EU Battery Regulation

From February 2027, batteries must carry a QR Code in accordance with the EU Battery Regulation. This applies to all categories of batteries sold or used within the EU. Failure to comply with the requirements of the EU Battery Regulation may result in substantial fines. This article explains what you, as a manufacturer or importer, need to know. 

The EU Battery Regulation (Regulation (EU) 2023/1542) applies to all categories of batteries sold or used in the EU. It is gradually replacing the ‘old’ Battery Directive and aims to ensure sustainability throughout the entire life cycle of batteries.

The aim is to prevent or reduce the negative environmental impacts of batteries and to protect human health and the environment by minimising the negative effects of the generation and management of waste batteries.

The EU Battery Regulation includes provisions on sustainability and safety requirements for batteries, requirements regarding the labelling of batteries, and information requirements for batteries, including the so-called Digital Battery Passport.

The EU Battery Regulation is in force since August 2023. Most of its provisions apply since February 2024. One exception to this is the requirement that all batteries must bear a QR Code – this becomes mandatory from 18 February 2027 onwards. The information that must be provided via the QR Code varies depending on the battery:

• if a Digital Battery Passport is required for the battery in question, it must be accessible via the QR Code
• see article Digital Battery Passport; this is required for LMT batteries (light means of transport, e.g. e-bikes), industrial batteries with a capacity of more than 2 kWh and electric vehicle batteries. See Digital Battery Passport article.
• if a Digital Battery Passport is not required for the battery in question, certain ‘basic information’ must still be accessible via the QR Code.

The following ‘basic information’ must be provided via the QR Code in accordance with Article 13(6)(b) and (c) of the EU Battery Regulation:

• information identifying the manufacturer
• the battery category and information identifying the battery
• place and date of manufacture
• weight
• capacity
• chemistry
• hazardous substances present in the battery, other than mercury, cadmium or lead
• usable extinguishing agent
• critical raw materials present in the battery in a concentration of more than 0.1% weight by weight
• rechargeable portable batteries: information on their capacity
• non-rechargeable portable batteries: the label ‘non-rechargeable’ and information on their minimum average duration for specific applications
• the ‘separate collection’ symbol
• batteries containing more than 0.002% cadmium or more than 0.004% lead: the chemical symbol for the metal concerned (Cd or Pb)
• declaration of conformity
• the report on the battery due diligence policy
• information regarding the prevention and management of waste batteries
• for SLI (starting, lighting and ignition) batteries: the amount of cobalt, lead, lithium or nickel recovered from waste and present in active materials in the battery

The Digital Battery Passport is a structured digital record containing all key information relating to the entire life cycle of the battery concerned. A QR Code must be affixed to the battery (or its packaging) to provide access to the Digital Battery Passport.

The Digital Battery Passport will be mandatory from 18 February 2027 for LMT batteries (light means of transport, e.g. e-bikes), industrial batteries with a capacity of more than 2 kWh and electric vehicle batteries.

Find out more about the Digital Battery Passport in our article Digital Battery Passport.

The EU Battery Regulation harmonises and standardises the legal framework for batteries. As a legally binding framework, it is designed to promote environmental responsibility, consumer safety and energy efficiency within the European Union. Failure to comply may result in substantial fines.

The requirement that all batteries must carry a QR Code providing digital access to certain information, which applies from February 2027 onwards, poses certain challenges for IT systems, particularly when dealing with a broad product portfolio – such as:

• How do I generate the necessary QR Codes?
• Where and how do I host the required information to ensure it is accessible at all times?
• My data is already structured within a PIM or ERP system; how can I make it available automatically?
• Can I also use the QR Code to provide my customers with additional, non-mandatory information?
• Can I also use the QR Code for analytical purposes to generate additional value?

You should already start addressing all these questions and look for suitable solutions so that you can be sure of meeting the regulatory requirements by February 2027, rather than having to complete an implementation project last-minute.

With QR Planet, you have a globally operating partner based in Austria who offers a web-based platform for creating QR Codes, the opportunity to generate and manage product information (automatically), and, on top of that, the possibility for next-level product marketing – all from a single source.

• We have over 10 years of experience with enterprise QR Code solutions
• are GDPR-compliant
• host your data in Europe
• provide ISO/IEC 15459-compliant GS1 QR Codes with Digital Link (see also article GS1 QR Code Management 
• offer a one-stop-shop solution for modern product labelling
• support you in meeting regulatory requirements
• offer consultancy and, on request, end-to-end system integration with your PIM/ERP from a single source

Article 93 of the EU Battery Regulation delegates to the EU Member States that they shall lay down the rules on penalties.

As each Member State therefore sets its own penalties and sanctions, these vary from country to country.

In Austria, according to the Federal Ministry of Agriculture, Forestry, Climate and Environmental Protection, Regions and Water Management, there will be an accompanying law to the EU Battery Regulation setting out the penalties and sanctions. However, the process of aligning national legislation with EU law is being delayed, meaning that as of April 2026, the accompanying law to the EU Battery Regulation has not yet been enacted. QR Planet will keep you up to date.

In other European countries, national laws and penalties are already in place and in effect. The fines for non-compliance are extremely high:

• Germany: Depending on the type and severity of the violation of the Battery Regulation, penalties of up to €100,000 may be imposed.
• France: Here, cumulative penalties for non-compliance can even reach a total of up to €200,000.

• Do you need help creating QR Codes for your batteries? 
• Are you looking for a hosting provider to store the information accessible via the QR Code? 
• Would you like to integrate the system so that data from your existing PIM or ERP system can be made available automatically?

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