The battery QR code that is not a battery passport
While EV, LMT, and large industrial batteries (>2kWh) are dominating headlines with the comprehensive Digital Battery Passport (DBP), the rest of the battery world faces a different but equally urgent digital deadline.
From 18 February 2027, all batteries placed on the EU market – including batteries in power tools, home appliances, and the billions of portable AA, AAA, and button cells sold every year – must carry a QR code under Article 13(6) of the EU Battery Regulation (EUBR).
The deadline is fixed, but the content requirements are a moving target. In this post, we cut through the regulatory noise to clarify exactly what needs to be behind that QR code on launch day.
Digital first? The timeline reality check
A significant portion of the QR code’s content is simply the digital twin of the physical label information described in Article 13(1)-(5).
However, we are facing a legislative gap. While requirements for the separate collection symbol and chemical markings are already active, the implementing act specifying the harmonized label design for other data (manufacturer details, capacity, etc.) is currently in draft mode. It likely won’t enter into force until mid-2026.
This creates a unique situation:
- Physical label deadline: Likely early 2028 (18 months after the act enters into force).
- QR code deadline: Strictly February 18, 2027.
In practice, this means the digital label will become mandatory before the new physical label design.
The QR code is a storage expansion, not a replacement. Critical safety symbols and the “crossed-out wheeled bin” must still remain printed on the physical pack.
Unpacking the QR code: 4 key compliance components
Article 13(6) mandates that your QR code acts as a portal to four specific compliance areas.
1. The Labelling Hub (Article 13)
First, the QR code must provide access to the information referred to in Article 13(1)–(5). In practice, this means your landing page must digitally reflect the required physical markings.
- General battery information (Paragraph 1): This includes manufacturer details, battery category, chemistry, hazardous substances, and references to critical raw materials.
- Capacity (Paragraph 2): For rechargeable portable batteries, the electric charge capacity (mAh or Ah) must be displayed digitally.
- Duration and non-rechargeable status (Paragraph 3): For primary (non-rechargeable) batteries, the minimum average duration and the “Non-rechargeable” warning must be accessible.
- Separate collection symbol (Paragraph 4): The crossed-out wheeled bin, confirming the product is subject to EU collection and recycling rules.
- Heavy metals marking (Paragraph 5): If the battery contains cadmium (>0.002%) or lead (>0.004%), the chemical symbols (Cd, Pb) must be shown digitally, just as they are on the physical label.
While the visual design of the physical label depends on the late implementing act, the data itself must be accessible via the QR code from February 2027.
2. The declaration of conformity (Article 18)
The Declaration of Conformity (DoC) is not new. Since August 2024, it has been mandatory to justify the CE mark on batteries. What is new is the delivery mechanism.
From February 2027, the EUBR requires that the DoC be digitally accessible via the QR code.
This shift creates clear efficiency gains. Instead of inserting multi-language paper booklets into packaging, Article 18(2) allows the QR code to act as the battery’s legal “birth certificate”. A paper copy is only required upon request.
Companies must also be careful of the single declaration requirement in Article 18(3). If a battery is subject to multiple Union acts – such as RoHS or the EMC Directive – a single EU Declaration of Conformity must cover all applicable legislation. Multiple documents are not allowed.
3. The due diligence report (Article 52(3))
The third area the QR code must point to is the due diligence report. This requirement focuses on four critical raw materials: cobalt, lithium, nickel, and graphite, including their compounds.
Although originally planned for 2025, Regulation (EU) 2025/1561 postponed the reporting obligation to 18 August 2027 – six months after the QR code becomes mandatory.
For that reason, we recommend including a placeholder or “ghost link” for due diligence within the QR structure from February 2027. This allows companies to activate the content smoothly once reporting becomes mandatory or even sooner.
Here, the proposed Omnibus IV amendments (COM(2025) 501) are also relevant. Two changes are currently under discussion:
- Raising the financial threshold from €40 million to €150 million in net turnover.
- Reducing the reporting frequency to every three years, with a possible first effective reporting date as late as August 2028.
Until these proposals are finalized – expected towards the end of 2026 – flexibility remains essential.
4. Waste prevention & management (Article 74(1))
Finally, your QR code must serve as a consumer education tool. While the physical wheelie bin symbol tells users what not to do, Article 74(1) requires the QR code to explain why and how batteries should be handled at end of life.
Six elements must be visible to the end user:
- (a) Waste Prevention: Tips to extend battery life (e.g., “Store in a cool place”).
- (b) & (c) Collection: The user’s role in recycling and where to find take-back points.
- (d) Safety: Handling instructions, specifically regarding lithium-ion risks (fire/thermal runaway).
- (e) Symbols: A legend explaining the meaning of labels and symbols, including the wheelie bin.
- (f) Impact: The environmental consequences of improper disposal. (e.g. hazardous substances leaching into soil/water).
The most challenging element is collection information, which varies by Member State. Many Producer Responsibility Organisations (PROs) already provide compliant digital content or standard URLs. Companies should engage with their PRO early to avoid reinventing this layer.
Closing remarks: how to approach compliance strategically
- Plan digitisation deliberately: Although we are waiting for the final word on physical label designs, the data requirements are known. Implementing them in one structured effort is often more efficient than redesigning labels and systems twice within a year.
- Leverage operational scale: If some of your products require a Digital Battery Passport and others only a QR code, choose a solution that supports both. The underlying data logic is largely shared.
- Design for persistence and change: The regulation requires information to remain accessible for 10 years after market placement. This demands permanent URLs, immutable records, and the ability to adapt as EU rules evolve – across all Member States.
How Kezzler can help
At Kezzler, we already deliver Digital Battery Passports for industrial and LMT batteries. The portable battery QR code is a lighter version of the same digital infrastructure.
By using a unified platform, companies can manage both requirements consistently, ensure long-term data availability, and stay aligned as EU battery regulation continues to evolve.
Whether you need a full passport or a compliant QR code, we help you build a digital bridge that lasts.
You might also find this interesting
- Our blog post: The EUBR compliance checklist
- Our Digital Battery Passport solution page