QR codes on batteries: mandatory from 2027.
From 18 February 2027 every battery placed on the EU market must carry a QR code - not just the ones with a battery passport. This guide explains, in plain language, what Article 13 of EU Battery Regulation 2023/1542 actually requires, how the code must look and why an ordinary QR generator will not cut it.
- The QR obligation covers all batteries. Article 13(6) requires a QR code on every battery from 18.02.2027 - from portable cells to industrial storage.
- The code has two possible targets. For EV, LMT and industrial batteries above 2 kWh it opens the digital battery passport; for all others, the mandatory labelling information.
- The design is regulated. High contrast to the background colour (since the 2024 corrigendum, instead of "100 % black"), easily readable by common scanners, printed or engraved - visible, legible and indelible (Annex VI Part C, Art. 13(7)).
- Static links are not enough. Passport batteries need a unique identifier per unit and a link that stays resolvable for years - which is why the GS1 Digital Link has become the standard.
One QR code, two jobs
The QR obligation is often confused with the battery passport obligation - but they are two different rules sharing the same code. Where the scan leads depends on the battery category:
| Battery category | Where the QR code must lead | Target |
|---|---|---|
| Electric vehicle batteries (EV) | Digital battery passport (Art. 77) | Passport |
| LMT batteries (e-bike, e-scooter …) | Digital battery passport (Art. 77) | Passport |
| Industrial batteries > 2 kWh | Digital battery passport (Art. 77) | Passport |
| Industrial batteries ≤ 2 kWh | Labelling info (Art. 13(1)–(5)), declaration of conformity & waste-battery information | Label info |
| Starter batteries (SLI) | Recovered cobalt, lead, lithium & nickel (Art. 8) - in addition to the labelling info | Recycled content |
| Portable batteries | Labelling info (Art. 13(1)–(5)), declaration of conformity & waste-battery information | Label info |
Simplified overview per Art. 13(6) of Regulation (EU) 2023/1542. Not sure which category your battery falls into? The eligibility check tells you in 90 seconds.
The road to 18 February 2027
The QR obligation is no surprise - it is the final building block in a chain of deadlines running since 2023:
Regulation enters into force
EU Battery Regulation 2023/1542 replaces the old batteries directive. The transition periods start running.
"Separate collection" symbol becomes mandatory
All batteries carry the crossed-out wheeled bin symbol (Art. 13(4)) - the regulation's first labelling building block goes live.
Delegated acts for the battery passport
By this date the Commission must define the technical details - including access rights and the rules for updating passport data.
QR code on every battery + battery passport
From now on both apply at once: QR labelling for all batteries (Art. 13(6)) and the digital battery passport for LMT, EV and industrial batteries above 2 kWh (Art. 77).
As of July 2026: details still in progress
Some harmonised standards and implementing acts (e.g. who counts as having a "legitimate interest") are still being finalised. The 18.02.2027 deadline is fixed - waiting for the last detail rule only costs preparation time.
What the QR code must look like
Annex VI Part C keeps the design rules deliberately lean - instead of millimetre specs there are three clear principles:
The code needs high contrast to the background colour. The original "100 % black" requirement was relaxed by a corrigendum in April 2024 - black on white remains the safe default, though.
It must be easily readable by commonly available readers. As a technical basis the regulation recommends ISO/IEC 18004 - the standard behind every ordinary QR code.
Printed or engraved - visible, legible, indelible (Art. 13(7)). Only if the nature or size of the battery does not allow it may the code move to the packaging and accompanying documents.
Practical trap: the code has to survive a battery's lifetime
"Indelible" means the code must stay scannable after years of use - heat, vibration, cleaning. A paper sticker on the housing of an industrial storage unit will quickly fail that test. Laser engraving or durable labels are the safe route.
Why the GS1 Digital Link is becoming the standard
The regulation does not prescribe a specific link structure - but it sets requirements that a plain static link can hardly meet. The GS1 Digital Link solves exactly these points:
One code for humans and machines
The Digital Link encodes the product and serial number directly in the URL. The same scan shows consumers the public passport view, while recycler systems and market surveillance resolve the same identifier programmatically and access deeper data levels.
There is also a hard requirement: Article 77(3) demands that the QR code and the unique identifier comply with the ISO/IEC 15459 series - GS1 is one of the issuing agencies foreseen there, which makes the Digital Link the obvious choice.
Combined with the data model of DIN DKE SPEC 99100 and interoperable standards like Catena-X, the result is a passport that works the same way across the EU - instead of one island solution per manufacturer.
- Unique identifier per unit, not just per model
- Target URL stays resolvable for years
- One code covers the passport duty and retail (Sunrise 2027)
From model to unit: the real effort
The battery passport applies per battery, not per model. If you sell 10,000 storage units of one type, you need 10,000 passports with 10,000 unique QR codes - the model data is identical, the serial numbers and unit data are not. Three steps get you there:
Capture all model-wide mandatory fields once - chemistry, carbon footprint, recycled content, dismantling information.
Generate a unique identifier for every produced unit and link it to the model - thousands of times, automated instead of by hand.
Generate a GS1 Digital Link QR per unit and hand it to production ready for printing or engraving.
For the step-by-step guide on how to create a battery passport with a QR code, see the five-step walkthrough.
Frequently asked questions about the QR code
When does the QR code on batteries become mandatory?
Do really all batteries need a QR code - or only those with a battery passport?
Is there a prescribed minimum size for the QR code?
Is an ordinary QR code generator enough for the battery passport?
What happens if the QR code is missing or does not work?
Sources & further reading
Serialised battery passports with GS1 Digital Link QR - per unit, automatically.
Batteriepasswerk turns one model template into thousands of passports with unique QR codes - compliant with EU 2023/1542 and DIN DKE SPEC 99100, hosted in the EU.