Article 13 battery labels and consumer information

Article 13 covers all five battery categories, including batteries incorporated into products and cells or modules supplied for end use as batteries. Regulation (EU) 2023/1542 excludes batteries incorporated into or specifically designed to be incorporated into equipment tied to Member States' essential security interests, arms, munitions or war material, except non-military products, and batteries incorporated into or specifically designed to be incorporated into equipment designed for space. Chapter III, which contains Article 13, also does not apply to equipment specifically designed for the safety of nuclear installations. Record the scope decision before selecting label fields.

The base label is separate from the already-applicable collection mark. Article 13 points to Annex VI Part A for general battery information, but that label begins on the later of 18 August 2026 or 18 months after the Article 13(10) implementing act enters into force. Build the file from product master data and record the implementing act used to calculate the release date.

The label inventory should identify the manufacturer, battery category, product identifier, manufacturing location, month and year of manufacture, weight, capacity, chemistry, hazardous substances other than mercury, cadmium or lead, usable extinguishing agent, and critical raw materials present above 0.1% weight by weight.

Article 13 uses the battery category to decide which performance notice belongs on the label. From the same act-dependent date as the general label, rechargeable portable batteries, light means of transport (LMT) batteries, and starting, lighting and ignition (SLI) batteries need capacity information. Non-rechargeable portable batteries need minimum average duration information for specific applications and a label indicating that the battery is non-rechargeable.

The release record should show which test value, declared capacity, or duration claim feeds the printed label and who approved it for the specific battery category.

All batteries have needed the separate collection symbol since 18 August 2025. The Regulation also gives sizing rules for the symbol and a packaging fallback where the battery is too small for the required symbol.

Article 13 separately requires Cd or Pb chemical symbols when cadmium or lead exceeds the stated thresholds. Those heavy-metal symbols are printed beneath the separate collection symbol and sized relative to that symbol, so substance classification and label layout have to be reviewed together.

From 18 February 2027, Article 13 requires every battery to carry a QR code and says the information reached through it must be complete, up-to-date, and accurate. The destination depends on the battery type: for LMT batteries, industrial batteries with a capacity greater than 2 kWh, and electric-vehicle batteries, the QR code provides access to the battery passport; for other batteries it provides access to Article 13 label information, the declaration of conformity, the due diligence report where relevant, and waste-battery information; for SLI batteries it also covers recovered-material information.

Annex VI adds a practical design control: the QR code must be high contrast and easily readable by commonly available QR readers. Treat the QR as part of the release package, with scan testing before launch and change control after launch.

Article 13 prefers the battery itself: labels and QR codes are printed or engraved visibly, legibly, and indelibly on the battery. Packaging and accompanying documents are the fallback only where battery nature or size makes direct marking impossible or not warranted.

The implementation file should therefore show why a fallback was used, where the information appears instead, and how the package or document remains tied to the exact battery model.

A defensible Article 13 file should let a reviewer trace each visible statement from source data to artwork. Keep it narrow: battery category, Annex VI fields, capacity or duration notice, separate collection symbol, Cd/Pb decision, QR target, packaging fallback, and post-launch update ownership.

The evidence file should also include the specimen label because the Regulation's conformity documentation references the label required under Article 13. That specimen should match the product version actually placed on the market.