Annex VI Part A. It includes manufacturer identification, battery category and identifying information, place and date of manufacture, weight, capacity, chemistry, hazardous substances other than mercury, cadmium or lead, usable extinguishing agent, and critical raw materials above 0.1% weight by weight.

Article 13 also adds targeted markings: capacity for rechargeable portable, LMT and SLI batteries; minimum average duration and a non-rechargeable label for non-rechargeable portable batteries; a separate collection symbol for all batteries; and Cd or Pb chemical symbols where cadmium or lead thresholds are exceeded.

For LMT batteries, industrial batteries with a capacity greater than 2 kWh, and electric vehicle batteries, the QR code must open the Article 77 battery passport through a unique identifier attributed by the economic operator placing the battery on the market. Article 77 requires the passport from 18 February 2027 for those battery categories.

For other batteries, Article 13(6) points the QR code to the applicable Article 13 label and marking information, the EU declaration of conformity, the Article 52(3) due diligence report where that report applies, and waste-prevention and management information. For SLI batteries, the QR code must also provide recovered cobalt, lead, lithium or nickel information calculated under Article 8.

A battery that has been prepared for re-use, prepared for repurposing, repurposed, or remanufactured needs new Article 13 labels or markings. Its change of status must also be available through the QR code.

Article 13(10) requires the Commission to adopt implementing acts for harmonised specifications for the Article 13(1), (2), and (3) labelling requirements. That dependency matters because those label obligations apply from 18 August 2026 or 18 months after that implementing act enters into force, whichever is later.

Separate delegated-act powers cover future changes to smart labels and passport information. Article 13(8) allows delegated acts for alternative smart labels instead of, or in addition to, the QR code. Article 77 allows delegated acts to amend Annex XIII passport information and the QR-code or unique-identifier standards. Article 77(9) separately requires implementing acts specifying legitimate-interest access and permitted download, sharing, publication, and reuse rights.