EMC, WEEE, and EU Battery Labelling (2023/1542): What You Must Do Before Selling in the EU
Electrical and electronic products placed on the EU market often trigger more than one compliance framework at the same time. In practice, you frequently need to align: electromagnetic compatibility (EMC), end-of-life obligations (WEEE), and battery marking and information rules (EU Battery Regulation 2023/1542). This article explains what each framework covers, what the markings must look like, and what you should prepare in your technical documentation.
1) EMC Directive 2014/30/EU (Electromagnetic Compatibility)
1.1 What “EMC” means in plain terms
EMC is the ability of equipment to function properly in its electromagnetic environment without causing unacceptable electromagnetic disturbance to anything else in that environment. In compliance work, this is typically structured into:
EMI (Electromagnetic Interference)
The emissions side. The question is whether your product generates electromagnetic disturbances that can disrupt other equipment.
EMS (Electromagnetic Susceptibility / Immunity)
The immunity side. The question is whether your product continues to operate correctly when exposed to electromagnetic disturbances from the environment.
1.2 When EMC compliance is generally required
If a product is powered (or otherwise contains electronic circuits) and there are emission or immunity considerations, it typically falls into EMC compliance. The attached overview explicitly lists several in-scope product examples such as household appliances, industrial equipment, medical/scientific devices, educational electronic equipment, and information technology equipment.
For official background on harmonised standards under the EMC Directive, see the European Commission guidance on harmonised standards for EMC.
1.3 Common EMC standard families referenced for typical product groups
The attached overview lists the following harmonised standard families by product category (examples):
Household appliances and power tools
EN 55014-1, EN 55014-2, EN 61000-3-2, EN 61000-3-3.
Luminaires (lighting)
EN 55015, EN 61547, EN 61000-3-2, EN 61000-3-3.
ITE and AV equipment
EN 55032, EN 55035, EN 61000-3-2, EN 61000-3-3 (the overview notes EN 55035 replacing older standards at a given date).
1.4 Practical documentation expectation
Your technical documentation should show which standards were used, the intended operating configuration, and evidence that both emissions and immunity were addressed. For multi-variant product lines, align the documentation with your BOM and variant matrix so you can justify what is equivalent and what is not.
If you are preparing a full compliance structure, review our guide on GPSR technical file documentation and EU Declaration of Conformity requirements.
2) WEEE Directive 2012/19/EU (and amendment 2024/884/EU): End-of-life obligations for EEE
2.1 What WEEE regulates
WEEE focuses on the collection, recycling, reuse, and environmentally sound treatment of electrical and electronic equipment (EEE). It assigns responsibility to the producer (or the party legally considered the producer in each country) for proper handling of products at end of life.
For official EU background, see the European Commission page on WEEE waste electrical and electronic equipment.
2.2 Typical in-scope categories
The overview lists broad categories including large and small household appliances, IT and telecommunications equipment, consumer equipment (and photovoltaic panels), lighting equipment, electrical and electronic tools (with exceptions), toys/leisure/sports equipment, medical devices (with exclusions), monitoring/control instruments, and automatic dispensers.
2.3 Core WEEE obligations you must plan for
Registration and reporting
Producers must register in the target country or countries where products are sold and submit required declarations/reporting (the overview notes national registration is typically managed via national authorities or systems).
Practical guidance is available in our WEEE registration compliance guide.
Financing take-back and recycling
Producers must ensure compliant treatment of waste equipment and bear associated costs (often based on equipment type and weight).
Product marking
Products should carry the WEEE symbol (crossed-out wheeled bin) and it must be clear and legible. The overview notes a height requirement of at least 7 mm for the WEEE symbol.
2.4 Crossed-out wheelie bin (WEEE): with bar or without?
For EEE under WEEE, the crossed-out wheeled bin symbol is typically used with an additional bar underneath in the commonly used WEEE marking set. Operationally, this “bar” version is widely used for modern products (it is part of the conventional WEEE symbol set used by manufacturers for current EU market placement).
Important: This “bar” convention is specific to WEEE marking for EEE. Batteries follow different symbol rules (see Section 3.4).
3) EU Battery Regulation 2023/1542: Article 13 labelling, marking and information requirements
3.1 Why this matters now
The Battery Regulation is a major shift from the older battery directive model and introduces more explicit and phased labelling and information obligations. The overview shows an implementation timeline with key milestones and indicates Article 13 requirements tied to implementing acts and dates.
See the official regulation text here: EU Regulation 2023/1542 (official version) and the PDF version of Regulation 2023/1542.
3.2 Article 13 overview (what the Regulation expects)
The attached material shows Article 13 requirements focused on labelling and marking of batteries, including general information, capacity marking for certain battery types, and additional information for non-rechargeable portable batteries.
General information label
From 18 August 2026 (or 18 months after the implementing act enters into force, whichever is later), batteries must bear a label containing the general information set out in Annex VI (Part A).
