EU Battery Regulation (EU) 2023/1542: Battery Labelling Guide
If you sell electronics in the EU, you are effectively placing batteries on the market, even when the battery is built into a product (phones, laptops, headphones, toys, keyboards, wearables, smart home devices, power banks). Regulation (EU) 2023/1542 replaces the old Batteries Directive and introduces EU-wide rules covering the entire battery lifecycle, including mandatory labelling, marking, traceability, and digital information access.
Battery labelling is no longer a minor symbol requirement. Under the new Regulation, it is a structured compliance obligation that links what appears on the battery and packaging with technical documentation, conformity assessment, economic operator identification, and, for certain battery categories, digital data continuity. This approach mirrors broader GPSR labelling requirements and how authorities assess complete compliance files.
Official legal text (EUR-Lex): https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng
1. Scope: when electronics trigger battery labelling obligations
The Battery Regulation applies to all batteries placed on the EU market, including batteries incorporated into appliances. For consumer electronics, this most commonly means portable batteries, although other categories may apply depending on device configuration, capacity, and intended use, as explained in the EU compliance guide for selling consumer products.
1.1 Embedded or non-removable batteries remain in scope
Even if a battery is built in and not intended to be removed by the end user, it remains subject to the Regulation’s labelling and information requirements. The compliance question is not whether labelling applies, but how and where the required information is provided, whether directly on the battery, or, where justified, on packaging and accompanying documentation. This assessment is typically documented in the GPSR technical file documentation.
2. Why battery labelling is now a market access requirement
2.1 Labelling as a compliance gate
Under Regulation (EU) 2023/1542, battery labelling is directly linked to CE marking, conformity assessment, and economic operator identification. Incorrect, incomplete, or inconsistent labelling can block EU market access, trigger customs issues, or lead to product delisting, particularly on online marketplaces such as those described in Amazon EU sales and GPSR compliance.
Battery labelling must therefore be treated as part of the technical documentation and traceability system, not as a last-minute artwork exercise. This mirrors how market surveillance authorities assess compliance files under the GPSR risk analysis process.
2.2 Digital access and data continuity
A major change introduced by the Regulation is the move beyond purely physical labels. Where required, QR codes provide access to mandatory digital information. For certain battery categories, this extends to the Battery Passport, introducing ongoing obligations to maintain accurate and accessible information over time. Compliance is no longer a one-time label approval but a continuous obligation, often reviewed during EU Safety Gate registration checks.
3. Core battery labelling elements for consumer electronics
The Regulation defines what information must be provided and how it must be displayed. For electronics, compliance is typically achieved using a combination of on-battery marking (where feasible), packaging, accompanying documentation, and QR-code-based digital access, aligned with the EU GPSR technical file and product compliance guide.
3.1 Separate collection symbol (crossed-out wheeled bin)
3.1.1 What it is and why it matters
Batteries must display the separate collection symbol to indicate that they must not be disposed of with household waste and must be collected separately.
3.1.2 Size rules and small-battery fallback
The Regulation includes explicit size requirements and a practical fallback for very small batteries. Where marking on the battery is impractical due to size or nature, the symbol must appear on the packaging and in accompanying documents, in line with Annex VI requirements. Packaging obligations should also be checked against national schemes such as LUCID registration in Germany.
3.2 General information label (Annex VI Part A)
The Regulation requires a “general information” label containing a defined dataset listed in Annex VI Part A. For many electronics businesses, this is where packaging and documentation need redesign, as the dataset is broader than what was typically disclosed under the old Batteries Directive.
3.2.1 Typical data points expected
Depending on battery category and implementing specifications, required elements include battery identification, manufacturer identification, place and date of manufacture, weight, capacity, chemistry, and additional information elements referenced in Annex VI. These data points must remain consistent with the EU Declaration of Conformity.
3.3 Capacity information
Rechargeable portable batteries, which are common in consumer electronics, are subject to capacity labelling obligations. Capacity must be presented clearly and consistently, using the appropriate unit and format for the battery category, and supported by technical evidence such as chemical testing and material compliance documentation.
3.4 Hazardous substance markings (conditional)
If specific heavy metal thresholds are exceeded, chemical symbols such as Cd or Pb may be required. While most modern consumer electronics batteries should not trigger these thresholds, compliance should be confirmed through supplier declarations and material evidence, often supported by an SDS (Safety Data Sheet), not assumptions.
4. QR code and digital access requirements
4.1 QR code as a regulated element
The Regulation introduces a mandatory QR code requirement, set out in Annex VI Part C. For consumer electronics, the QR code is critical because it allows access to required information without overloading the physical label, especially for small embedded batteries.
4.2 What the QR code must link to
The QR code must provide access to specific information referenced in the Regulation, including conformity and waste-prevention information. QR codes are regulated compliance elements, not marketing tools. They must not link to empty pages, marketing-only content, or temporary URLs, and the linked information must remain available and up to date.
5. Where battery labelling may appear
The Regulation follows a standard EU hierarchy for product information, aligned with general EU compliance principles.
5.1 On the battery
This is the preferred option where technically feasible.
5.2 On the packaging
Packaging is commonly used when battery size or design constraints apply. Packaging labelling must also remain consistent with national packaging obligations, such as those outlined in the WEEE registration compliance guide and LUCID requirements.
5.3 In accompanying documentation
Instructions or manuals may be used where permitted, provided the information aligns with the GPSR technical file and product-level documentation.
