When someone searches for what battery information must go in the accompanying or technical documentation, they are usually looking for one rule — one checklist. There isn't one. EU Battery Regulation (2023/1542) imposes three legally distinct obligations: Article 13 labelling and marking on or with the battery, Annex VIII technical documentation for conformity assessment, and the Article 77 digital battery passport. Each has its own legal basis, its own content scope, and its own application date. Conflating them leads to real compliance errors. This post disentangles all three.
What must be labelled on a battery — and from when?
Article 13 of Regulation (EU) 2023/1542 governs labelling and marking. It covers what is physically on or with the battery — not documentation stored elsewhere. The requirements are staggered across four dates depending on the marking type.
The separate-collection symbol — the crossed-out wheeled bin from Annex VI Part B — is required under Article 13(4) from 18 August 2025. This is the earliest marking obligation and is already in force.
The general information label (Annex VI Part A), the capacity label, and the non-rechargeable duration and 'non-rechargeable' indication under Article 13(1)–(3) apply from 18 August 2026 — or 18 months after the Article 13(10) harmonised-labelling implementing act enters into force, whichever is later. Because the implementing act has not yet been adopted, this date may slip beyond 18 August 2026.
Batteries containing more than 0.002% cadmium must carry the chemical symbol 'Cd', and those with more than 0.004% lead must carry 'Pb'. Both are required under Article 13(5), printed beneath the separate-collection symbol at no less than one-quarter of its size.
The QR code under Article 13(6) and Annex VI Part C applies from 18 February 2027 — a single uniform date for all battery types. What the QR code resolves to differs by battery type: for LMT, industrial batteries above 2 kWh, and EV batteries it gives access to the Article 77 passport; for other batteries it links to the Article 13(1)–(5) information, the EU declaration of conformity, and the relevant waste-management information. The CE marking is a separate matter governed by Articles 19–20, not Article 13.
What goes in the technical documentation (Annex VIII)?
Annex VIII defines 'Conformity Assessment Procedures — Module A (Internal Production Control).' It is the closest equivalent to what a German query about Begleitdokumentation or technische Dokumentation is looking for. This is the pre-market technical file the manufacturer must compile before placing a battery on the EU market.
The technical documentation must make it possible to assess the battery's conformity with Articles 6, 9, 10, 12, 13, and 14 of the regulation. It must include: an adequate analysis and assessment of the risks, a general description of the battery and its intended use, and a specimen of the Article 13 label. This is a precondition for CE marking and for placing the battery on the market — an ongoing conformity obligation that predates any passport requirement.
Critically, the Annex VIII technical documentation is not the same as the battery passport and does not replace it. It is the manufacturer's internal conformity file — held and made available to authorities on request. The passport is a separate, externally accessible data record.
Is the accompanying documentation the same as the battery passport?
No. They overlap because the Art. 13 labelling and the Art. 77 passport are both reached via the same QR code — but the technical documentation (Annex VIII) is a separate conformity file that is not on the QR at all. All three are distinct obligations.
- Article 13 labelling and marking — physical marks on or with the battery (separate-collection symbol, capacity, QR code, Cd/Pb chemical symbols). An obligation for manufacturers. Staggered from 18 August 2025.
- Annex VIII technical documentation — the manufacturer's internal conformity file, including a description of the battery and a specimen of the Art. 13 label. Held by the manufacturer, shown to authorities on request. A pre-market obligation that applies before the passport.
- Article 77 + Annex XIII digital battery passport — a structured, externally accessible data record for LMT, industrial >2 kWh, and EV batteries, accessed through the Art. 13(6) QR code. Mandatory from 18 February 2027.
When does each requirement apply?
The table below maps the three obligations to their legal basis and application dates. Where a date depends on a secondary act that has not yet been adopted, that conditionality is stated explicitly.
