How Is CE Marking Applied to Batteries?

CE marking for batteries is the marking by which a manufacturer indicates that a battery conforms with the applicable Union harmonisation legislation, including Regulation (EU) 2023/1542, after conformity assessment has been carried out. Articles 19 and 20 set the general principles and the rules for affixing CE marking, including visibility, legibility, indelibility, placement and the addition of the notified body identification number where a notified body was involved in the production control phase. CE marking is a conformity indication, not a quality mark, a safety guarantee or a passport, and it must not be confused with any of those.

CE marking work is a sequence, not a label printing task. Assessment first, declaration second, marking third, with the marking reflecting the assessment route and the notified body involvement that actually took place. A marking affixed before assessment, or a marking with a notified body number where no notified body was involved, misstates the conformity route even when the battery is sound. The marking file should show the sequence, so that the marking can be traced to the assessment that supports it.

When must CE marking be affixed?

CE marking must be affixed before a battery is placed on the market, after conformity assessment has been carried out and the declaration of conformity has been drawn up. The marking applies to batteries within the scope of the Regulation, subject to the application dates for CE marking duties, which generally applied from 18 August 2024 for the initial CE marking requirements, with further labelling elements following on later dates. A battery placed on the market without CE marking, where marking is required, is non-compliant on marking alone, even when the underlying battery meets the technical requirements.

A placing checklist should list assessment completion, declaration signing and marking affixing as separate gated steps, each with a date and an evidence reference. A checklist that lists only the placing date, without the three gates, cannot show that marking followed assessment. A gated checklist allows a placing to be held where any gate is open, and it provides the evidence that an authority will request.

How must CE marking be presented?

CE marking must be visible, legible and indelible, affixed to the battery, or, where the size or nature of the battery makes direct affixing impracticable, to the packaging or accompanying documents as the Regulation provides. The marking must follow the form set in the Regulation, with the correct proportions and without alteration that changes its meaning. A marking that is present but illegible, removable or obscured by fitting does not meet the presentation duty, even when the marking was correct at manufacture.

Worked check: a battery is marked at manufacture with a correct CE mark, but the mark is placed where a mounting bracket covers it after fitting. The fitted battery fails the visibility check, even though the factory check passed. The correction is to move the marking to a visible position on the fitted battery, or to use a permitted alternative presentation, with the change recorded. A factory only check misses the fitted position failure, and the check should be carried out after fitting.

When is a notified body number added?

A notified body identification number is added after the CE marking where a notified body was involved in the production control phase, under Module D1 or Module G, or where the Regulation provides for the number to follow the marking. The number must be that of the notified body that carried out the production control tasks, and it must not be added where the assessment route was Module A without notified body involvement, or where a different body carried out the tasks. A number added without notified body involvement, or a number for the wrong body, misstates the assessment route.

Number checking should compare the marking, the declaration and the notified body certificate or notification, with the body number identical in all three sources. A difference in number between any two sources should be treated as a record error and corrected before placing. The check should be carried out for each model and variant, because a variant assessed under a different module may carry a different marking presentation. A shared marking across variants with different modules will be wrong for at least one variant.

How does CE marking interact with other markings?

CE marking interacts with other markings, including the separate collection symbol, the QR code, capacity and chemistry labelling, and any other Union harmonisation marking that applies to the battery or the product incorporating it. Each marking must be presented without obscuring another, and the combined marking set must be legible as a whole. A battery that carries CE marking but obscures the separate collection symbol, or a QR code that covers the CE marking, fails the combined presentation duty even when each marking is correct alone.

Combined marking design should be checked as a set, on the finished battery and after fitting, with each marking identified and its legibility confirmed. A design check that reviews each marking artwork separately, without checking the combined presentation, misses overlap and obscuring errors. The combined check should be recorded with a photograph or diagram of the finished marking set, so that a later reviewer can see the presentation that was approved.

What marking mistakes are most common?

Common marking mistakes include affixing CE marking before assessment, adding a notified body number without involvement, using an incorrect CE form, placing the marking where it is obscured, and affixing CE marking to a battery outside the scope of the marking duty. Each mistake is a marking nonconformity, and each can lead to market surveillance action even when the battery meets the technical requirements. The correction in each case is to return to the assessment file, confirm the route and the body involvement, and re-mark the battery in the correct form and position.

Marking review should sample finished batteries from production, not only artwork, because production variation in printing, placement and durability can introduce errors that artwork review misses. A sample review that covers each model, each variant and each production site, with the sample results filed, provides stronger evidence than an artwork approval alone. The review should be repeated after a marking material, printing or placement change.

How is CE marking evidenced?

CE marking is evidenced by the marking itself, the declaration, the technical documentation, the assessment reports and, where applicable, the notified body certificate or notification. The evidence file should link the marking to the assessment route, so that an authority can trace the mark to the file without inference. As checked on 28 October 2026, CE marking duties should be checked per Member State presentation and per battery model, with the file dated. 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 act, as checked on 28 October 2026, before acting.

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 act, as checked on 28 October 2026, before acting. Marking follows assessment, and the fitted position check is part of the marking evidence.