What Labelling Must a Portable Battery Carry?

Portable labelling is the set of physical label, marking and symbol duties for portable batteries under Article 13 and Annex VI to Regulation (EU) 2023/1542. Labelling applies to every portable battery within scope, whether or not the battery carries a passport, and it is the main information layer that a holder, retailer or collector sees without scanning a code. The label must be correct, legible and durable, and it must agree with the technical documentation for the battery model.

Labelling duties are phased by element and date. The separate collection symbol, capacity information, chemistry information and QR code each have application dates within the labelling timetable, and a label that is complete for one date may be incomplete for a later date. A labelling plan should therefore be drawn as a dated set of elements, with each element marked for its application date, rather than as a single label design that is assumed to cover every date.

What information must a portable label carry?

A portable label must carry manufacturer identification, battery category and type, chemistry, capacity information where required, hazardous substance information where relevant, critical raw material information where relevant, and the separate collection symbol. Rechargeable portable batteries carry capacity information, and non-rechargeable portable batteries carry minimum average duration information and a non-rechargeable marking. The full set is defined in Article 13 and Annex VI, and the label must present the set in a form that is visible, legible and indelible.

A label check should compare each element against the technical documentation, with the element, the value and the source recorded. A label that omits chemistry, or that states a capacity value that differs from the documentation, fails the check even when the remaining elements are correct. The check should be carried out for each model and variant, because a variant with a different chemistry or capacity needs a different label, and a shared label across variants will misstate at least one variant.

When does each labelling element apply?

Labelling elements apply on the dates set in Article 13. The separate collection symbol applies from 18 August 2025. General label information, including manufacturer, category, chemistry and capacity presentation, applies from 18 August 2026. The QR code applies from 18 February 2027. A label prepared for the 2025 date will lack elements required in 2026, and a label prepared for 2026 will lack the QR code required in 2027, so the labelling timetable must be planned as a sequence of label versions.

Worked check: a portable pack is placed on the market in September 2026. The label must carry the separate collection symbol and the general information set, but the QR code duty has not yet applied. The same pack placed on the market in March 2027 must also carry the QR code. A labelling file that uses one version for both placings will be incomplete for one of them, and the version must be tied to the placing date.

How is the separate collection symbol presented?

The separate collection symbol is the crossed out wheeled bin symbol, presented with the chemical symbols for cadmium and lead where the thresholds in the Regulation are exceeded. The symbol must be visible and legible on the battery, subject to the size provisions that allow the symbol to be presented on packaging or accompanying documents where the battery size makes direct marking impracticable. For small portable cells, the size provision is frequently relevant, and the presentation route must be recorded.

A symbol check should confirm the symbol, the chemical symbols where required, the size and legibility, and the presentation route. A symbol that is present but too small to be legible, or a chemical symbol omitted where the threshold is exceeded, fails the check. The check should be carried out on the finished battery as placed on the market, including any packaging presentation, because a symbol correct in artwork but omitted in production fails in use.

What capacity information is required?

Capacity information for rechargeable portable batteries is presented as capacity in ampere hours or milliampere hours as set in the labelling provisions, with the value taken from the technical documentation. Non-rechargeable portable batteries carry minimum average duration information instead of rechargeable capacity presentation, together with a marking that the battery is non-rechargeable. The two presentations must not be mixed, because a duration value presented as a rechargeable capacity, or a capacity value presented without rechargeability status, misleads a buyer about the battery type.

Capacity values should be verified against test evidence for the model, with the test basis recorded. A capacity value copied from a supplier sheet without verification, or a duration value estimated from a similar cell, is weak evidence. The verification record should state the test method, the sample basis and the date, so that a later query about the label value can be answered from evidence rather than from a supplier claim.

How are small batteries labelled?

Small portable batteries, including button cells and other small formats, are labelled under the size provisions in Article 13, which allow information to be presented on packaging or in accompanying documents where the battery itself is too small for the full label set. The allowance is a presentation allowance, not an information exemption: the information must still be provided, and the route by which the holder receives it must be clear. A small battery sold loose, without packaging or documents, cannot rely on a packaging route that the holder never receives.

A small battery labelling file should state the battery size, the information that cannot be presented directly, the alternative presentation route, and the evidence that the holder receives the information through that route. A file that states only that the battery is small, without the alternative route, is incomplete. A file that uses the packaging route for a battery sold loose is incorrect, and the labelling presentation must be redesigned for the actual supply route.

How are label and QR code checked together?

Label and QR code checks should be carried out together at the placing date, because the two layers must agree and must both be present where required. The combined check covers label completeness, symbol correctness, capacity agreement with documentation, carrier presence, carrier legibility and carrier resolution. As checked on 28 October 2026, the QR code for a portable battery provides access to the Article 13 information, not to a passport, and the resolution check should confirm that result. 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. Labelling is a dated set of elements, and each version should be tied to the placing date it serves.