COMMENT
challenges, it is explicitly defined in the Regulation and must be addressed. The QR code must also link to information that has traditionally been communicated through symbols and documentation. This includes the symbol for separate collection, which remains mandatory, and the chemical symbols for cadmium or lead where concentration thresholds of 0.002 per cent and 0.004 per cent, respectively, are exceeded. In addition, the EU Declaration of Conformity referred to in Article 18 must be made accessible digitally, along with the report referred to in Article 52(3), which relates to broader compliance obligations under the Regulation.
Finally, manufacturers must ensure that information regarding the prevention and management of waste batteries is available through the QR code. This content, defined under Article 74(1) points (a) to (f), is intended to support the Regulation’s wider objectives around sustainability, recycling and circularity and must be maintained throughout the battery’s life.
Implications for manufacturers For device manufacturers, the QR code requirement introduces an extra layer of regulatory responsibility. Under Regulation (EU) 2023/1542, the “manufacturer” is often defined as the entity placing the battery or battery-powered product on the EU market, rather than those producing the battery itself. Consequently, responsibility for QR code compliance may rest with the device manufacturer rather than the battery supplier.
This has practical implications for data ownership, hosting and long-term accessibility. QR-linked information must remain accurate and available over the battery’s lifetime. Therefore, manufacturers must consider how regulatory content is managed, updated and maintained. Furthermore, QR codes must be incorporated into product or packaging design in line with ISO/IEC marking standards, with the Regulation allowing placement on packaging or accompanying documentation where direct marking is not feasible due to size or format constraints.
Preparing for February 2027 It may seem distant now, but February 2027 will soon come around. In the meantime, manufacturers must identify which batteries in their portfolio will require passports and those that only require QR- linked declarations. They must assess what information is already available, where gaps exist and how regulatory data will be hosted
in a stable and compliant online location. Of course, non-compliance brings risks. This could be in the form of corrective action or product withdrawals and recalls – all causing significant damage to manufacturers’ reputations. Early engagement with the Regulation can help manufacturers clarify responsibilities and avoid last-minute compliance challenges. As a specialist battery manufacturer, Ultralife are actively working with customers to navigate the evolving regulations. While the technical data required under Article 13 is largely understood, structuring, maintaining and hosting that information in a way that meets regulatory expectations over the long term remains a challenge.
QR codes represent a major shift in battery packaging and labelling requirements – and they’re just a few months away from being mandatory in the EU. However, manufacturers still have time to familiarise themselves with the required changes and seek the technical advice required. Even the batteries that do not require full battery passports will need a QR code linking to technical information and documentation – and an experienced battery specialist can make the process easier. To find out more about battery manufacturing, including regulatory support, visit the Ultralife website or speak to a member of the engineering team.
SEPTEMBER 2026 | ELECTRONICS FOR ENGINEERS
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