Batteries that need no passport still need a QR code
The short answer
Portable batteries, industrial batteries up to 2 kWh, starter (SLI) batteries and similar need no battery passport. But from 18 February 2027 every battery carries a QR code that opens a page with label and compliance information.
Three steps to decide
Is it an LMT battery, an EV battery or an industrial battery above 2 kWh?
If so, it needs a passport: see the page for that category. If not, read on.
Other batteries: no passport, but a QR code.
Portable batteries (sealed, 5 kg or less), industrial batteries up to 2 kWh and starter batteries fall here.
What to do
Make a QR information page and print the QR code on the battery. That is what the QR Compliance plan is for.
Common products
| Product (example) | Category | Passport needed? |
|---|---|---|
| Lithium cell of a phone or small appliance, 0.02 kWh | Portable battery | No passport QR code needed |
| Power tool battery pack, 0.3 kWh, 1.5 kg | Portable battery | No passport QR code needed |
| Home storage module, 1.8 kWh | Industrial battery | No passport Up to 2 kWh; QR code needed |
| Portable power station, 1.0 kWh, 4.8 kg | Generally a portable battery | No passport QR code needed; confirm with an expert |
| Lead-acid starter battery of a car | Starting, lighting and ignition (SLI) battery | No passport QR code needed |
The table gives examples and the numbers are for illustration. Ask us where your product falls; what we say is for reference and not legal advice.
What the regulation says
Every battery carries a QR code
“From 18 February 2027, all batteries shall be marked with a QR code as described in Part C of Annex VI.”
What the QR code of a battery without a passport leads to
“for other batteries, the applicable information referred to in paragraphs 1 to 5 of this Article, the declaration of conformity referred to in Article 18, the report referred to in Article 52(3) and the information regarding the prevention and management of waste batteries”
What a portable battery is
“a battery that is sealed, weighs 5 kg or less, is not designed specifically for industrial use and is neither an electric vehicle battery, an LMT battery, nor an SLI battery”
Quotes are from the English text of Regulation (EU) 2023/1542; the text published in the Official Journal prevails.
What a QR information page carries
- The information on the battery label (Art. 13(1) to (5))
- The EU declaration of conformity
- The supply chain due diligence report, where it applies
- Information on preventing and managing waste batteries
- For SLI batteries also: the amount of cobalt, lead, lithium or nickel recovered from waste
Source: Art. 13(6)(b)(c). The QR code must follow Annex VI, Part C: high contrast to the background and a size that common readers scan easily.
Common mistakes
“No passport means nothing to do.”
In fact: From 18 Feb 2027 every battery carries a QR code (Art. 13(6)).
“Any link behind the QR code will do.”
In fact: The code must contrast well and be easy to read, and the page behind it must carry the information the regulation asks for. The platform checks size and quiet zone before it generates the file.
“Home storage up to 2 kWh needs a passport too.”
In fact: Home storage is an industrial battery; up to 2 kWh it needs a QR code, not a passport.
Still not sure? Ask us.
Tell us about your product and we say which category it falls in, whether it needs a passport and by when.
More battery types
Deadline: 18 February 2027 · The QR code is required from this day.