6. Interaction with WEEE and product-level labelling
Electronics often already display a crossed-out wheeled bin symbol under the WEEE Directive for electrical and electronic equipment. This symbol is not interchangeable with battery marking.
Battery labelling requirements under Regulation (EU) 2023/1542 are battery-specific and include distinct sizing rules and fallback logic. In practice, many electronics products correctly display both WEEE and battery symbols, each fulfilling separate legal obligations.
WEEE Directive 2012/19/EU (EUR-Lex): https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32012L0019
7. Conformity assessment and documentation expectations
Battery labelling is explicitly connected to technical documentation and conformity assessment. Compliance files should retain controlled copies of battery labels, packaging artwork, and the digital content accessed via QR codes, ensuring information remains stable, auditable, and consistent with the EU Declaration of Conformity. This documentation is typically reviewed together with the EU Responsible Person appointment.
7.1 Evidence to retain for electronics product lines
- Battery identification and category classification
- Label and symbol artwork versions (battery, packaging, manuals)
- Supplier declarations confirming chemistry, capacity, and heavy metal compliance
- QR landing page content snapshots or controlled exports
- Declaration of Conformity references covering battery obligations
8. Sample battery label (template)
The following is a conceptual example of how a rechargeable battery label may be structured. It must be adapted to the specific battery type, size, and applicable regulatory obligations.
Rechargeable Lithium-Ion Battery
Model: BAT-18650-26
Nominal Capacity: 2600 mAh
Manufacturer:
ExampleTech Ltd.
12 Innovation Road, Shenzhen, China
EU Responsible Person:
Example Compliance GmbH
Musterstraße 10, 0815 Musterstadt, Germany
Do not dispose of with household waste.
Collect separately for recycling.
Safety information:
Do not short-circuit, disassemble, crush, or expose to fire.
Digital product information:
Scan QR code for compliance and recycling information.
This battery complies with Regulation (EU) 2023/1542.
9. Practical takeaway
Battery labelling under Regulation (EU) 2023/1542 is no longer a minimal marking task. It is a compliance interface connecting the battery, packaging, technical documentation, and regulated digital information. Brands that integrate battery labelling early into their compliance systems are better positioned to avoid recalls, penalties, and marketplace disruptions, as outlined in GPSR penalties and recall management.
Frequently Asked Questions
Does Regulation (EU) 2023/1542 require new labels for all batteries?
In most cases, yes. Even if a battery already carried symbols under the old Batteries Directive, Regulation (EU) 2023/1542 introduces additional labelling elements and stricter consistency requirements. These include clearer economic operator identification, alignment with CE marking and the EU Declaration of Conformity, and, for certain battery categories, QR-code-based digital access to mandatory information.
If my product contains an embedded battery, do I still need battery labelling?
Yes. Batteries incorporated into products remain fully in scope. Depending on size and design constraints, required information may appear on the battery itself, on the packaging, or in accompanying documentation. What matters is that the information is available, legible, and consistent with the technical documentation and product-level labelling.
Where must the CE marking appear for batteries?
Where technically feasible, the CE marking should appear directly on the battery. If the battery is too small or its surface does not allow marking, the CE mark may be placed on the packaging and in accompanying documentation. In all cases, the CE marking must be supported by a valid EU Declaration of Conformity.
What is the Battery Passport and does it apply to consumer electronics?
The Battery Passport applies to certain higher-capacity batteries such as EV batteries, LMT batteries, and large industrial batteries, with mandatory application from 2027. Most consumer electronics are not subject to the Battery Passport itself, but they are subject to the QR code and digital information requirements set out in the Regulation.
Are QR codes on battery labels optional or a marketing feature?
No. QR codes are a regulated compliance element under the Battery Regulation. They must link to specific mandatory information and cannot lead to empty pages, marketing-only content, or temporary URLs. Maintaining the accuracy and availability of the linked information is an ongoing compliance obligation.
What language must battery labels be provided in?
Mandatory battery information must be provided in the official language or languages of each EU Member State where the product is sold. For pan-EU distribution, this often requires multilingual packaging or country-specific labelling variants. English-only labelling is a common reason for enforcement action.
How does battery labelling interact with GPSR product labelling?
Battery labelling does not exist in isolation. Where a battery is part of a consumer product, battery information must align with GPSR product labelling, safety warnings, age grading (where applicable), and the technical file. Inconsistencies between battery labels and product documentation are frequently flagged during market surveillance and Safety Gate reviews.
What are the most common battery labelling mistakes?
Common issues include missing or incorrect CE marking, unsupported or incorrect capacity claims, QR codes that do not work or link to incorrect information, missing economic operator details, incorrect use or sizing of the separate collection symbol, and failure to localise mandatory information for EU languages.
Can incorrect battery labelling lead to recalls or penalties?
Yes. Incorrect or misleading battery labelling can result in product withdrawals, recalls, fines, and marketplace delistings. Labelling failures are often treated as a compliance breach even if the battery itself is technically safe.
Who is responsible for battery labelling compliance in the EU?
Responsibility lies with the economic operator placing the battery or battery-containing product on the EU market. For non-EU brands, this typically requires appointing an EU Responsible Person who ensures that labelling, technical documentation, and conformity obligations are met and can be demonstrated to authorities.
10. References
- European Commission, Batteries policy overview: https://environment.ec.europa.eu/topics/waste-and-recycling/batteries_en
- EUR-Lex, Regulation (EU) 2023/1542: https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng
- WEEE Directive 2012/19/EU (EUR-Lex): https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32012L0019
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