How Do QR Codes and Marking Work for LMT Batteries?

QR and marking for LMT batteries covers the data carrier, the label information and the symbols that must appear on the battery, as set out in Article 13 of Regulation (EU) 2023/1542. From 18 February 2027, batteries within scope must be marked with a QR code, and for LMT batteries that QR code provides access to the battery passport. The QR code is the key to the record, not the record itself, and marking duties and passport duties must be kept distinct even though they share the same date and the same carrier.

Marking work is physical as well as digital. A carrier that is printed correctly but placed where it is damaged, covered or removed during fitting will fail in use. A label that is complete at manufacture but illegible after outdoor use will fail at the point where a repairer or recycler needs it. Marking discipline therefore covers content, placement, durability and resolution, and each element needs a check at manufacture, at fitting and at handover.

What must the QR code do for an LMT battery?

The QR code for an LMT battery must provide access to the battery passport through the unique identifier, in a form that resolves reliably when scanned. The code must be affixed to the battery, must be visible and legible, and must remain accessible through the life of the battery as far as the marking rules require. The code links to the passport record held by the responsible operator or an authorised operator, and the link must survive changes to the underlying hosting arrangement where the Regulation requires the passport to remain available.

A QR check should be carried out with a standard scanning device, not only with the manufacturer system, and should confirm that the scan resolves to the correct passport and the correct unique identifier. A code that resolves only inside a closed application, or only when the manufacturer system is available through a private route, does not meet the access purpose of the public and legitimate interest tiers. The check should be recorded with the device used, the date and the resolution result, so that a later failure can be traced to a printing, placement or hosting cause.

What label information accompanies the QR code?

Label information for batteries includes manufacturer identification, battery category, chemistry, capacity, hazardous substance information where relevant, critical raw material information where relevant, and the separate collection symbol, with the full set and the application dates set in Article 13 and Annex VI. Capacity information for rechargeable LMT batteries, and the separate collection symbol, follow their own application dates within the labelling timetable. The label is the physical information layer, and the passport is the electronic record layer, and the two layers must agree on model, chemistry and capacity presentation.

Worked check: a pack label states a capacity value, the passport model tier states the same capacity value, and the QR code resolves to that passport. The three sources agree, and a repairer can rely on the capacity presentation. A second pack label states a capacity value that differs from the passport model tier by a rounding difference that is not explained. The difference should be treated as a record error, not as a rounding tolerance, until the manufacturer information explains the basis. Unexplained differences erode reliance on both layers.

Where must marking be placed on an LMT battery?

Marking must be placed on the battery itself, subject to the size and design provisions in Article 13 that allow marking on packaging or accompanying documents where the battery size or design makes direct marking impracticable. For LMT packs, which are generally large enough for direct marking, the expectation is direct marking on the pack in a position that remains visible and accessible after fitting, subject to the detailed placement rules. A carrier placed inside a housing, under a cover that requires tools to remove, or on a removable accessory does not meet the accessibility purpose.

Placement should 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 frame, covered by a guard or obscured by a mounting bracket. The 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.

How durable must marking be?

Marking must be visible, legible and indelible, in the terms used in the Regulation for CE marking and label durability. For LMT batteries used outdoors, exposed to weather, vibration and handling, durability means resistance to the conditions of normal use, cleaning and storage for the battery model. A label that fades, peels or becomes illegible during normal use fails the durability purpose even when it was correct at manufacture. Durability testing and material selection for the label and carrier are therefore part of conformity evidence, not a printing choice alone.

Durability evidence should include the label material, printing method, adhesion or affixing method, and any test or field evidence relied on for the expected use conditions. A durability claim based only on a supplier statement, without a link to the use conditions of the LMT model, is weak evidence. A durability record that links material, method and use conditions, with a review point after field experience, is stronger evidence and allows a label failure pattern to be detected before it affects a large number of packs.

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, and 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 it later. The replacement record should state the checker, the device type and the resolution result, so that the replacement can be audited.

How do marking and passport access tiers interact?

Marking provides the entry point to the passport, and access tiers control what the entrant can see after entry. The QR code itself does not grant access to restricted tiers; access rights in Annex XIII and the implementing act under Article 77 govern what each actor can see. A member of the public who scans a code reaches the public tier. A repairer, recycler, notified body or authority reaches further tiers only where access rights allow it. The carrier and the access control are separate controls, and neither substitutes for the other.

As checked on 28 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. 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 is the physical promise that the electronic record can be reached, and the promise should be tested after fitting, not only at manufacture.