For battery suppliers entering the EU market, label readiness is a data-control task as much as an artwork task. Regulation (EU) 2023/1542 separates physical markings, general information labels and QR access into different requirements. A working QR code alone does not demonstrate that the required information is complete or that a battery complies with the regulation.
Build a requirements timeline before releasing artwork
Article 13(4) requires the separate-collection symbol from 18 August 2025. General information and the category-specific labels addressed in Article 13(1)–(3) follow a different trigger: 18 August 2026 or 18 months after the implementing act under Article 13(10) enters into force, whichever is later. Passing the calendar date is therefore not enough to establish that all these provisions have become applicable. Check the relevant implementing act and its entry-into-force date for the product concerned.
The QR requirement has its own date. Under Article 13(6), batteries within the regulation’s scope must carry a QR code meeting Annex VI, Part C from 18 February 2027. This article explains preparation against the current text reviewed on 3 October 2026; it does not report a newly announced rule on that date.
Route the code according to the battery category
The passport route applies to light means of transport (LMT) batteries, industrial batteries above 2 kWh and electric vehicle batteries. For other batteries, Article 13(6) specifies access to applicable labelling information, the declaration of conformity and other relevant information. Starting, lighting and ignition (SLI) batteries also have specified recovered-material information requirements. Underlying information obligations must be read with their own application conditions, rather than assuming every data field becomes mandatory on the QR start date.
Classify the battery before choosing a destination page. A generic marketing page shared by every model is not evidence that the legally required information is available. Keep a controlled mapping between each product, its label version and the information reached through its code.
Give each label field an evidence owner
Annex VI, Part A lists manufacturer and battery identification, battery category, manufacturing location and month/year, weight, capacity and chemistry. It also addresses specified hazardous substances, usable extinguishing agent and critical raw materials present above 0.1% by weight. These inputs may come from several teams, so artwork approval should not be the first occasion on which they are reconciled.
A practical model-data sheet can record the source and owner of each field, the approved artwork revision and its QR destination. When a factory, formulation or key parameter changes, review which fields are affected before releasing another print run. Capacity and duration requirements vary by category; one undifferentiated template is unlikely to capture the necessary distinctions.
Test the physical label and its destination together
Article 13(7) requires visible, legible and indelible printing or engraving on the battery. Where its nature or size makes this impossible or unwarranted, the labels and QR code must be placed on the packaging and accompanying documents. A website alone is not that fallback. Annex VI, Part C also requires high contrast and a size readable by commonly available QR readers.
As a preparation measure, check production samples for placement, glare, curvature, mobile scanning and model-to-page consistency. Retain label specimens, approvals and records of changes to linked information. Annex VIII includes a label specimen among technical-documentation requirements; an internal scanning check should not be marketed as a separate regulatory QR certification.
Connect testing evidence to the product record
Qianxin can discuss relevant standards and testing needs using the target market, battery category, model list, draft labels and existing reports supplied by the customer. Available work and deliverables require written confirmation for the project. Testing evidence does not replace the operator’s responsibility to maintain information and does not amount to a battery-passport platform service or regulatory approval.
The original cover illustration is conceptual, not a compliant label specimen. This is general compliance information, not product-specific legal advice or a final conformity assessment. Recheck current legislation and implementing requirements before artwork release.
