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Battery labelling requirements 2026–2027: what must be on your product

The Annex VI markings have applied since August 2026 and the QR code becomes mandatory on 18 February 2027. Exactly what has to appear on the battery, the packaging or the documentation — capacity, chemistry, hazardous substance symbols, collection symbol, size rules — and how it differs from GPSR traceability marks.

REVIEWED BY THE REGONANCE EDITORIAL TEAM

Battery labelling changed in two steps. Since 18 August 2026, the Annex VI Part A markings under Regulation (EU) 2023/1542 apply to batteries placed on the EU market. From 18 February 2027, a QR code has to appear as well. The old approach — a crossed-out wheelie bin and the chemistry letters, and nothing else — is no longer sufficient.

This is a practical guide to what has to appear, where it can appear, and what the QR code must resolve to.

What Annex VI Part A requires

Every battery placed on the EU market carries a label showing, in a visible, legible and indelible form:

  • the manufacturer's identity — name, registered trade name or registered trade mark, and postal address, with a single contact point where more than one address exists;
  • the battery category — portable, LMT, industrial, EV or SLI;
  • a model identifier or type, and the manufacturing batch or serial number;
  • the date of manufacture — month and year;
  • the place of manufacture — country or region;
  • the weight of the battery;
  • the capacity — for portable and LMT batteries this is expressed so consumers can compare like with like; rechargeable portable batteries carry capacity in mAh or Ah, and rated energy in Wh where relevant;
  • the chemistry;
  • hazardous substances other than mercury, cadmium or lead that are present above the threshold;
  • hazardous substance symbols — the chemical symbols Hg, Cd or Pb below the separate-collection symbol where the battery contains more than the specified thresholds of mercury, cadmium or lead;
  • usable extinguishing agent;
  • the separate collection symbol — the crossed-out wheeled bin;
  • and, from 18 February 2027, the QR code.

Non-rechargeable portable batteries additionally carry a marking indicating minimum average duration in specific applications, and the words "non-rechargeable".

Two of these are commonly missing on imported product. The date and place of manufacture are often absent from cells specified for other markets, and the batch or serial number is frequently absent from cheap cells — which also breaks your GPSR traceability, because a recall without a batch scheme is a recall of everything.

Where the label physically goes

The rule is a hierarchy, not a free choice.

On the battery itself, where the surface allows. This is the default, and the regulation expects you to try.

On the packaging, where the size of the battery means a label on the battery would leave the markings smaller than the readable minimum, or where the surface is not sufficient.

In the documents accompanying the battery, where neither of the above is possible.

The label must not exceed 1.5% of the surface of the battery for prismatic and pouch cells, and must not exceed a circle of 25 mm diameter for cylindrical cells; where the label would have to be larger than that to be readable, it moves to the packaging or documentation instead. The separate collection symbol has its own size floor — it covers at least 3% of the largest side of the battery, up to a maximum of 5 × 5 cm, and for cylindrical cells at least 1.5% of the surface with the same maximum.

Markings must be indelible. Printed on a removable sleeve, or on a sticker that peels in a warm warehouse, will not hold up in an inspection.

The QR code: what it must do

From 18 February 2027, batteries carry a QR code printed or engraved on the battery, or — under the same hierarchy — on packaging or accompanying documents where the battery is too small.

What the code resolves to depends on the category, and this is where most of the confusion sits.

Portable batteries and SLI batteries — the QR code gives access to the information in the label, the declaration of conformity, the information about removal and replacement, and the information required for separate collection. It is not a full battery passport.

LMT, industrial over 2 kWh, and EV batteries — the QR code is the carrier for the digital battery passport under Article 77, holding a much larger structured dataset: material composition, carbon footprint, recycled content, performance and durability, due diligence, and state of health.

If you sell consumer electronics with portable cells, your Q4 2026 work is a stable URL that serves label information, the declaration of conformity, removal instructions and collection information. That is a manageable web page, not a data platform.

