Do you sell batteries, or products that contain them: toys, string lights, small electronics, tools, remote controls? From 18 February 2027, every battery placed on the European market must carry a QR code. This is not only a matter for cell manufacturers: brands, importers and retailers are all responsible, including for their private-label products.
This article walks through the EU Batteries Regulation (Regulation (EU) 2023/1542) from the point of view of a brand selling battery-powered products: who is concerned, what the code must give access to, where it goes and what to prepare now.
What the regulation says about the QR code
Article 13(6) is clear on the principle: from 18 February 2027, all batteries are marked with a QR code. The text makes no distinction between large and small batteries: portable batteries are included.
What the code contains depends on the battery category. For light means of transport batteries (electric bikes and scooters), industrial batteries above 2 kWh and electric vehicle batteries, it opens the battery passport provided for in Article 77. For all other batteries, including portable ones, it points to labelling, conformity and end-of-life information, detailed below.
The regulation adds a requirement that matters for what follows: this information must be "complete, up to date and accurate". A QR code pointing to an outdated page does not meet the rule.
Are you concerned? Brands of batteries and battery-powered products
The regulation covers batteries placed on the EU market, including those incorporated in appliances. A portable battery is defined as a sealed battery weighing 5 kg or less that is not industrial, electric vehicle, light means of transport or starter battery. A battery in a toy, a luminaire or a small electronic device therefore falls within the scope of the text. You are concerned in three common situations:
- you sell batteries under your brand, alone or in packs;
- you sell products that incorporate a battery: toys, lighting decoration, small appliances, tools, electronic accessories;
- you have these products made or import them under your own name, as private label.
On responsibilities, the text distinguishes three roles:
- the manufacturer;
- the importer, who places on the EU market a battery coming from a third country: before doing so, they verify that it is "marked and labelled in accordance with Article 13" (Article 41);
- the distributor, who makes it available: they carry out the same check before making it available and must not do so if they have reason to believe it is non-compliant (Article 42).
Two points to remember. First, an importer or distributor that places a battery on the market under its own name or brand is treated as a manufacturer (Article 44): for private-label products, the QR code obligation rests with them. Second, the distributor's check applies to every battery they stock, including those of third-party brands: your retail customers will therefore ask you for proof of marking.
What the QR code must give access to
For batteries other than those covered by the passport, the regulation lists what the code must open (Article 13(6)(b)):
- the "applicable" labelling information from paragraphs 1 to 5 of Article 13 (manufacturer, battery category and identification, place and date of manufacture, weight, capacity, chemical characteristics, hazardous substances, separate collection symbols);
- the EU declaration of conformity (Article 18);
- the annual due diligence report (Article 52(3)), for the operators subject to those obligations;
- the information on prevention and management of waste batteries (Article 74): the end user's role in separate collection, take-back and collection points, safety instructions, meaning of symbols, effects of the substances on the environment and health.
The word "applicable" deserves attention. The general label (paragraphs 1 to 3) applies from 18 August 2026 or 18 months after the entry into force of a Commission implementing act, whichever is later. As long as that act is not in force, the timing of this label may slip, which may also change the exact content of the code on 18 February 2027. This reading should be confirmed with your legal team for each product.
The text gives few technical details on the code itself: Annex VI requires strong contrast with the background and a size easily readable by a common reader, such as those built into smartphones.
Where to place the QR code: on the battery, or on the packaging and documents
The placement rule is precise (Article 13(7)). The code is printed or engraved visibly, legibly and indelibly on the battery. If its nature or dimensions make that impossible or unjustified, it appears on the packaging and on the documents accompanying the battery.
It is therefore not a free choice between battery and packaging: the battery comes first. The fallback to packaging and documents applies when the size or nature of the battery rules it out, such as a button cell or the small battery of a toy. For these products, packaging and instruction leaflets are designed with suppliers, often months ahead: the decision has to be made earlier than the application date suggests.
For a battery incorporated in a product, the precise reading of this placement rule remains to be validated with your legal team.
One point has applied since 18 August 2025 and affects packaging: the separate collection symbol (the crossed-out wheeled bin) must appear on every battery. If the battery is too small to carry it, a symbol of at least 1 cm by 1 cm is printed on the packaging (Article 13(4)).
Key dates (Regulation (EU) 2023/1542)
- 18 August 2025: separate collection symbol on all batteries, or on the packaging for very small batteries (Article 13(4)).
- 18 August 2026 or 18 months after the implementing act, whichever is later: general information label, capacity label, "non-rechargeable" mention (Article 13(1) to (3)).
- 18 February 2027: QR code on all batteries (Article 13(6)) and battery passport for light means of transport batteries, industrial batteries above 2 kWh and electric vehicle batteries (Article 77).
Getting ready before February 2027: three workstreams for a brand of battery-powered products
1. List the references that contain a battery, including incorporated ones, and sort them by category. The qualification of each product is validated with your quality and legal teams.
2. Collect information from suppliers: manufacturer, chemistry, declaration of conformity, end-of-life information. This is the longest part, and it is what makes the code useful: the regulation requires complete, up-to-date and accurate information.
3. Choose a code that can evolve. Information changes (new supplier, updated declaration, modified collection instruction): if the link is fixed at print time, the packaging has to be reprinted. With a dynamic QR code, the destination address can be changed after printing, per reference, batch or series depending on what the text requires, without touching the printed design. At Qezako, these codes are generated on a subdomain owned by the brand, and they can follow the GS1 Digital Link standard if you also want to prepare for checkout scanning (see our page on the GS1 Augmented QR Code).
The battery passport, for its part, covers a separate scope (mobility and industrial batteries). It follows the logic of the Digital Product Passport: for the European context, see our article on the launch of the Central DPP Registry.
Frequently asked questions
Is the QR code mandatory on a button cell?
In principle, yes: Article 13(6) covers all batteries. If the size of the cell does not allow it to carry the code, the code appears on the packaging and on the documents accompanying it (Article 13(7)).
Who must make sure the code is present on a product sold in store?
The manufacturer, the importer and the distributor each verify the marking and labelling before placing a battery on the market or making it available (Articles 41 and 42). For a private label, the retailer is treated as a manufacturer (Article 44).
Does the QR code replace the separate collection symbol?
No. The symbol has been mandatory since 18 August 2025. The QR code is added to it and gives access to additional information.
In short
On 18 February 2027, a battery in a toy carries the same obligation as a large battery: a QR code, with complete, up-to-date and accurate information. Placement follows a precise order: the battery first, packaging and documents as a fallback. The date is known, the specifications of the general label less so: for a brand of battery-powered products, this is the right time to list references and choose a code that can evolve.
See how a QR code can be updated without reprinting the packaging.
