QR codes and marking for EV batteries mean a printed QR code on the battery that opens the battery passport for that individual EV battery. The duty applies to EV batteries within the scope of Regulation (EU) 2023/1542, and the QR code duty in Article 13 applies from 18 February 2027. The passport duty in Article 77 gives the QR code its destination for EV batteries, so the code and the passport must be read together, even though marking and passport content remain separate duties.
The key term in this guide is the data carrier. A data carrier is the physical mark that carries a link to an electronic record, and for an EV battery that record is the battery passport. This guide covers EV batteries only, including the QR code, the individual unique identifier, CE marking as distinct from passport marking, placement and legibility under Annex VI Part C, and the scan test that proves the link works. This guide does not cover LMT, portable, or industrial batteries except in one brief contrast sentence, and it does not cover product choice, vehicle choice, or repair advice for a particular vehicle.
What does the QR code open for an EV battery?
For an EV battery, the QR code opens the battery passport. Article 13 requires the QR code, and Article 77 requires the passport, with the QR code serving as the access route to the passport through the individual unique identifier. The code itself holds no passport data of substance. The code holds a link, and the passport held behind that link holds the record. A reader who scans the code should reach the passport for the exact battery that carries the code, not a model page, not a catalogue page, and not a general information page for EV batteries as a class.
That distinction matters at every check. A code that resolves to a correct model description but to the wrong individual battery has failed as a passport carrier, even when the model description looks complete. A code that resolves to a test page, a holding page, or a dead link has also failed, even when the printed code looks sharp and well placed. The test for an EV QR code is therefore a destination test first and a print test second. Print quality matters only because print quality decides whether the destination can be reached reliably in normal use.
The passport behind the code is organised in tiers. Public information, information for parties with a legitimate interest, and information for notified bodies, market surveillance authorities, and the Commission sit in separate tiers under Article 77 and Annex XIII, with detailed access rules set in the implementing act under Article 77. The QR code does not grant entry to a restricted tier by itself. Scanning the code gives entry to the passport system, and access rights then decide what the scanner can see. A member of the public who scans an EV code reaches the public tier. A repairer, recycler, or authority reaches further tiers only where access rights allow that access. The carrier and the access control are separate controls, and neither substitutes for the other.
What is the individual unique identifier?
The individual unique identifier is the identity that ties one physical EV battery to one passport record. The identifier follows the ISO/IEC 15459 series or an equivalent system, as set out for the passport in Article 77. Each EV battery carries its own identifier, and the QR code encodes the link that resolves through that identifier. Two batteries of the same model, made on the same line, in the same batch, still carry different identifiers and different passports. Model identity and individual identity must not be confused, and a check that confirms only the model has not confirmed the passport link.
An identifier register should record the identifier, the battery model, the date the identifier was assigned, and the date the QR code was linked to the passport. The register should also record any change to the link, including a carrier replacement, so that the history of the link can be traced. A register that lists models without individual identifiers cannot prove that a scanned code reaches the right passport. A register that lists identifiers without link dates cannot prove when a code became live or when a broken link was repaired.
A worked record, with illustrative values only, shows the form. Identifier: EV-ILLUSTRATIVE-0001. Model entry: EV pack, illustrative model name only. QR link date: recorded as the date the link was first tested. Scan result: passport reached for identifier EV-ILLUSTRATIVE-0001. The values in this example are illustrative placeholders, not measurements from a real battery, and not values taken from a real pack. The point of the example is the structure of the check, not the values. A real check must use the real identifier, the real model entry, and the real scan result for the battery under check.
How does CE marking differ from passport marking?
CE marking and passport marking answer different questions, and the two marks must not be treated as interchangeable. CE marking states that the battery meets the applicable conformity requirements of Regulation (EU) 2023/1542, following the conformity assessment procedure for that battery. Passport marking, in the sense used in this guide, means the use of the Article 13 QR code as the data carrier for the Article 77 passport. CE marking points to conformity. Passport marking points to a record. A battery can carry a correct CE mark and still fail on passport marking when the QR code resolves to the wrong passport, and a battery can carry a working QR code and still fail on conformity when the CE marking or the declaration behind that marking is wrong.
