This article summarises the regulation and is not legal advice. Produktpass helps you with the battery passport and the battery QR code under Regulation (EU) 2023/1542. The plugin's texts, templates and notes are not legal advice. You remain responsible for your duties and for the accuracy of your data. For a binding answer on your own case, ask a lawyer.
The regulation is the same in every member state
Every member state had to transpose the former Batteries Directive into its own law. The Batteries Regulation, by contrast, applies directly across the EU. For retailers this means: sales to Germany, Austria and France follow the same rules, and the regulation's dates are the same for everyone.
The regulation sorts batteries into categories: portable batteries, starter batteries (SLI), batteries for light means of transport (LMT) such as e-bikes and e-scooters, industrial batteries and electric-vehicle batteries. Many duties depend on the category; the battery passport, for example, only on LMT, industrial and vehicle batteries.
The role depends on the single product
Duties such as the QR code and the battery passport fall on whoever places a battery on the EU market, that is, makes it available on the Union market for the first time (Art. 3). A manufacturer is whoever has a battery designed or made and markets it under their own name or brand, including a retailer with an own brand. An importer is whoever is established in the EU and places a battery from a third country on the market.
Whoever buys a branded battery within the EU and resells it does not place it on the market and does not have to create a battery passport for it (Art. 3). So the role does not depend on the company but on the single product: the same shop can be the manufacturer for its own brand and only a retailer for the bought-in branded battery.
The label applies from 18.08.2026 or later
Batteries carry a label with the information of Annex VI Part A (Art. 13(1) to (3)), such as the manufacturer, category, chemistry and capacity. This duty applies from 18.08.2026 or 18 months after the implementing act on labelling enters into force, whichever is later (Art. 13(1)). The label's information is the same that the QR code later leads to; whoever records it cleanly once uses it twice.
The QR code comes on 18.02.2027
From 18.02.2027 every battery carries a QR code (Art. 13(6), Annex VI Part C). It leads to the battery passport or, for all other batteries, to the label's information, the declaration of conformity, the due diligence report and the information on disposal. It is printed or engraved on the battery and, where that is not possible, on the packaging and the accompanying documents (Art. 13(7)). More in the article battery QR code.
The battery passport covers three categories
From 18.02.2027 every LMT battery, every industrial battery above 2 kWh and every electric-vehicle battery needs an electronic battery passport (Art. 77(1)). It has three parts: information open to the public, information for persons with a legitimate interest and information for authorities (Annex XIII). The QR code leads to a unique identifier under ISO/IEC 15459, parts 1 to 6 (Art. 77).
The passport is kept up to date and ends when the battery is recycled (Art. 77). The economic operator who places the battery on the market is responsible for the accuracy of its data; they may mandate another operator in writing (Art. 77(4)). The article battery passport duty 2027 gives an overview.
Art. 78 sets the rules for the passport's data
Art. 78 describes what the battery passport's data should be like: open, interoperable and machine-readable, with free access according to the access rights, stored by the economic operator or a mandated operator, available also when the economic operator no longer exists, and protected against change.
Six harmonised standards on the product passport are published (Implementing Decision (EU) 2026/1736): EN 18216 (exchange protocols), EN 18219 (identifiers), EN 18220 (data carriers), EN 18221 (storage and persistence), EN 18222 (interfaces) and EN 18223 (interoperability).
Registration and retailer duties are still open
Battery passports are registered in the EU's registry of digital product passports (Implementing Regulation (EU) 2026/1778, Art. 1(1)(b) and Art. 8). Whether that is needed from 18.02.2027 for passports on the shop's own domain, and at which level, is not settled yet. Retailer duties under the Ecodesign Regulation (EU) 2024/1781 (Art. 31(2)) apply only once a delegated act sets them for a product group; there is none for batteries.
Produktpass for JTL-Shop covers the parts that live in the shop: battery passport pages and QR codes on your domain with the fields of Annex XIII, and an export as CSV and JSON for the registration once it is settled.
Frequently asked questions
Does the Batteries Regulation apply directly in Germany too?
Yes. As a regulation it applies directly in all member states, without transposition into national law.
Who is a manufacturer under the regulation?
Whoever has a battery designed or made and markets it under their own name or brand, including a retailer with an own brand (Art. 3).
Which articles concern the QR code?
Art. 13(6) (QR code from 18.02.2027, Annex VI Part C) and Art. 13(7) (where the code goes).
What must the battery passport's data be like?
Open, interoperable and machine-readable, available for the long term and protected against change (Art. 78).
Are there standards for the product passport?
Yes, six harmonised standards are published (Implementing Decision (EU) 2026/1736), from EN 18216 to EN 18223.
Sources
- Regulation (EU) 2023/1542, Art. 3, Art. 13, Art. 77, Art. 78, Annexes VI and XIII
- Implementing Regulation (EU) 2026/1778, Art. 1(1)(b) and Art. 8
- Implementing Decision (EU) 2026/1736
- Regulation (EU) 2024/1781 (Ecodesign), Art. 31(2)
Produktpass: Battery passport and battery QR code