Briefing
Battery Rules: Instructions and QR Code
The Short Answer
Three Duties, Different Batteries
The Batteries Regulation does not give every battery the same documentation. Instructions and safety information apply to all of them. The online removal-and-replacement instructions in Article 11 are for products with portable batteries. The QR code applies to all batteries from 18 February 2027, and what it opens depends on the battery: for LMT batteries, industrial batteries over 2 kWh, and electric vehicle batteries, it opens the battery passport.
For a maker of industrial storage or traction packs, the passport is the larger task. It is a content program, not only a label. This article is a reading aid, not legal advice; read the text of the Regulation for your product. For how it sits beside other EU rules on digital manuals, see EU rules on digital manuals compared.
Instructions
What the Text Requires
- Every battery: instructions and safety information
- Article 38(1)(a) makes the manufacturer responsible for a battery that is accompanied by clear, understandable, and readable instructions and safety information, in a language end-users can easily understand, as the Member State where it is sold determines. This is the baseline for industrial batteries too.
- Portable batteries in products: removal and replacement
- Article 11(1) requires the battery to be readily removable and replaceable by the end-user, and the product to be accompanied by instructions and safety information on use, removal, and replacement, made available permanently online on a publicly available website. Article 11 applies from 18 February 2027.
- LMT batteries: replacement by an independent professional
- Article 11(5) requires products with light means of transport (LMT) batteries to allow the battery, and the individual cells in the pack, to be removed and replaced by an independent professional. The online-instructions sentence sits in paragraph 1 and names portable batteries.
Article 96(2) applies Article 11 from 18 February 2027 and the Regulation otherwise from 18 February 2024. The text sets no year count for how long the Article 11 instructions stay online; it says permanently. Our comparison page sets that against the other EU rules, such as the Machinery Regulation's digital-instructions rule.
The QR Code
What It Is and What It Opens
Article 13(6) requires the QR code from 18 February 2027, and Annex VI Part C asks for high contrast and a size an ordinary QR reader can scan. Article 13(7) says it is printed or engraved visibly, legibly, and indelibly on the battery; where that is not possible or not warranted given the battery's nature and size, it goes on the packaging and the documents that accompany the battery. The same article says the information behind the code must be complete, up to date, and accurate.
For passport batteries, Article 77(3) has the code link to a unique identifier that the economic operator attributes to the battery, and requires the code and identifier to comply with the ISO/IEC 15459 series or an equivalent. A repurposed or remanufactured battery needs new markings and, under Article 77(7), a new passport linked to the original. Article 13(1) to (3) also add general-information, capacity, and non-rechargeable labels, on a date tied to an implementing act on label specifications. Check the current text for that date.
The Passport
Industrial Batteries Over 2 kWh
Article 77(1) requires an electronic record for each LMT battery, each industrial battery with a capacity above 2 kWh, and each electric vehicle battery from 18 February 2027. Annex XIII sorts the content by who may see it.
- Public information about the battery model
- The Part A label content (manufacturer, place and date of manufacture, weight, capacity, chemistry, hazardous substances, extinguishing agent, critical raw materials), material composition, carbon footprint, recycled and renewable content, rated capacity, voltage ranges, expected lifetime in cycles, warranty period, efficiency, resistance, the EU declaration of conformity, and waste-management information.
- Model information for persons with a legitimate interest
- Detailed composition, spare part numbers and sources, dismantling information (exploded diagrams, disassembly sequences, fastening types and counts, required tools, damage warnings, cell count and layout), and safety measures. This is the part that reads like a maintenance procedure.
- Data on the individual battery
- Performance and durability values, state of health, status (original, repurposed, re-used, remanufactured, or waste), and use data such as charge cycles, negative events, operating temperatures, and state of charge. Access is limited to persons with a legitimate interest.
- Test reports for authorities
- Test reports proving compliance, visible only to notified bodies, market surveillance authorities, and the Commission.
Article 78 adds that the data must be machine-readable, based on open standards, and free of charge to access subject to the access rights. Article 77(9) tasked the Commission with an implementing act saying who counts as a person with a legitimate interest; read it, once published, before you configure access.
Documentation Work
Where a Publications Team Fits
Most of the passport comes from engineering and compliance records. Three pieces are documentation: the dismantling information (diagrams, sequences, tools, warnings), the safety measures, and the instructions and safety information that must accompany every battery. These are the same content types a publications team already writes and controls.
What the code resolves to is a controlled release, not a static file. The information must stay current, and the identifier is attributed to the individual battery, so you need a clear rule for which revision of the content applies to which unit. That is the same problem as publishing documents that change on a date. Whether to rewrite existing service documentation as passport content or reference it is the question in convert or ingest.
FAQ
Questions We Hear
Does every battery need a QR code from 18 February 2027?
Article 13(6) says all batteries shall be marked with a QR code from that date. For LMT batteries, industrial batteries over 2 kWh, and electric vehicle batteries it opens the battery passport. For other batteries it opens the label information, the declaration of conformity, the due-diligence report, and waste-management information. Article 13(7) lets the code go on the packaging and accompanying documents where marking the battery is not possible or not warranted.
Does Article 11 apply to industrial batteries?
Its title covers portable and LMT batteries, and the instructions sentence in paragraph 1 names products incorporating portable batteries. An industrial battery over 2 kWh falls under the passport (Article 77) and the general duty to supply instructions and safety information (Article 38(1)(a)). Check the definitions in the Regulation for your product before deciding which applies.
Which batteries need a battery passport?
Article 77(1): each LMT battery, each industrial battery with a capacity greater than 2 kWh, and each electric vehicle battery placed on the market or put into service from 18 February 2027. The passport is linked to a unique identifier, and the QR code and identifier must comply with the ISO/IEC 15459 series or an equivalent.
What date applies to the new battery labels?
Article 13(1) to (3) set the general-information, capacity, and non-rechargeable labels from 18 August 2026 or 18 months after the entry into force of the implementing act on label specifications, whichever is the latest. Read the current text and the implementing act itself before you fix a date for a product.
Can the QR code be replaced by another type of label?
Article 13(8) lets the Commission adopt delegated acts providing alternative smart labels instead of, or in addition to, the QR code. Until one is adopted, the QR code described in Part C of Annex VI is the marking the Regulation names. Part C asks for high contrast and a size a commonly available QR reader can read.
Get In Touch
Know What the Code Has to Open
Tell us which batteries and products you place on the EU market and which documents you already hold. We will talk through what the instructions and passport content involve.