Four requirements are easy to underestimate:

Stability. The code stays valid for the lifetime of the battery, which for a power tool pack is years. A campaign URL, a shortener owned by an agency, or a path that changes when you replatform, will break it.

No login, no app. The information has to be accessible. A code that opens a portal requiring registration does not meet the requirement.

Language. The information must be understandable to end users in the market where the battery is sold. In practice the landing page needs the language versions your markets require.

Print quality. Codes are laser-etched or printed on curved, small, sometimes dark surfaces. Contrast, quiet zone and module size need testing on production units, not on a design mock-up.

Getting capacity and chemistry right

Capacity declarations are the most frequently wrong field on imported cells, because the number on the wrapper is often a marketing figure rather than a measured rated capacity. Rated capacity has to be determined by the test methods the regulation refers to, and the declared value has to match what the cell actually delivers. For power banks the mismatch is notorious: a pack marked 20,000 mAh at cell voltage delivers far less usable energy at output voltage, and declaring the cell figure as the product figure is both a labelling problem and a consumer-law problem under unfair commercial practices rules.

Chemistry has to be stated accurately too — Li-ion, LiFePO4, NiMH, alkaline, lithium metal, lead-acid. It drives the collection stream, the extinguishing agent information, and the hazard communication. "Lithium" alone is not a chemistry.

Hazardous substance symbols

Where a battery contains more than 0.0005% mercury, more than 0.002% cadmium or more than 0.004% lead by weight, the chemical symbol Hg, Cd or Pb is printed under the separate-collection symbol. Note the direction of this rule: the symbol is required only when the threshold is exceeded. Printing Pb on a lithium cell "to be safe" is incorrect labelling, and it also misdirects the recycling stream. Get the actual composition from your supplier in writing rather than copying a template.

How battery markings sit alongside GPSR markings

The same product carries two independent sets of information, and satisfying one does not satisfy the other.

GPSR (Regulation (EU) 2023/988) requires the manufacturer's name and postal address, the EU responsible person's details where the manufacturer is outside the EU, a model or type identifier and a batch or serial number, on the product or — where size does not allow — on the packaging or an accompanying document. It also requires warnings and instructions in the language of the market.

The Battery Regulation requires the Annex VI markings above, on the battery under its own size hierarchy, plus the QR code.

In practice, a pair of wireless earbuds ends up with: product-level GPSR traceability marks and responsible-person details on the case or box; battery-level Annex VI information, usually on the packaging because the cell is too small; a separate collection symbol; a QR code; removal and replacement instructions; and the CE mark with the relevant conformity documentation behind it. Designing that as one artwork exercise, once, is far cheaper than discovering each element separately when a listing is suppressed.

A label audit you can run today

Take a physical unit from stock and check it against this list.

  1. Manufacturer name and address present — and is it the identity you want on the product, given private-label rules?
  2. Battery category stated.
  3. Model or type identifier, plus batch or serial number.
  4. Month and year of manufacture, and place of manufacture.
  5. Weight and capacity, with capacity matching a real rated figure.
  6. Chemistry, stated specifically.
  7. Hg, Cd or Pb symbols only where thresholds are exceeded.
  8. Separate collection symbol at the required size.
  9. "Non-rechargeable" wording on primary cells, with minimum duration information.
  10. Extinguishing agent information.
  11. QR code present, resolving to a stable page with label information, the declaration of conformity, removal instructions and collection information — required from 18 February 2027, and worth having in place before Q1.
  12. Removal and replacement instructions available to the end user.
  13. GPSR product-level marks and responsible-person details, separate from the battery marks.

Anything missing on the sample is missing across the shipment. Fixing it at artwork stage with your supplier before the next production run is the only version of this that is cheap.

Educational information only, not legal advice. Marking sizes, test methods and language requirements depend on category and market — confirm your obligations with a qualified advisor.

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Compliance guidance based on published EU regulatory texts. Not legal advice. Consult qualified counsel for your specific situation.