EU Battery Regulation 2023/1542 — three obligations and their application dates
| Obligation | Legal basis | Application date |
|---|---|---|
| Separate-collection symbol (crossed-out wheeled bin) | Art. 13(4), Annex VI Part B | 18 August 2025 |
| General info label + capacity label + non-rechargeable indication | Art. 13(1)–(3), Annex VI Part A | 18 August 2026, or 18 months after the Art. 13(10) implementing act (whichever is later) |
| Hazardous-substance symbols: >0.002% Cd → 'Cd'; >0.004% Pb → 'Pb' | Art. 13(5) | Printed beneath the separate-collection symbol (Art. 13(5)) |
| QR code (Annex VI Part C) — links to Art. 77 passport for LMT/industrial >2 kWh/EV; links to Art. 13 info + DoC + waste info for other batteries | Art. 13(6), Annex VI Part C | 18 February 2027 (uniform date, all battery types) |
| Technical documentation (general description, risk analysis, Art. 13 label specimen) | Annex VIII, Module A | Pre-market obligation — required before placing the battery on the EU market |
| Digital battery passport (LMT, industrial >2 kWh, EV batteries only) | Art. 77 + Annex XIII | 18 February 2027 |
A note on the 2026 corrigendum
Corrigendum CELEX 32023R1542R(13), published in OJ L 2026/90285 on 10 April 2026, corrected Annex XIII point 1(q) — the passport's marking cross-reference — from 'Article 13(3) and (4)' to 'Article 13(4) and (5)'. This aligns the passport's marking field with the correct paragraphs: Article 13(4) governs the separate-collection symbol, and Article 13(5) governs the Cd/Pb chemical symbols. If your technical file or passport template cross-references the marking requirements, the correct citation after 10 April 2026 is Article 13(4) and (5), not 13(3) and (4).
How TracePass helps with the passport and QR obligations
TracePass builds the Article 77 digital battery passport and generates the GS1 Digital Link QR code that Art. 13(6) requires. The Article 13 physical labelling — the marks that go on the battery itself — and the Annex VIII technical documentation are the operator's separate obligations, which this post has described.
Scan to open on your phoneSee a real Digital Product Passport.
Panasonic NCR18650B lithium-ion cell — all 94 mandatory battery-passport fields populated and reviewer-approved. Scan the QR with your phone or open the link to see how a published passport renders to a customer.
Frequently asked questions
What battery information must be in the technical documentation under EU Regulation 2023/1542?
Annex VIII (Module A — Internal Production Control) requires the manufacturer's technical documentation to allow conformity assessment against Articles 6, 9, 10, 12, 13, and 14. It must include an adequate risk analysis, a general description of the battery and its intended use, and a specimen of the Article 13 label. This is a pre-market obligation — not the same as the digital battery passport.
What must be labelled on a battery under Article 13 of the EU Battery Regulation?
Article 13 requires: the separate-collection symbol (crossed-out wheeled bin, Annex VI Part B) from 18 August 2025; the general information label, capacity label, and non-rechargeable indication from 18 August 2026 or 18 months after the Art. 13(10) implementing act (whichever is later); Cd/Pb chemical symbols if thresholds are exceeded; and a QR code (Annex VI Part C) from 18 February 2027. The CE marking is governed separately by Articles 19–20.
Is the Annex VIII technical documentation the same as the Art. 77 digital battery passport?
No. The Annex VIII technical documentation is the manufacturer's internal conformity file held for inspection by authorities. The Article 77 digital battery passport is a separate, externally accessible structured data record for LMT, industrial batteries above 2 kWh, and EV batteries, accessible through the Art. 13(6) QR code from 18 February 2027.
When does the QR code obligation apply, and does it differ by battery type?
The QR code under Article 13(6) applies from 18 February 2027 for all battery types — one uniform date. What the QR code resolves to differs: for LMT, industrial batteries above 2 kWh, and EV batteries it gives access to the Art. 77 digital passport; for other batteries it links to the Art. 13(1)–(5) labelling information, the EU declaration of conformity, and the relevant waste-management information.
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