A scan does not show the whole passport. It shows the public information for that one battery, and it proves only that the code resolves to a record for the battery in hand. Restricted information stays behind access controls, and a working scan says nothing about whether the record is complete, current or correct.
| What a scan can show | What a scan cannot prove |
|---|---|
| That the code resolves to a record for this battery | That the record is complete |
| Public model information for the battery | That restricted tiers are set correctly |
| That the record could be reached today | That it will still resolve in ten years |
| The current status shown in the record | That every value in the record is accurate |
How does a battery passport QR code work?
For an in-scope battery, the QR code is the physical route to its electronic passport. Article 77(3) of the EU Batteries Regulation says the code referred to in Article 13(6) links to a unique identifier attributed to the battery by the economic operator placing it on the market. The code, identifier and digital record are related but distinct. A successful scan must lead to information for the correct individual battery, with access governed by the applicable rules.
The wider Article 13(6) QR-code rule begins on 18 February 2027 for all batteries. Only the categories specified in Article 77 require the battery passport at that date; the code for other batteries provides access to other specified information. See the EU passport scope guide before treating every battery QR code as a passport.
What should the code connect?
| Layer | Purpose | Failure to test for |
|---|---|---|
| Printed or engraved code | Allows a device to read the carrier | Damage, poor contrast, inaccessible placement |
| Unique identifier | Distinguishes the battery | Collision, reuse or wrong unit association |
| Resolution path | Connects the identifier to a record | Broken domain, redirect or provider migration |
| Passport record | Supplies the relevant information | Wrong model revision, stale data or access leak |
The regulation references ISO/IEC 15459 parts 1 through 6 or equivalent standards for the QR code and unique identifier. This article does not replace the standards or provide a barcode conformance test. The distinction helps teams ask the right questions of their identifier provider.
Where must the QR code appear?
Article 13(7) calls for the labels and QR code to be printed or engraved visibly, legibly and indelibly on the battery. Where that is not possible or not warranted because of the nature and size of the battery, the provision describes placement on packaging and accompanying documents. Product design and marking review should use the exact current provision rather than a generic instruction to “put a sticker on it.”
For a practical pilot, test scans after ordinary handling, under realistic lighting and from the intended placement. This is an operational check, not an official certification protocol. The QR code should still identify the correct record after a data update; an update should not silently point it to a different unit.
Does the QR code contain the whole passport?
No. The regulation describes access through the code to a unique identifier and passport. The information can live in a connected digital system. A code that contains a short address or identifier should not be confused with a complete offline copy of the data. A direct URL may be part of a technical implementation, but continuity, identity and interoperability need to be assessed as a whole.
A printed code can remain physically readable while its online destination fails. Assign an owner to the identifier namespace, domain or resolver and document what happens if hosting, vendors or corporate ownership changes. Article 78’s availability and interoperability requirements make that long-term question important.
What should a scan reveal?
Access is not all-or-nothing. Annex XIII identifies public model information and information reserved for specified bodies or persons with a legitimate interest. An ordinary scan should not expose a restricted dismantling file or unit-use dataset merely because both relate to the same battery. At the same time, access rights should not make public information unusable.
Test three separate experiences: an unauthenticated reader, an authorised role with a legitimate use case, and an editor who updates information. Verify the returned record, permissions and audit trail for each. The data requirements guide explains field-level access mapping.
A scan-path test before rollout
- Select a non-sensitive representative battery and approved unique identifier.
- Scan the production-format mark with multiple devices.
- Confirm the identifier resolves to that battery and the right model revision.
- Check public and restricted views separately.
- Change a test field through its authorised workflow; confirm the record reflects the approved update.
- Simulate a redirect or system migration and verify that the printed code still reaches the correct record.
- Record failures, owners and retest criteria.
This is a systems test, not proof of regulatory conformity. Ask the provider to show how identifiers can be exported, kept unique and maintained if the service ends. The software evaluation guide provides a broader demonstration plan.
Frequent questions
Is a working QR link enough for compliance?
No. It does not establish correct category scope, required information, accuracy, access rights, interoperability or durable availability.
Can the same code point to changing information?
The connected record can be updated under controlled rights. The identifier-to-battery association should remain reliable; test how revisions and status changes are represented. Article 77 has specific rules for new linked passports after certain lifecycle operations.
Is every scanned field public?
No. Annex XIII and Article 77 distinguish access groups. Design the public experience and restricted access from those provisions, not from a vendor’s default sharing setting.
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.