COMMENT
Preparing for QR codes: How device manufacturers can prepare their batteries for 2027
From February 2027, every battery sold in the EU must carry a QR code. Introduced under Article 13 of Regulation (EU) 2023/1542, this change represents a fundamental shift in how battery information is communicated, accessed and regulated. While QR codes are not new in themselves, the scope and regulatory intent behind these rule changes significantly impact both battery and device manufacturers. By Neil Oliver, senior technical marketing manager, Ultralife Corporation.
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t’s important to note that Regulation (EU) 2023/1542 is precisely that – a regulation, not a directive. At over 190 pages, this comprehensive piece of legislation replaces the previous Battery Directive that guided European standards. Unlike a directive, all requirements will apply uniformly across all EU member states.
Article 13 specifically addresses labelling and marking and makes clear that, from 18 February 2027, all batteries must be marked with a QR code (or have it present on the packaging or instructions) providing access to relevant battery information.
Declarations vs Passports One area of confusion has been the difference between QR codes for declarations and those for passports. Though similar and closely linked, these are not interchangeable. From February 2027, all batteries in the EU will require a QR code linking to a declaration, but only certain batteries will require a full battery passport. Battery passports will apply to batteries powering Light Means of Transport (LMT), such as e-scooters, segways and small electric bikes. They will also apply to industrial batteries with a capacity greater than 2 kWh and to those powering electric vehicles (EVs). For these batteries, the QR code must link to a digital battery passport in accordance with Article 77 of the Regulation.
Once a battery falls into the passport category, the regulatory requirements become significantly more complex. Battery
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passports are structured around three layers of information, covering data accessible to the public, data received for market surveillance authorities and the European Commission as well as information intended for parties with a legitimate interest, such as repairers, remanufacturers and recyclers. While the Regulation defines what information must be provided, it offers limited practical guidance on how access to these layers will be managed in practice.
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Article 13 specifically addresses labelling and marking and makes clear that, from 18 February 2027, all batteries must be marked with a QR code (or have it present on the packaging or instructions) providing access to relevant battery information.
The information behind the QR code
A full battery passport is unlikely to be needed for most batteries used in commercial, industrial and medical devices. However, there will still be a need to provide information digitally. For these batteries, the QR code must still link to a defined set of
SEPTEMBER 2026 | ELECTRONICS FOR ENGINEERS
data as laid out in Part A of Annex VI of the Regulation.
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At a minimum, this includes core product information such as the battery’s manufacturer, category, place and date of manufacture, weight, capacity and chemistry. Information must also be provided on any hazardous substances present, other than mercury, cadmium and lead, along with details of any usable extinguishing agent and the presence of critical raw materials where these exceed 0.1 per cent by weight.
Further information requirements may apply depending on battery type. For example, rechargeable portable batteries, LMT batteries and Starting, Lighting, Ignition (SLI) batteries must provide capacity information via the QR code, while non- rechargeable portable batteries must include details of their minimum average duration in specified applications. Although this latter requirement presents practical
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