Capacity marking (rechargeable portable, LMT, SLI)
From 18 August 2026 (or 18 months after the implementing act, whichever is later), rechargeable portable batteries, LMT batteries and SLI batteries must bear a label containing information on their capacity.
Non-rechargeable portable batteries (duration + “non-rechargeable”)
From 18 August 2026 (or 18 months after the implementing act, whichever is later), non-rechargeable portable batteries must bear a label with their minimum average duration when used in specific applications, and a label indicating “non-rechargeable”.
3.3 Where and how markings must be applied
On-battery marking is the default
The labels and the QR code must be printed or engraved visibly, legibly and indelibly on the battery.
If on-battery marking is not feasible
Where on-battery marking is not possible or not warranted due to the nature and size of the battery, the labels and QR code must be affixed to the packaging and to the documents accompanying the battery.
Minimum symbol size (batteries)
The overview notes a minimum symbol height of at least 5 mm for battery symbols.
3.4 Crossed-out wheelie bin for batteries: with bar or without?
For batteries under the EU Battery Regulation 2023/1542, use the crossed-out wheeled bin symbol without the additional bar. The “bar” convention is used in the WEEE marking set for EEE, but it is not used for battery marking under the Battery Regulation.
In other words: EEE under WEEE generally uses the WEEE symbol set (commonly shown with the bar), while batteries use the crossed-out bin symbol without the bar. This distinction matters when you sell:
(1) a device with an integrated battery (you may have both WEEE and battery obligations),
(2) spare batteries sold separately (battery marking applies directly to the battery and, if needed, to packaging and accompanying documents).
3.5 Heavy metal marking thresholds (Cd, Pb)
The overview states that all batteries containing more than 0.002 percent cadmium or more than 0.004 percent lead must be marked with the chemical symbol for the metal concerned (Cd or Pb) beneath the separate collection symbol.
3.6 QR code expectations
The overview explicitly references QR code inclusion as part of labelling/marking requirements and notes that the QR code should be in high contrast and readable by commonly available QR readers (including those integrated into handheld communication devices).
3.7 What you should prepare now (practical implementation steps)
Artwork and packaging layout readiness
Battery markings are not an afterthought. If your battery is too small for on-product marking, packaging and accompanying documents must carry the required information. This impacts packaging dielines, inserts, multi-language layouts, and SKU management.
Bill of Materials alignment
Your labelling and documentation must align with the battery chemistry, rated capacity, voltage, and the product’s operating mode. Inconsistent BOM statements are a common reason for compliance queries, rework, and label revisions.
SKU and variant control
If you have multiple battery capacities or chemistries across SKUs, the capacity and related labelling elements must match the specific battery variant. Treat this like a controlled data set, not marketing text.
For broader launch planning, see our EU product launch checklist and EU compliance guide for selling consumer products.
4) Combined compliance scenarios (what typically trips up manufacturers)
4.1 Battery-powered electronics: “one product, three frameworks”
A battery-powered electronic device can simultaneously trigger:
(1) EMC requirements for emissions and immunity,
(2) WEEE obligations for EEE end-of-life compliance,
(3) Battery Regulation marking and information requirements for the battery.
4.2 Device vs battery labelling (avoid symbol confusion)
Do not assume that one crossed-out bin symbol covers everything. Battery and WEEE markings are related, but they are not identical in application or symbol conventions. For batteries, use the crossed-out bin without the bar and follow the Battery Regulation’s size, placement, and heavy-metal marking rules. For EEE, apply the WEEE marking requirements and observe the WEEE symbol size guidance.
4.3 When you are allowed to move information to packaging or documents
The Battery Regulation explicitly allows packaging and accompanying documentation placement when on-battery marking is not feasible due to the nature and size of the battery. This is not a free choice. You should document why on-battery marking is not possible and ensure the packaging/document solution remains robust for all distribution channels.
5) Internal compliance checklist (use this before final artwork approval)
5.1 EMC
Confirm the intended standard set for the product category, confirm test configuration represents the worst case, and retain evidence covering both emissions (EMI) and immunity (EMS).
5.2 WEEE
Confirm correct product categorisation, country-by-country registration planning, reporting and financing setup, and correct WEEE marking application (including symbol size guidance).
5.3 Batteries (EU 2023/1542)
Confirm which battery types apply (rechargeable portable, LMT, SLI, non-rechargeable portable), confirm whether capacity or duration statements are required, and implement:
(1) crossed-out bin symbol without bar,
(2) Cd/Pb marking if thresholds are exceeded,
(3) QR code requirements and contrast/readability,
(4) on-battery marking unless legitimately not feasible, in which case packaging and accompanying documents must carry the labels and QR code.
6) Conclusion
EU compliance for electronics is no longer a single “CE checkbox”. It is a coordinated system of technical performance rules (EMC), environmental take-back responsibilities (WEEE), and increasingly strict battery transparency and marking requirements (EU 2023/1542). If you align these early (especially symbol conventions and where information must appear), you avoid expensive rework of packaging, inserts, and product moulding/engraving decisions.