Battery label: which requirements apply and from when?

What is included in a battery label?

A battery label includes all mandatory labeling and marking on a battery under Regulation (EU) 2023/1542. This concerns the symbol for separate collection, the chemical symbols for cadmium and lead, an information and capacity label, and a QR code. Each marking has its own effective date and its own placement on the battery or the packaging.

The requirements apply to every battery placed on the EU market. This includes not only loose batteries, but also batteries contained within another product. A wireless earbud case, a power bank, toys with a battery, an electric toothbrush: in all these cases, the battery itself must bear the correct labels and markings.

If you have products manufactured in Asia and place your own brand on the product, you are legally the manufacturer. The obligation to correctly label the battery then lies with you, even if your supplier provides and installs the battery.

Which labels and markings are mandatory?

Four markings are mandatory: the symbol for separate collection, the chemical symbol Cd or Pb if cadmium or lead levels are exceeded, an information label with general battery data, and a capacity label. Portable non-rechargeable batteries must also include the statement ‘non-rechargeable’ and their minimum average duration. The QR code will be added starting in 2027.

The requirements are set out in Article 13 and Annex VI of the regulation. Per marking, it comes down to the following:

• The symbol for separate collection, the crossed-out wheeled bin. It must cover at least 3 percent of the largest side of the battery, up to a maximum of 5 by 5 centimeters. For cylindrical cells, this is at least 1.5 percent.
• The chemical symbol Cd or Pb if there is more than 0.002 percent cadmium or more than 0.004 percent lead. It is placed below the collection symbol and covers at least one-quarter of its area.
• The general information label including, among other things, the manufacturer, the battery category, the year of manufacture, and the capacity, as laid down in Annex VI, Part A.
• The capacity label for rechargeable portable batteries, light means of transport batteries, and starting, lighting and ignition batteries.
• The QR code, which is mandatory on every battery from February 18, 2027, and refers to further information.

What belongs on the battery and what on the packaging?

As a rule, every marking belongs on the battery itself. Regulation (EU) 2023/1542 only permits placement on the packaging if the battery is too small. If the collection symbol would be smaller than 0.47 by 0.47 centimeters, it may be removed from the battery and placed on the packaging, measuring at least 1 by 1 centimeter.

This exception is narrow. It only applies to the collection symbol and only for a battery that is truly too small to apply the symbol legibly. The other markings, the information label, and the QR code, belong on the battery itself as soon as the dimensions allow it.

From which date does each label apply?

The labeling requirements apply in phases. The symbol for separate collection has been mandatory since August 18, 2025. The general information label and the capacity label apply from August 18, 2026. The QR code on every battery follows on February 18, 2027. The carbon footprint declaration has separate dates per battery type between 2025 and 2030.

The regulation has mainly applied since February 18, 2024, but the labeling requirements are being rolled out in phases. The dates below are the effective dates from Article 13 and the associated articles.

The dates for the information label, the capacity label, and the carbon footprint will shift if the corresponding implementing or delegated act enters into force later. Furthermore, the carbon footprint only affects batteries for electric vehicles, rechargeable industrial batteries above 2 kWh, and batteries for light means of transport, not standard portable batteries in consumer products.

Who is responsible for the labeling?

The manufacturer is responsible for the labeling. If you have products manufactured in Asia and place your own brand on the product, you are legally the manufacturer and must ensure the labeling and marking are applied. The importer checks that it is correct. A missing or incorrect label remains your responsibility.

In practice, the factory often supplies the battery with a label made for their home market. That label often does not meet European requirements: the collection symbol is missing, the capacity is not stated, or the QR code leads nowhere. You are the one who must rectify this for the European market and be able to demonstrate that it is correct.

What do the QR code and the battery passport mean?

From February 18, 2027, every battery will be provided with a QR code. For light means of transport batteries, industrial batteries above 2 kWh, and electric vehicle batteries, this code opens the battery passport. For all other batteries, the code leads to the label information, the declaration of conformity, and data regarding collection and recycling.

The battery passport is an electronic file per individual battery unit. This does not affect your document folder, but your production registration: you must record traceable data per unit. For a standard portable battery in a consumer product, no passport applies, but the QR code that refers to the other mandatory information does.

The requirement for a stationary storage system or an industrial battery to receive a passport is further detailed in our article on the battery regulation for energy storage systems.

What you should arrange now

Start with the markings that are already mandatory, as those dates have passed. Check whether the collection symbol and chemical symbols are correctly placed on your batteries and whether the information and capacity labels are correct. Then prepare the QR code, as this affects your production registration and not just your packaging.

1. Record which batteries are in your products, including their chemistry, capacity, and cadmium or lead content. This determines which markings are mandatory.
2. Check whether the label applied by the factory complies with Annex VI. If not, have a correct label designed.
3. Map out which data you register per unit. This determines whether the QR code and, where applicable, the passport are feasible by 2027.
4. Record the supporting evidence in your technical documentation, so that you can show the basis for the labeling during an inspection.