Why the Draft EU Battery Label Rules Matter

The EU Battery Regulation is moving battery compliance beyond basic product marking. Under the attached draft implementing regulation, companies placing batteries on the EU market may need to prepare harmonised label formats, structured product data, clear QR-code access and category-specific information.

The draft focuses on rules for applying Regulation (EU) 2023/1542, especially labelling requirements under Articles 7 and 13. It covers general battery label information, certain category-specific labels, carbon footprint performance class labels and practical rules for where information may appear when there is limited space on the battery.

For compliance, quality, sustainability and supply-chain teams, the message is clear: battery labelling is becoming a data management task. Companies will need reliable information on battery identity, origin, chemistry, mass, substances, critical raw materials, QR-code content and, for relevant battery categories, carbon footprint performance.

What Battery Label Information Companies Need

The annexes set out different label information requirements for portable non-rechargeable batteries; portable rechargeable, SLI and LMT batteries; and electric vehicle and industrial batteries. Across these categories, the required data may include manufacturer details, battery category and model identification, place and date of manufacture, mass, electrochemical composition, restricted and hazardous substances, usable extinguishing agent or fire class, and critical raw materials above the stated concentration threshold.

The draft also states that where a battery may fall under more than one battery category, the category with the strictest labelling requirements applies. Battery packs are also treated as batteries for labelling purposes where they meet the described definition.

QR Codes, Space Limits and Multilingual Labelling

One of the most practical challenges is label space. The draft allows information to be split across multiple labels where battery space is limited, where one label would reduce readability or durability, or where a single label is not appropriate for safety reasons. Where the battery or packaging cannot carry all required information, the draft allows information to be provided through packaging, accompanying documents and QR-code access, depending on the case.

For embedded batteries or batteries not immediately visible in products or vehicles, the draft includes QR-code solutions and refers to documentation such as instructions for use or other commercial documentation. Where the QR code is shown on the product or vehicle surface, the draft refers to an accompanying battery icon.

Design also matters. The draft requires labels to be readable, high contrast and positioned with visibility and durability in mind. It also refers to Noto Sans or another open-source font compatible with all EU official languages.

For multilingual markets, the draft allows digital versions of the label in other languages through a QR code unless national legislation requires otherwise. It also requires consumer-facing labelling information to be accessible for persons with disabilities.

Carbon Footprint Labels and Battery Passport Readiness

The draft carbon footprint label is especially important for electric vehicle batteries, rechargeable industrial batteries with capacity greater than 2 kWh and LMT batteries. The draft describes a harmonised label format showing the carbon footprint performance class, declared life-cycle carbon footprint and functional unit.

The annex also specifies the format details for the carbon footprint label, including minimum printed size, CMYK colour references for the A-to-E class scale, and the option to use a black-and-white version when the label is printed or engraved on the battery surface.

This creates a direct link between labelling, carbon data and digital product information. The draft notes that the carbon footprint label is also to be included in the publicly accessible part of the battery passport.

Practical Steps for Compliance Teams

To prepare without overcommitting before the final text is published, companies can start with a controlled readiness plan.

The draft indicates that entry into force would occur on the twentieth day after publication in the Official Journal, while the Article 13 labelling application date is presented as 18 months after entry into force. Because the attached text is still a draft, companies should avoid publishing fixed internal deadlines until the final regulation is confirmed.

How ComplyMarket Supports Battery Labelling Readiness

ComplyMarket can help companies move from draft awareness to operational readiness by centralising the product, material and supplier data needed for battery labelling compliance.

Through ComplyMarket, companies can support battery compliance work by collecting supplier declarations, managing substance and material data, tracking critical raw materials, preparing documentation and supporting Digital Product Passport readiness. ComplyMarket’s official service pages describe capabilities for battery compliance management, material and product compliance, environmental reporting and Digital Product Passport requirements.

For compliance teams, this means a more controlled process for:

• Mapping batteries and product families to applicable requirements
• Collecting and validating supplier evidence
• Managing restricted and hazardous substance information
• Tracking critical raw materials and battery composition data
• Preparing QR-code and Digital Product Passport information
• Maintaining audit-ready documentation for customers and authorities

Battery label compliance is no longer just a packaging task. It is a connected product compliance, supplier data and sustainability data challenge. ComplyMarket helps companies build that connection in one structured compliance environment, so teams can prepare early, reduce manual work and stay ready as EU battery requirements continue to develop.