Article 13 battery labels and consumer information

The base label is not just a recycling mark. Article 13 points to Annex VI Part A for general battery information, so the label file should be built from product master data rather than marketing copy.

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. Rechargeable portable batteries, LMT batteries, and 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.

This is a data-quality step, not a design preference. 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 need the separate collection symbol when the Article 13 marking requirement applies. 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.

Article 13 requires batteries to be marked with 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, conformity 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.