We do not know how to label our batteries
Article 13 of the Battery Regulation (EU) 2023/1542 sets the battery marks in stages. The separate collection symbol has been required since 18 August 2025, with Cd or Pb beneath it above the thresholds. A general information label, and capacity or durability labels, follow from 18 August 2026 or 18 months after the implementing act, whichever is later. A QR code is required from 18 February 2027.
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Reviewed 4 October 2026 by the Conphora compliance team · Not legal advice
Why this happens
Battery labelling under the Battery Regulation (EU) 2023/1542 comes in stages, set out in Article 13 and Annex VI. The first stage already applies. From 18 August 2025, all batteries are marked with the symbol for separate collection shown in Annex VI, Part B (Article 13(4)). The symbol covers at least 3 % of the area of the largest side of the battery, up to a maximum of 5 × 5 cm; for cylindrical cells, at least 1,5 % of the surface area. Where it would be smaller than 0,47 × 0,47 cm, the battery need not carry it, and a symbol of at least 1 × 1 cm is printed on the packaging. Batteries containing more than 0,002 % cadmium or more than 0,004 % lead are marked Cd or Pb beneath the symbol, covering at least one-quarter of its size (Article 13(5)).[1]
The second stage is the information label. From 18 August 2026 or 18 months after the entry into force of the implementing act on harmonised label specifications, whichever is the latest, batteries bear a label with the general information in Annex VI, Part A (Article 13(1)): the manufacturer, the battery category and identification, the place and date of manufacture, weight, capacity, chemistry, hazardous substances other than mercury, cadmium or lead, the usable extinguishing agent and critical raw materials above 0,1 % weight by weight. On the same timetable, rechargeable portable, LMT and SLI batteries get a capacity label, and non-rechargeable portable batteries a label with their minimum average duration in specific applications and the words 'non-rechargeable' (Article 13(2)–(3)). The Commission was to adopt the implementing acts by 18 August 2025 (Article 13(10)).[1]
The third stage is digital. From 18 February 2027, all batteries carry a QR code (Article 13(6)), which leads to the battery passport for LMT batteries, industrial batteries above 2 kWh and electric vehicle batteries, and for other batteries to the label information, the EU declaration of conformity, the due diligence report and the waste information.[1]
Some marks sit outside Article 13. Manufacturers put a model identification and a batch, serial or product number on the battery (Article 38(6)) and their name, registered trade name or trade mark and postal address with a single contact point (Article 38(7)); importers add their own details (Article 41(3)). The CE marking is affixed to the battery before it is placed on the market (Article 20). Labels and the QR code are printed or engraved visibly, legibly and indelibly on the battery, and go on the packaging and accompanying documents only where the battery's nature and size do not allow it (Article 13(7)).[1]
How to solve it
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Put the collection symbol and the heavy metal marks on now
Since 18 August 2025, all batteries carry the separate collection symbol shown in Annex VI, Part B, covering at least 3 % of the largest side up to 5 × 5 cm (1,5 % of the surface for cylindrical cells). Batteries with more than 0,002 % cadmium or 0,004 % lead also carry Cd or Pb beneath the symbol, at least one-quarter of its size.
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Add the manufacturer, importer and identification details
The battery carries a model identification and a batch, serial or product number. The manufacturer's name, registered trade name or trade mark and postal address with a single contact point go on the battery; importers add theirs. Where size does not allow it, use the packaging or an accompanying document.
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Prepare the general information label
Annex VI, Part A lists the label content: manufacturer, battery category and identification, place and date of manufacture, weight, capacity, chemistry, hazardous substances other than mercury, cadmium or lead, usable extinguishing agent, and critical raw materials above 0,1 % weight by weight. Collect this data per battery model from your supplier.
Product validationCompliance engine Open in the console -
Add the capacity or durability label for your battery type
Rechargeable portable, LMT and SLI batteries get a label with their capacity. Non-rechargeable portable batteries get a label with their minimum average duration in specific applications and the words 'non-rechargeable'. Follow the harmonised specifications the Commission sets by implementing act for these labels.