The evidence behind each mark also sits in a different file. CE evidence sits in technical documentation and the EU declaration of conformity. Passport evidence sits in the passport record and the identifier register. A line by line check should compare the physical marks, the declaration, the technical documentation, and the passport entry, and should record each comparison separately, so that a failure in one file is not hidden by a pass in another file.
| Mark | Question answered | Evidence file |
|---|---|---|
| CE marking | Does the battery meet the applicable conformity requirements | Technical documentation and EU declaration of conformity |
| QR code as passport carrier | Does the code open the passport for this individual battery | Identifier register and scan test log |
| Label information | Does the physical label state the required model, chemistry, and capacity information | Label artwork version and approval record |
A checker who finds a mismatch between the label and the passport should treat the mismatch as a record error until the source of the difference is explained. A capacity value on the label that differs from the capacity value in the passport model tier, without an explained basis for the difference, undermines reliance on both layers. A chemistry statement on the label that differs from the chemistry entry in the passport creates the same problem. Agreement between label and passport is the evidence that the physical battery and the electronic record describe the same object. A capacity value in such a check should name the unit, the method, and the date behind the value, so that the same battery tested again gives a comparable result.
What does Annex VI Part C require for placement and legibility?
Annex VI Part C sets the form rules for marking, including the QR code. The QR code must be in high contrast to the background and of a size easily readable by a commonly available reader. Those two phrases carry the whole placement and legibility test. High contrast means the code stands out from the surface behind that code under normal light, not only under laboratory light. Easily readable by a commonly available reader means a standard smartphone reader, or a comparable common reader, can read the code at a normal distance, in normal light, without special equipment or special software.
Placement must protect that readability through the life of the battery as far as the marking rules require. For an EV battery, placement must be checked after fitting, not only at manufacture. A pack that is marked correctly in the factory can lose carrier access when fitted into a vehicle, covered by a guard, obscured by a mounting bracket, or placed against a surface that blocks scanning. A fitting check should confirm that the carrier remains scannable in the fitted position, or that an alternative access route permitted by the Regulation is provided and documented. A fitting procedure that covers the carrier without a documented alternative creates a marking failure at the point of use, even when the factory marking was correct.
Durability belongs in the same check. Marking must remain visible, legible, and indelible under normal conditions of use for the battery model. For an EV battery, normal conditions include vibration, temperature change, handling during service, and cleaning during service. A label that fades, peels, or becomes illegible during normal use fails the durability purpose even when that label was correct at manufacture. Durability evidence should name the label material, the printing method, the affixing method, and the use conditions relied on for the model. A durability record that links material, method, and use conditions, with a review point after field experience, allows a label failure pattern to be detected before that pattern affects a large number of packs.
How is a scan test recorded?
A scan test proves that the carrier works, and the test log is the evidence. The test starts with a scan using a common reader, in normal light, at a normal distance, on a finished battery. The scanner should be a standard device, not only the manufacturer system, so that the test reflects the experience of a repairer, recycler, or authority who will scan the code later. The test then checks the destination, the identifier, and the model entry behind the destination. A code that resolves to a test page, to a model page for another model, or to a dead link fails the test, and the batch should be held until the destination is corrected and retested.
A scan test log should record, for each battery sampled, the identifier, the scan date, the reader used, the destination reached, and the result. The log should also record the artwork version of the label and the approval date for that artwork, so that a failure can be traced to a printing cause, a placement cause, or a hosting cause. A log that records only a pass mark, without the identifier and the destination, cannot prove which battery was tested or which record was reached. The scan test should be repeated after fitting where fitting can affect access, and after any carrier replacement. A code tested only in the factory, before fitting, has not been tested in the position where the code will be scanned in service.
What happens when a carrier is damaged or replaced?
When a data carrier is damaged, the passport link is broken for scanning, even though the passport record itself may remain intact. The carrier must be replaced with a carrier linked to the same unique identifier, and the replacement must be recorded as a carrier replacement event, with the date, the reason, and the identity check that confirms the new carrier resolves to the same passport. A replacement carrier linked to a new identifier creates a duplicate identity problem, because the physical battery would then point to a passport that does not describe the original battery history. A replacement carrier that is not recorded leaves a gap in the evidence trail.
Carrier replacement should be carried out by a person with access to the identifier and passport systems, and the replacement check should be carried out with a standard scanning device after fitting. A carrier replaced in a workshop and checked only in the workshop system, without an independent scan, has not been verified for the repairer, recycler, or authority who will scan that carrier later. The replacement record should state the checker role, the device type, and the resolution result, so that the replacement can be audited.
Other battery categories follow different QR destinations, but this guide covers EV batteries only.
As checked on 30 October 2026, the access rights and updating rules for passport information depend in part on the implementing act under Article 77. A marking and access plan prepared before that act is final should carry a review date, and the review should check whether the act has changed the access tiers, the updating duties, or the form of the passport link.
This guide gives general educational information only and is not individual legal advice. A reader with a specific battery or market decision should check the current Regulation text and any applicable delegated or implementing act before acting. Marking is the physical promise that the electronic record can be reached, and that promise should be tested after fitting, not only at manufacture.
Sources & further reading
Source links point to primary materials and further reading, including commercial implementation resources where cited. This introductory guide does not replace the legislation.