Regulation guidesKnow-how Free Open -
Plan the QR code for 18 February 2027
From 18 February 2027 all batteries carry a QR code. For LMT, industrial above 2 kWh and electric vehicle batteries it leads to the battery passport; for other batteries to the label information, the declaration of conformity, the due diligence report where applicable and the waste information.
Work through the steps in the platform with your own product.
What you need to show
| Document | Where it comes from | Legal ground |
|---|---|---|
| A specimen of the label in the technical documentation | The battery manufacturer | Battery Regulation Annex VIII, Part A, point 2(d) |
| The label data per battery model (Annex VI, Part A) | The battery manufacturer and its suppliers | Battery Regulation Article 13(1) |
| Information to end-users on the meaning of the labels and symbols | The producer or its producer responsibility organisation | Battery Regulation Article 74(1)(e) |
If you do nothing
Distributors must check the labels
Before making a battery available, distributors verify that it bears the CE marking and is marked and labelled in accordance with Article 13, and that the manufacturer's and importer's details are on it (Battery Regulation Article 42(2)(b) and (d)).[1]
Missing contact details are formal non-compliance
Absent, false or incomplete manufacturer or importer information under Articles 38(7) or 41(3) must be ended on request; if it persists, the Member State restricts or prohibits the battery or ensures its withdrawal or recall (Battery Regulation Article 83).[1]
Penalties under national law
Member States lay down effective, proportionate and dissuasive penalties for infringements of the regulation (Battery Regulation Article 93).[1]
Questions about this problem
The battery is too small for the collection symbol. What then?
Where the symbol would be smaller than 0,47 × 0,47 cm, the battery does not need to carry it; a symbol of at least 1 × 1 cm is printed on the packaging instead (Battery Regulation Article 13(4)).
Can the labels go on the packaging instead of the battery?
The labels and QR code are printed or engraved visibly, legibly and indelibly on the battery. Only where that is not possible or not warranted by the nature and size of the battery do they go on the packaging and the accompanying documents (Article 13(7)).
When does the general information label become mandatory?
From 18 August 2026 or 18 months after the entry into force of the implementing act on harmonised label specifications, whichever is the latest (Article 13(1) and 13(10)). Check the date of that implementing act before you fix the artwork.
Does a refurbished battery keep its old label?
No. Batteries that have been prepared for re-use or repurposing, repurposed or remanufactured get new labels or markings, with information on their change of status accessible through the QR code (Article 13(9)).
Does the CE marking go on the battery too?
Yes. The CE marking is affixed visibly, legibly and indelibly to the battery before it is placed on the market, or to the packaging and accompanying documents where the battery's nature does not allow it (Battery Regulation Article 20(1)–(2)).
Sources
- Regulation (EU) 2023/1542 concerning batteries and waste batteries (consolidated text of 13 August 2026) EUR-Lex · accessed 4 October 2026
- Regulation (EU) 2023/1542 concerning batteries and waste batteries (Official Journal L 191, 28.7.2023) EUR-Lex · accessed 4 October 2026
About this page
- Reviewer
- Conphora compliance team
- Reviewed
- 4 October 2026
General information, not legal advice. Check the legal text or ask an adviser about your own product.
Conphora (2026). We do not know how to label our batteries. Retrieved 13 October 2026 from https://www.conphora.com/solutions/problem/battery-labelling/
Conphora (2026) We do not know how to label our batteries. Available at: https://www.conphora.com/solutions/problem/battery-labelling/ (Accessed 13 October 2026).
@misc{conphora2026wedonotknowhowtolabelour,
author = {Conphora},
title = {We do not know how to label our batteries},
year = {2026},
url = {https://www.conphora.com/solutions/problem/battery-labelling/},
note = {Retrieved 13 October 2026}
} See it working before you add a product
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